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Hi Chris,

good post, let me add some thoughts....as regards direct debits, on should read carefully no. 18 in EBA's consultation paper. It may appear that also direct debits are affected to some extent.

It is particularly astonishing that EBA takes so much emphasis on pull payments like cards. Just recently, the british consumer organisation Which put forward a super complaint regarding better protection of victims of fraud in push payments. In its reasoning, Which proposed the view that for pull payments like cards and direct debits, liability is allocated appropriately and banks have approaches for reducing risk. So, at least the consumer organisations seem to be happy with the current procedures......

In my view, the EBA draft does not sufficiently reflect the essential features of push payment schemes and pull payment schemes respectively. Whereas a multi layered security (merchant, gateway, acquirer, issuer) is inherent to  pull payment such as cards, security in push payment schemes draws primarily on the authentication of the payer through its bank.

Accordingly, security requirements which may be indispensible for push payment schemes may be considered as inproportionate for pull payment schemes......EBA is mandated to apply "business model neutrality" but this does not mean to ignore the essential features of different sorts of payment schemes.

JM2C

Christoph