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Location
Stuttgart
Member since
2013
Writes about
Payments Regulation & Compliance

Ralf's blog archive

2019 (1) 2017 (1) 2016 (3) 2015 (4)
Ralf Ohlhausen

Ralf Ohlhausen

Executive Advisor at Pay Practice
Message Message me Posts: 9 Comments: 24
Bio Payments expert in Open Banking, PSD2, Public Policy, E-Commerce and Central Banking matters. Executive advisor to PPRO, Tink, and other fintechs. ECB/ERPB and ECB/MIB board member, Vice-chairman of the European TPP Association (ETPPA) and Co-chair of the Berlin Group NextGenPSD2 API advisory board. Career History MSc in Math and MBA in Telecoms, 30 years experience in e-commerce, financial services, mobile telecommunications and IT. Previously BD Director PPRO Group, President Europe SafetyPay, Group Products Director Digicel, Group Products Strategy O2, IT Director BT Europe and Project Director Mannesmann.

Blogs

 

Obstacles per se

17 Aug 2019

The closer we come to 14th September 2019, the implementation deadline for the RTS on SCA & CSC, which details much of the PSD2 legislation, the less room we have for unclarity about its stipulations. One of these open points and maybe the most important one is the definition of an “obstacle” in the sense of RTS Art 32(3). The RTS stipulates a...

 

The EBA is wrong about screen scraping - and it’s going to hurt European fintech!

23 Mar 2017

On 23 February, the European Banking Authority (EBA) announced its intention to outlaw ”screen scraping” in one of their Regulatory Technical Standards (RTS) complementing the revised Payment Services Directive (PSD2), set to come into force in January 2018. Screen scraping sounds sinister. In fact, it simply refers to the practice of automating a...

2

 

Brexit: a body blow for UK fintech?

22 Jun 2016

With less than one day to the UK referendum on whether to remain in the European Union, debate on the potential impact of Brexit is intensifying. While some of the recent campaigning directed at voters appears designed to provoke a knee-jerk reaction, businesses and industry bodies are taking a more considered, analytical view. Analysis released b...

 

Open banking API vs PSD2: the UK is taking the lead again!

04 Mar 2016

The conclusions of the UK’s Open Banking Working Group’s recently released report confirm that once again the UK is a step ahead of its European neighbours. The report’s call for an open banking standard and an open banking API demonstrates that while the rest of Europe has been battling out compromises in the PSD2 revision that will give Third P...

2

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Ralf is Commenting on

PSD2 - 10 questions I would like to see a clear answer on

  I reckon I can answer most of these, just contact me under ro@paypractice.com.

25 Sep 2019 Reply Read article

Why we’re nowhere near delivering on PSD2’s bold ambition

  Rather than reinventing Open Banking, the UK should have looked at other EU countries practicing it for over 10 years already and having very successful bank-agreed payment execution services (PES) and bank-independent payment initiation services (PIS). Listening to their advice and not taking the worst of both worlds, would have helped to understand the difference between the two and what needs PSD2 licensing and what not. Rather than prescribing a “user experience” it is of paramount importance to leave this area to innovation and competition. After all, that’s the whole point of Open Banking!  

25 Jan 2019 Reply Read article

Open Banking vs. Screen Scraping: looking ahead in 2019

  The UK version of Open Banking forces customers to do all the authentication and authorisation themselves using the bank's user interface. Replacing screen scraping with APIs is great, but depriving TPPs from acting on behalf of the customer and automating the payment flow defies the whole point of PSD2 and throws the baby out with the bathwater. The user experience is the key element here and any single unnecessary screen or click can kill the take up. Don't expect mass adoption as long as consumers are redirected back and forth and have to go through more than one screen.

07 Jan 2019 Reply Read article

Learning from the UK open banking experience

  Open Banking, at least in the form of PSD2, wasn’t designed to eliminate credential sharing. It was designed to secure this common practice by bringing it under a licensing regime to ensure that credentials stay safe within supervised and security audited financial institutions. This is to allow licensed TPPs to own the front end and compete in providing the best user experience and most compelling services. Open Banking in the form of bank-redirect services like iDEAL, MyBank, giropay, etc. do not fall under PSD2, because they do not need that level of supervision, exactly because they don’t use credential sharing. Open Banking, as designed in the UK, should fall into that latter category, because it allows the banks to control most of the user experience, at least from a PISP perspective. I would argue that users are actually initiating the payments themselves in that case, meaning that the use of OB UK should not need a PSD2 license either. Why burden UK OB PISPs with all that regulatory overhead, if they don’t have to secure anything and can’t do anything different to PayByBankApp aka Zapp for which no license is required? Many more TPPs would enter the UK market if UK OB was either license free or would allow them services, which do not require a redirect to the bank’s website or app.

25 Oct 2018 Reply Read article