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Good write-up. Relicensing could be added .. as it is likely to be on the critical time-line, and must be initiated despite the uncertainty (and faint hopes) the costs and manouevers involved will not be needed (in case of a transition agreeement).

This must be the way to go, now that PSD2 is here. Have a bank common standard (e g ISO 20022 based) interface, and central testing framework for TPPs and PSPs, to minimise work for all. There needs to be a clear framework as well for what consent the data owner (account holder) must give, and how that is handled, in addition to a clear delineation of the steps by which increasing amounts of data is shared, i.e. only balance on account, reserving amounts in case of delayed booking, selected transaction history, CT initiation for predefined amount to select beneficiaries, approval of beneficiaries, etc.. A similar continental European initiative ought to be launched.

After spending two days in London with the L39 people, meeting a few start-up banks and founders of a series of FinTechs as well as the UK T&I people I am amazed at the speed, available funding and commitment of the people engaged. More and more players in banking, insurance, brokerage, clearing and settlement infrastructures are realizing that the Future Bank is being recreated here and now. UBS is one of the foresightful ones.