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Response to consultation on the Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance under PSD2
Go backQuestion 1: Do you agree with the requirement that competent authorities require undertakings to review, and if necessary re-calculate, the minimum monetary amount of the PII or comparable guarantee, and that they do so at least on an annual basis, as proposed in Guideline 8?
Annual seems a reasonable period and consistent with insurance policies.Question 6: Do you think the EBA should consider any other criteria and/or indicators to ensure that the minimum amount is adequate to cover the potential liabilities of PISPs/AISPs in accordance with the Directive? Please explain your reasoning.
Should the calculations take the greater of the last 12 months or the projected volumes for the next 12 months? Someone new to the market would have a greater insurance requirement than someone that had been in pilot mode and about to grow extensively?Question 7: Do you have any other comments or suggestions that you think the EBA should consider in order to ensure that the minimum amount is adequate to cover the potential liabilities of PISPs/AISPs in accordance with the Directive? Please explain your reasoning.
It may be more sensible to round the resulting required levels of cover up to the nearest 10 or 100 thousand to reflect the fact these are estimates and not some precise level of cover.Please select which category best describes you and/or your organisation
[Other "]"Please select which category best describes the services provided by you/your organisation
[Other"]"Name of organisation
Optima Consultancy
