Other · Spain
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Letrado nº 94.416 del Colegio de la Abogacia de Madrid filed 2 positions on 31 Oct 2023, across 1 of the 665 legislative files tracked here, attaching a full position paper 2 times.
Comment on Article 59 of the PSR1 proposal: The PSR1 proposal identifies an error in PSD2: in a context of fraud, the diffuse difference between authorised and unauthorised transactions, owing to a defect in consent or even lack of consent. However, it seeks to amend it in Article 59 in a way which, in our view, is contrary to the principles of law.
Filed in Spanish · English published by the European Commission
Comment on Article 55 of the PSR1 Proposal It is positive that the proposed Regulation is not unrealistic and addresses in the preamble one of the biggest problems faced by payment service providers: the disproportion and high financial cost they bear when opening each fraudulent transaction, whether authorised or not, to a systematic reimbursement right in cases of impersonation, see recital 79.
Filed in Spanish · English published by the European Commission
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