The challenge for data sharing has<\/strong> a major role for all actors in the financial ecosystem, so:<\/p>\r\n\r\n\r\n\r\n There is no doubt that the payment services directive ( PSD2<\/strong> ) (1) (2)<\/em> served as a forerunner to Open Finance<\/em> ( or Open Banking) because it highlighted the opportunities that arise from data and data sharing<\/strong> with the aim of increasing the competition and therefore improve efficiency as well as the security and convenience of payments and money management. In fact, PSD2<\/strong> allows the so-called Third Party<\/strong> suppliers – authorized – to access the customer’s (current\/payment) account data to provide services that can be grouped into two macro-categories:<\/p>\r\n\r\n\r\n\r\n The PSD2<\/strong> gives the customer the right to use the services provided by Third Party<\/strong> – other than their own bank – and, to be able to withdraw the authorization to access bank account information at any time.<\/p>\r\n\r\n\r\n\r\n Open Finance<\/em>\/Open Banking is the natural evolution of PSD2<\/strong>. Thanks to Open Finance<\/em>, the Third Parties<\/strong> will be able to access many other financial data of individual customers – subject to authorization<\/em> -, relating for example to their mortgages<\/strong>, insurance<\/strong>, investments<\/strong>, pension funds<\/strong> but also to how much money a customer can save monthly<\/strong> and deposit on a possible savings account.<\/p>\r\n\r\n\r\n\r\n The Third Parties<\/strong> may also use the data aggregated with other data to provide new services<\/strong> or integrate their services<\/strong> with those of other Third Parties<\/strong>. Think, for example, of the possibility of offering customers, other companies (also in the financial sector) that offer the same services at more advantageous economic conditions<\/strong> or offer new types of information<\/strong> and information<\/strong> reports.<\/p>\r\n\r\n\r\n\r\n With Open Finance it<\/em> is also possible to combine<\/strong> the two macro-categories: customer account information with payment initiation services. Among the scenarios, the possibility of service providers who make<\/strong> financial decisions<\/strong> on behalf of clients. In this case, think, for example, of:<\/p>\r\n\r\n\r\n\r\n The range of possibilities and choices for the customer grows exponentially.<\/p>\r\n\r\n\r\n\r\n PSD2<\/strong> and Open Finance are part of a much broader Turkey or Europe\u2019s objectives: social development through regulated open data<\/strong> and bringing clarity – rights, duties, limits, and obligations – to practices that, in some cases, have already been carried out. Open banking in Turkey is too popular with Legislative Decree 6493 Law on Payment And Securities Settlement Systems, Payment Services and Electronic Money Institutions<\/a><\/p>\r\n\r\n\r\n\r\n It is clear to everyone that the digital technology that is transforming people’s habits and lives cannot be stopped but can only be governed<\/strong> – so that the benefits are to the benefit of citizens and businesses also by creating the framework the legislation for digital transformation.<\/p>\r\n\r\n\r\n\r\n For example, according to European strategy, The European context for the development of digitization includes:<\/p>\r\n\r\n\r\n\r\n A few weeks ago the European Data Strategy <\/strong>(7) (8)<\/em> was published with the planning of activities for the realization of the digital single market<\/strong> of data and artificial intelligence (9)<\/em>. The aim of the strategy is to ” create a true single data market that ensures the security of <\/em>personal and non-personal<\/em><\/strong> data, including confidential and sensitive data and offers businesses and the public sector easy access to large quantities of high-quality data. to create and innovate<\/em> ” (10)<\/em>.<\/p>\r\n\r\n\r\n\r\n The single data market allows the free flow of data within the EU and in all sectors for the benefit of businesses, researchers, public administrations. Among the possibilities that emerge, we can think of the development of tools – for the benefit of individuals and organizations – to make more accurate decisions because they are derived from objective data. The data available could concern public and private information relating to telecommunication activities, energy consumption, geographical locations, medical and legal records, leisure activities, etc.<\/p>\r\n\r\n\r\n\r\n It is good to underline that the sharing of data is not an easy and automatic thing but the experience, even if recent, of the PSD2,<\/strong> can serve to remove some obstacles to get Open Finance<\/em> to take off and guarantee:<\/p>\r\n\r\n\r\n\r\n 1. Standardized data access<\/strong>. The difficulty of accessing data and the lack of standardization of the tools to facilitate access ( API <\/strong>– Application Programming Interface<\/em> ) are the causes of the fragmentation<\/strong> of the market for PSD2<\/strong> services. Fragmentation makes it difficult for third parties to offer their services across Europe in scalable<\/em><\/strong> form, effectively <\/em><\/strong>limiting the possibilities and economic benefits for customers. The recent entry of the Integrators<\/em> – intermediaries between Banks and Third Parties – allows limiting fragmentation.<\/p>\r\n\r\n\r\n\r\n The advantage of open data ( Open Data<\/em> ) for the benefit of the whole society is only captured with: a) standardized data access by third parties (to avoid fragmentation); b) efficient and secure access.<\/p>\r\n\r\n\r\n\r\n 2. Legislation that looks to the future<\/strong>. Cooperation and dialogue between legislators, regulators and public authorities<\/strong> involved in data sharing are desirable in the planning phase of laws and regulations to enact long-term rules.<\/p>\r\n\r\n\r\n\r\n Two dimensions are to be taken into consideration: the international one; and protecting public interests related to data sharing.<\/p>\r\n\r\n\r\n\r\n Consider, for example, that:<\/p>\r\n\r\n\r\n\r\n Ex-ante<\/em> cooperation, ie in the planning<\/strong> phase of laws<\/strong> and regulations precisely to mitigate<\/strong> the risks of contagion, becomes fundamental. In this sense, the EU legislative acts of December 2019 are to be considered to strengthen the role of the European Supervisory Authorities ( AEV<\/strong> ) (11)<\/em> with the aim of promoting the convergence of National Supervisory Authorities.<\/p>\r\n\r\n\r\n\r\n The use and analysis of data is an area characterized by recent and innovative developments with still little jurisprudence, where the risk scenario linked to possible conflicts between the various protected public interests is real (for example security, privacy, risks of concentration). The recent news that the judge has declared illegal for a violation of the right to privacy<\/em>, the system used by the Dutch government to counter fraud in social assistance benefits and the tax authorities.<\/p>\r\n\r\n\r\n\r\n Cooperation and dialogue allow us to make a decisive contribution upstream – in the planning phase – and create regulations that achieve public objectives<\/strong>, are projected into the future and smooth out possible conflicts (ie privacy<\/em>, fraud, security, etc.). In the case of sharing financial data, the stakeholders<\/em><\/strong> include the central bank, the competition and market authority, the authority for the protection of personal data.<\/p>\r\n\r\n\r\n\r\n The Trust<\/strong> – with a capital letter – is the basis of the relationship with consumers. In fact, if consumers do not trust they will not allow access to their data and will not use the services offered by Third Parties<\/strong>. Consumers are unwilling to share their payment data with their bank, are reluctant to share with other banks and even more so with non-bank entities. For Third Parties it<\/strong> is essential to build and maintain<\/strong> consumer confidence: it is the key to accessing their data. So, clarity<\/strong> on who are the parties that have access to their data and ease to<\/strong> grant or withdraw explicit consent to the<\/strong> use of the data.<\/p>\r\n\r\n\r\n\r\n The development of Open Finance<\/em> allows third parties<\/strong> access to large quantities of sensitive financial data but with an exponentially negative impact in the event of any abuse<\/strong> and fraud<\/strong>. Real consumer protection and safety are essential to ensure that sharing with third parties<\/strong> becomes the rule<\/strong> and you can fully benefit from the opportunities of open finance<\/em> and open data.<\/p>\r\n\r\n\r\n\r\n Digitization and open data can revolutionize the economy and change people’s lives.<\/em><\/strong><\/p>\r\n\r\n\r\n\r\n If you would like to more information on macroeconomic analysis for Europe or Turkey, we welcome\u00a0you to\u00a0get in touch with our specialists.<\/a><\/strong><\/p>\r\n\r\n\r\n For further information and regulations, consult the following links and \/ or references:<\/em><\/p>\r\n\r\n\r\n\r\n (1)\u00a0 \u00a0 <\/em>EU Directive 2015\/2366, Payment Services in the internal market<\/a><\/p>\r\n\r\n\r\n\r\n (2)\u00a0 \u00a0 <\/em>EU Delegated Regulation 2018\/389, Authentication and Communication Standards<\/a><\/p>\r\n\r\n\r\n\r\n (3)\u00a0 \u00a0 <\/em>EU Regulation 2018\/1807, Free movement of non-personal data<\/a><\/p>\r\n\r\n\r\n\r\n (4)\u00a0 \u00a0 <\/em>EU Regulation 2019\/881, Cybersecurity<\/a><\/p>\r\n\r\n\r\n\r\n (5)\u00a0 \u00a0 <\/em>EU Regulation 2016\/679, Protection of Personal Data (GDPR)<\/a><\/p>\r\n\r\n\r\n\r\n (6) \u00a0 <\/em>EU Directive 2019\/1024, Open Data<\/a><\/p>\r\n\r\n\r\n\r\n (7)\u00a0 \u00a0 <\/em>European data strategy (EN)<\/em>\u00a0 – European Commission, 19-02-2020<\/a><\/p>\r\n\r\n\r\n\r\n (8) \u00a0 <\/em>Shaping Europe’s Digital Future – A European Strategy for Data – European Commission, 10-03-2020<\/a><\/p>\r\n\r\n\r\n\r\n (9)\u00a0 \u00a0 <\/em>White Paper on Artificial Intelligence – European Commission, 19-02-2020<\/a><\/p>\r\n\r\n\r\n\r\n\r\n
FROM PSD2 TO <\/strong>OPEN FINANCE<\/em><\/strong><\/h3>\r\n\r\n\r\n\r\n
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AN IDEAL <\/strong>OPEN DATA<\/em><\/strong> STRATEGY OR OPEN DATA<\/strong><\/h3>\r\n\r\n\r\n\r\n
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\r\nWHAT ARE THE CRITICALITIES AND HOW TO OVERCOME THEM<\/strong><\/h3>\r\n\r\n\r\n\r\n
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International dimension<\/strong>.<\/h4>\r\n\r\n\r\n\r\n
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Protection of public interests<\/strong>.<\/h4>\r\n\r\n\r\n\r\n
The full trust of people for the control of their data<\/strong>.<\/h4>\r\n\r\n\r\n\r\n
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