In regards to Open Banking for our customers in Europe, we'd like to share the following:
Currently we believe there is no need for us to obtain certification as we're working with SaltEdge. SaltEdge is licensed AISP and TSP and as such they are able to legally connect to a customer's bank to retrieve and display the data and, assuming the said customer gives their permission. The customer will also be in a position to grant MoneyWiz the permission to display the data SaltEdge has obtained as well. The customer will further be able to withdraw such permissions at any time he or she desires.
Here in an excerpt from the FCA handbook about this scenario:
"An agent of an account information service provider cannot provide or purport to provide account information services in its own right. This means that if a firm (Firm A) (which may or may not be an account information service provider) passes data to another firm (Firm B), and Firm B uses that data to provide account information services to its customers, Firm B must be authorised or registered with permission to provide account information services. However, if Firm A is an account information service provider and Firm B is acting as Firm A’s agent, it may present Firm A’s account information service to users through its own platform: for example, its website or application. It must be clear to the customer that Firm B is acting as agent of Firm A, the principal. This may include, for example, using Firm A’s branding within Firm B’s application. Further, the agreement for the provision of account information services must be between the customer and Firm A, the principal."
Using the above scenario, our provider SaltEdge will be Firm A and we'll be Firm B.
We're working closely with SaltEdge to comply with any changes we'd have to do on our end (for example obtaining customer consent) and we have the full intention to be fully compliant within the given deadline of mid September 2019.
You should also be aware that regulations might change and if they do, we'll do our best to comply but some delays may occur.
We'll update this article should new information arise.
Last revision: 25 March 2019