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Category

Feedback

Response

1

Will Miao (Deactivated)

Paymark

Payments Initiation API

Addition of refund API links to the Payment initiation V2.0 release candidate:

  • Being able to offer real time refund on transactions initiated by API links is a key requirement for merchants to keep the admin cost down, and for customers to have a streamlined payment experience.

  • For some retailers, not being able to refund means they will have to set the customer up as a “supplier” in the system, resulting in weeks of delay and a huge amount of admin effort.

Refunds are not currently an agreed part of the scope for v2.0:
/wiki/spaces/ACSC/pages/49283242

It should be noted that in the v2.0 standard - Third Parties are be able to initiate a refund to a Customer via these steps:

  • Requesting the DebtorAccountRelease as part of the Customer's original payment-consent (to identify the Customer's bank account details)

  • Agreeing a new payment-consent for the Merchant with the Third Party - to pay the Customer

  • A Merchant's payment-consent may be an enduring-payment-consent - which would mean that under agreed parameters, the Merchant would only need to authorise this refund payment-consent once.

  • Third Party initiating a payment-order with the Merchant's Bank to refund the Customer

Note that the existing v2.0 (and v1.0) standards rely on push payments initiated by the Customer's Bank. If we were to re-utilise the push payments system for refunds - then a refund must be initiated by the Merchant's Bank.

Your feedback on future functionality will be incorporated into the discussions informing the scope for pipeline activities.

2

David Mitchell (Unlicensed)

BNZ

Account types

We would like to see what it would take to loosen the limitation of the accounts to only BECS identifiable accounts to include scheme card formats

Limiting the types of transactions / accounts to be able to be queried to non credit card accounts may make the Transactions API less useful as a large portion of customers to their primary transactional banking from their credit card (mainly because of things like paywave and loyalty schemes).

Hi David Mitchell (Unlicensed)

We raised this as a business decision /wiki/spaces/PaymentsDirectionAPIStandardsDevelopment/pages/22282274 - and the Business Working Group made a decision (Option 1) for v2.0 to continue with the approach taken from v1.0:

  • Only BECS identifiable accounts

  • No clarification of what account types are in scope - i.e., some API Providers will only implement current accounts, some API Providers may also implement savings accounts, some API Providers may only implement some current accounts

As this was the business decision - we have reflected this in the technical specifications.

This will be fed back to the business group for the scope for pipeline activities.

3

Gavin Wong (Unlicensed)

Payments NZ

Errata

In both the Account Information and Payments Basics/Steps section - clarify “Once the consent has been authorised, the API Provider may make a callback to the Third Party to provide an access token.” - as the push method has been de-scoped by the FAPI working group.

To be updated in v2.0-rc2

4

Gavin Wong (Unlicensed)

Payments NZ

Errata

In the Payments Initiation Basic/Steps section - update “The Customer selects the debtor account(s) at this stage (if not previously specified in Step 1)." to reflect only one debtor-account may be selected. Linking multiple debtor accounts to an enduring payment consent has been de-scoped from v2.0.

To be updated in v2.0-rc2

5

Gavin Wong (Unlicensed)

Payments NZ

Errata

In the Payments Initiation Basic/Steps section - update wording for clarity from “may only create multiple” to “may create multiple”

To be updated in v2.0-rc2

6

Chris Barton

Xero

DevelopmentPipeline

Payments API - future standards:

  • V2 standards appear more suitable for consumer application

  • For business payments the addition of Batch, Multi-Auth, Enduring Consent and feasible transaction limits will be required to encourage uptake from Xero or its partners

  • Batch - users should be able to provide one authorisation for the batch payment rather than authorise individual payments

  • Enduring consent - needs to be extended to advisors / administrators to prepare payment files, with decoupled flow enabling authorised signatories to authorise payment

  • Multi-authorisation - needs to enable advisors / administrators and account signatories to prepare and approve payments

  • Transaction limits - need to be sufficient to support SMB’s end of month batch payments

Account Information API

  • A unique transaction ID should be included

  • Enduring consent should extend to account information with the same flexibility around administrators / signatories

  • Should include credit card accounts

Bills API

  • Should not include a bills API as this should be covered by Peppol / E-invoicing standards. We have some reservations about the API Centre being used to set standards for non API Providers. This seems out of scope of the API Centre's mandate.

Hi Chris Barton, Thank you for providing your thoughts and feedback on what you consider to be the high priority areas for future state standards development.

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

7

Dimitri Stylianidis (Deactivated)

Xero

Development Pipeline

Feedback on Account Information API Specification v2.0.0

  • Mandatory immutable transaction ids, these are currently optional.
    The absence of a unique and consistent Transaction Id restricts all third party consumers from providing an equivalent complete list of unique transaction to the customer that the API Providers can.

  • Where available Account Name should be populated i.e. wherever there is an Account Name value/field used by the API Provider in its interaction with its customers. This will allow end users to quickly and easily identify their accounts.

Thanks for your feedback on the Account Information API specification Dimitri Stylianidis (Deactivated). We will be incorporating all feedback received on future state of the APIs, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

8

Andy Wynes (Deactivated)

ACC

Multiple

As a potential third-party user of the API standards, I see the benefits that the Payments Initiation and Account Information Standards provide to an organisation such as ACC, however given the following factors, these would complicate their implementation for third-party users:

9

Andy Wynes (Deactivated)

ACC

Multiple

The fact that bilateral agreements need to be put in place with each individual API Provider (currently there are 9 listed on the website), rather than a single organisation that facilitates connectivity between the third party and the banks.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

10

Andy Wynes (Deactivated)

ACC

Multiple

The fact that some elements of the individual APIs are optional, meaning that each API Provider could provide a slightly different level of service to the others. Third-parties will have to cater for this themselves on an API, by API Provider basis. It is noted that the mandatory endpoints are probably the ones that ACC would use. Although I can see a use case where Party information (currently optional) within the Account information specification would be desirable.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

11

Andy Wynes (Deactivated)

ACC

Multiple

I saw enduring consent as being a game-changer for the use cases by which these APIs could be used, however with this being implemented as an optional offering for the API Providers, this could lead to a less favourable user experience for end users whose API Provider banks do not support this capability. This could lead to an increase in customer contacts for the third-party where enduring consent is not offered by the appropriate API Provider.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

12

Andy Wynes (Deactivated)

ACC

Multiple

As for future use cases that these APIs could possibly support, one that I have heard discussed, but I accept may not be desirable for security reasons, is where a payment could be initiated as a result of an invoice payment request being received by email for example, rather than from within a user authenticated channel/portal such as MyACC for Business.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

13

Carl Samuelson

ASB

Multiple

Release candidate 001 - v2.0.0-rc1

https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283181/Release+candidate+001+-+v2.0.0-rc1#Version-scope

The “Consultation and feedback section” link is not working.

14

Carl Samuelson

ASB

NZ Banking Data API Specification v2.0-rc1

NZ Banking Data API Specification v2.0-rc1

“This document and its sub-pages must be read in conjunction with the Known Issues Log” – It would be helpful if a link to the ‘Known Issues Log’ was included (as was done in upstream version).

As we’re still in development for v2.0 we do not have a Known Issues Log as yet.

We will update this when we release v2.0

15

Carl Samuelson

ASB

NZ Banking Data API Specification v2.0-rc1

It would also be useful to have an overview table of all APIs and endpoints on this page with a short description for each API and whether they are mandatory or not. This will give Third Parties and API Providers a good overview of the endpoints that are covered by the specification. Similar to the tables at the top level of each specification (e.g. https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283859/Payments+Initiation+API+Specification+-+v2.0-rc1)

The endpoints and whether they are mandatory/optional are described in each API Group page:

https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283859/Payments+Initiation+API+Specification+-+v2.0-rc1#Endpoints

https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283572/Account+Information+API+Specification+v2.0.0-rc1#Endpoints

Would prefer not to duplicate these across the specification - as the main spec page is for only elements that are common for both API Groups.

16

Carl Samuelson

ASB

Account Access Consents v2.0.0-rc1

Account Access Consents v2.0.0-rc1

The plurality of account access consents should be consistent throughout the documentation: account-access-consents vs account-access-consent (account-access-consents is correct). This NZ spec appears consistent with the upstream spec so we are unsure if this difference is intentional.

“An API Provider may delete the account-access-consent resource 24 hours after creation if not authorised by the Customer or, if authorised by the Customer, 24 hours after the specified expiry date.”

We can update this in v2.0 to reference resources in plurality.

17

Carl Samuelson

ASB

NZ Banking Data API Specification v2.0-rc1

This is a bit ambiguous / unclear and may be clearer in the same form as the specification page

https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283453/NZ+Banking+Data+API+Specification+v2.0-rc1):

  • API Providers must not archive a ConsentId within the first 24 hours of creation.

  • API Providers may archive an expired ConsentId after 24 hours of creation.

However, this does highlight the inconsistency between the two pages. The first states “if [the consent was] authorised by the Customer, [the consent may be deleted by the API Provider] 24 hours after the specified expiry date”. The second bullet point above states: “the API Providers may archive an expired ConsentId after 24 hours of creation”. Note the discrepancy between 24 hours after expiry vs creation.

We can look to clarify this in v2.0-rc2.

18

Carl Samuelson

ASB

Domestic Payments Consents

https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49284091/Domestic+Payment+Consents+-+v2.0-rc1) does not mention archiving or deletion. It seems that these should all be consistent and use a consistent term (archive or delete). Upstream has different wording, but essentially they specified that consents can only be deleted 24 hours after creation:

  • ASPSPs must only delete expired intent-ids 24 hours after creation.

  • ASPSPs may archive these expired intent-ids.

We can look to clarify this in v2.0-rc2.

19

Carl Samuelson

ASB

Accounts v2.0.0-rc1

Accounts v2.0.0-rc1

“The first step for a Third Party after an account-access-consent is authorised – is to call the GET /accounts endpoint”

It is not immediately clear why this endpoint needs to be the first step after account-access-consentId. Also, the Third Party’s first step might be to do something else, e.g. retrieve the consent first. For clarity, it may be better to state explicitly: “For the Third Party to retrieve resources that require an AccountId, e.g. GET /accounts/{AccountId}, the Third Party will need to call the Get /accounts endpoint first to retrieve the AccoundIds”.

The NZ spec is consistent with upstream here, but we feel could be clarified.

We can clarify this in v2.0-rc2

20

Carl Samuelson

ASB

Beneficiaries v2.0.0-rc1

Beneficiaries v2.0.0-rc1

It appears that the Creditor agent is mandatory in the UML diagram (1..1), but optional in Data Dictionary (0..1).

This appears to be a deviation from upstream where it is consistent in both.

The data dictionary is correct in this instance..

To be updated in v2.0-rc2

21

Carl Samuelson

ASB

Direct Debits v2.0.0-rc1

Direct Debits v2.0.0-rc1

The examples have GBP. To be consistent with other examples, it should be NZD.

To be updated in v2.0-rc2

22

Carl Samuelson

ASB

Transactions v2.0.0-rc1

Transactions v2.0.0-rc1

Filtering – it would also be useful to filter by minimum and maximum amount. Suggest this for consideration for future versions.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

23

sam MacGeorge (Unlicensed)

Vigilence

Development Pipeline

Vigilance is looking forward to using the PaymentsNZ API when it is able to process bulk batch payments from a bank account that is a Business account and likely to require multiple authorisers. Vigilance already allows for batches to be authorised by multiple people, so would like to allow this pre-authorised batch to be processed via a future API.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

24

sam MacGeorge (Unlicensed)

Vigilence

Development Pipeline

The ability for payments to be made to Foreign bank accounts is important. Before each single payment in a batch is processed, we would like to use an API to check that payee's bank account to verify the account name and compare with the name the payer has on file - any difference to be warned about before the payment happens - so there is a chance to cancel.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

25

sam MacGeorge (Unlicensed)

Vigilence

Development Pipeline

Comparing names has a challenge with slight spelling differences, so some 'nearly matching' would be great. Being able to download bank statement transactions is likely to be the first API we could use - the most valuable information on each transaction would be the 'other party' details - name, account #. Plus if the transaction is deposit from a foreign account, we require the swift details, bank, branch - all for AML/CFT purposes - to enable us to create a Prescribed Transaction Report to the FIU.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

26

sam MacGeorge (Unlicensed)

Vigilence

Development Pipeline

The Party API would also be very useful for AML/CFT purposes for helping to build a complete picture of a transaction.We look forward to a possible timeline of when some of the above functionality may have research started and happy to provide more specific suggestions then.The API documentation seen to date has been clear and well written.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

27

Dermot Butterfield (Unlicensed)

WYCH Limited

Development Pipeline

Deviation from OBIE Enumeration standard.

There appears to be a change from the technical specifications as outlined in https://openbanking.atlassian.net/wiki/spaces/DZ/pages/937623722/Namespaced+Enumerations+-+v3.1 and omits any clarification or supporting documentation on the need for a deviation from the industry standard. Further in deviating form the standard it omits to declare the behaviour of the banks with regard to bank specific additions which we clarified in the standard.

The introduction of namespacing was an improvement to avoid collision on standard and non-standard (ASPSP specific) types. The specification defines a prefix of country in ISO 3166-1 Alpha-2 code followed by full-stop, followed by camel cased ASPSP name followed by enumeration value.

I appreciate the desire to NZ-ise this but this can be achieved while aligning with the standard. I would expect for example a root specification prefix of one of the following.

Considering PaymentsNZ as the specification owner

NZ.PaymentsNZ.AwaitingAuthorisation

  • aligns with standard country prefix+ aligns with standard ASPSP convention+ aligns with standard number of dots (2)+ supports bank additions without compromising standardNZ.Westpac, NZ.KiwiBank, NZ.ASB...+ total prefix size 14 characters

Considering PaymentsNZ apicenter product as the OBIE equivalent

NZ.ApiCenter.AwaitingAuthorisation

  • aligns with standard country prefix+ aligns with standard ASPSP convention+ aligns with standard number of dots (2)+ supports bank additions without compromising standardNZ.Westpac, NZ.KiwiBank, NZ.ASB...+ total prefix size 13 characters

Considering this an open banking spec

NZ.OBIE.AwaitingAuthorisation

  • aligns with standard country prefix+ aligns with standard ASPSP convention+ aligns with standard number of dots (2)+ supports bank additions without compromising standardNZ.Westpac, NZ.KiwiBank, NZ.ASB...+ total prefix size 8 characters

it is questionable if the standard is an open banking standard

The proposed

apicentre.paymentsnz.co.nz.AwaitingAuthorisation

total prefix size 26 characters

in the example (and many others) the proposed prefix is longer than some of the previous example with the Enumeration attached

does not align with the country standard prefix

uses a domain name format

references a product name

unclear how this supports bank additions such as must end in co.nz? must be lowercase? e.g. westpac.co.nz, KiwiBank.co.nz, ASB.co.nz e.g. api.westpac.co.nz, api.kiwibank, nz.asb

There is no guidance on Namespaced Enumerations in the standard because there are no Namespaced Enumerations in the standard.

I.e., all enumerations in the standard are of a fixed enumeration - as per guidance in https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283453/NZ+Banking+Data+API+Specification+v2.0-rc1#Enumerations.1

Enumerations

The specifications include various enumerated data types, where values are fixed to a defined set of alternatives (i.e. static enumerations). These static enumerations are listed on each API Specification page.

This decision was taken to standardise enumerations across the industry in NZ - rather than to allow API Providers to deviate from the standard.

/wiki/spaces/PaymentsDirectionAPIStandardsDevelopment/pages/22577217

So in the examples given - all API Providers will be responding with a status of “AwaitingAuthorisation” instead of a namespace.AwaitingAuthorisation.

Think this should simplify a Third Party’s implementation.

28

Zachary Tattle (Unlicensed)

OrbitRemit

Development Pipeline

Feedback on the Account Information API:

I would like to echo comments on mandatory immutable transaction_ids (even if the bank line information has been updated) and account_name fields.

Further/additional justification for these changes:

Providing transaction_ids would allow for real-time reconciliation.

Populating the account_name field is crucial, particularly with tightening AML/CFT regulations.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

29

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

Links in version control don't work when referencing draft1


Example in Accounts

Accounts v2.0.0-rc1
there is a link to


•In draft1-Endpoints table
https://paymentsnz.atlassian.net/wiki/pages/resumedraft.action?draftId=39551170#Accountsv2.0.0-draft3-Endpoints

Thank you for your highlighting this error, this will be updated and corrected in v2.0-rc2

30

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

Inconsistent security model applied. you want feedback, but we can't view all the documentation. Example link /wiki/spaces/PaymentsDirectionAPIStandardsDevelopment/pages/22282274 gives 'This is a restricted space' error (which is provided in feedback, and referenced in the V2 spec)Andrew Beech

Apologies for the inconsistency here. We will ensure this link is removed following publication of standard.

The Business Decision highlighted is held within the standards development area of our Confluence space, only accessible to registered Standard Users of the API Centre.

31

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

Scheduled Payments. Error in version control, version 1.0.0 states "baseline specification for party resource" (rather than scheduled payments)

Thanks - we will update the version control section in v2.0-rc2.

32

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

Mandatory immutable transaction ids, these are currently optional. would assist to ensure unique information supplied.

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

33

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

As a 3rd party looking to utilise for commercial purposes. We need to ensure what data is actually going to be provided. Would it be plausible for a technical template that each provider could complete to advise what fields each is going to make available (by account type?).

This could then be presented on a page within the wiki (not sure if that is correct location) so when we are developing we can limit scope to data available from all, or know that we need to handle a lot of optional combinations (which would be a maintenance nightmare if changes were made).

Without, this exercise would be done by each 3rd party. Providing it could speed up any developments.

A business decision was made on developer portal requirements /wiki/spaces/PaymentsDirectionAPIStandardsDevelopment/pages/22413350 - which had agreement for:

  • Standardisation of minimum information API Providers must make available to Third Parties on Developer Portals, and format, with respect to API standards.

  • No standardisation of registration and onboarding processes for Third Parties with API Providers.

  • No centralisation of information or registration processes as yet.

34

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

Payments Initiation.
DD, Scheduled payments are only GET. so payments is only option to POST. with the post there is no data item to schedule the payment. have scheduled payments been considered ?
example use case - allowing payment to be initiated and approved but not proceed until user pay day. so payment would wait in pending status until schedule date.

The initiation of scheduled payments (which are initiated by the Third Party for a future date) are not in scope for the v2.0 standard: /wiki/spaces/ACSC/pages/49283242 .

However - the ability for a Third Party to initiate a payment on a future date is possible with the enduring-payment-consents functionality in v2.0:

  • A Customer and Third Party agree an enduring payment consent which is authorised with the API Provider

  • The enduring payment consent is for (a) only 1 payment - i.e., a TotalCount=1, (b) can have the date the payment is initiated restricted using the FromDateTime and ToDateTime

  • The Third Party initiates a single domestic payment (via POST /domestic-payments) using the enduring payment consent ConsentId on the scheduled payment date.

This has benefits over a regular scheduled payment - as a Third Party may not know the exact amount of the future payment - but can agree a maximum amount with the Customer.

35

Andrew Beech (Unlicensed)

Trustees Executors Limited

Multiple

Term Deposits is a common banking instrument and should be an endpoint.
Would like to see term deposit as an available account type. so that balance can be retrieved.
Within the endpoint should be the ability

GetRates
retrieve available rates/terms/minimum.
Rates applicable to the client, or 3rd party (as the client or 3rd party institution may have a preferential rate to market)

CreateDeposit
Specify rate and term (will be validated against available rates)

UpdateDeposit
change preference of maturity action. Enum of the option ? payout, reinvest, reinvest+interest

  • CalculateBreakFee

Return the cost/fee to break the term deposit

TerminateDeposit
User would need to accept breakfee (if applicable)

Noted. We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

36

Kiran Bajaj (Unlicensed)

Multiple

Information around the transaction, Reconciliation, Reporting, Queries, Dispute ManagementEnd to End ID has to be a mandatory field by the banks(each party involved in the transaction remitter, remitters bank, beneficiary’s bank, beneficiary and the open banking app participants need to also store their “own reference numbers”)From a client perspective (the client supplied reference number) should also flow through all pay, collect, receive cases. This field E2E ID will flow through the message across all parties and will be used for reconciliation, disputes/charge back and inquiry / investigationsIn addition, for companies using this mechanism, the client reference number (invoice / erp number) should also flow through the transaction from remitter to beneficiary / origin to destination.

Kiran Bajaj (Unlicensed)

Multiple

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

37

Kiran Bajaj (Unlicensed)

Multiple

Reference to Enduring Consent (Mandates for future execution) Sample physical mandate referenced from the real world

Reference: National Payments Corporation of India

Enduring payment consent is not handling amount variances and as and when presented scenarios. Real world issues have come up on the mandate where the Debit As and when presented feature has been used by Supply Chain participants in their use cases, similar use by Non Bank Finance Companies for loan security (invoke on default scenarios) Today, companies using the debit mandates (enduring consent) are faced with the challenge of a fix / max cap amount when the government decides to change GST rates and / or add service charge / cess components to the service tax structure. In all such cases the companies go out and re-seek mandates which is a tedious activity and cause for strong feedback to the clearing house and member banks.

Enduring Consent for payments should also have the option of submitting payments "as and when" presented for submission.

Link to view full image

Kiran Bajaj (Unlicensed)

Multiple

Use case references for Enduring Payment Consent

UPI is not a case of pure open banking but it involves the creation of standard API’s by the clearing house which are consumed by participating banks. The PSP’s hook up to the bank switch through their own API’s. But the intent of pay, receive and collect remains the same.

Here is a reference : https://www.npci.org.in/product-overview/upi-product-overview

Case of Enduring Consent (UPI e-mandate) for Investors to use the ASBA (Application Supported by Blocked Amount) route for investing into IPO’s (Initial Public Offering)This is live in the real worldhttps://www.npci.org.in/upi-live-ipo

List of 3rd party Apps - on boarded on to the UPI ecosystem(can demonstrate in person)The principle we have kept in the design of the APIs is explicitness. The ability for a Customer and Third Party to agree a defined enduring payment consent with fixed limits promotes more explicitness in the APIs.

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

38

Kiran Bajaj (Unlicensed)

Multiple

Use case references for Enduring Payment Consent

UPI is not a case of pure open banking but it involves the creation of standard API’s by the clearing house which are consumed by participating banks. The PSP’s hook up to the bank switch through their own API’s. But the intent of pay, receive and collect remains the same.

Here is a reference : https://www.npci.org.in/product-overview/upi-product-overview

Case of Enduring Consent (UPI e-mandate) for Investors to use the ASBA (Application Supported by Blocked Amount) route for investing into IPO’s (Initial Public Offering)This is live in the real worldhttps://www.npci.org.in/upi-live-PSP%263rdpartyAppsipo

List of 3rd party Apps - on boarded on to the UPI ecosystem(can demonstrate in person)https://www.npci.org.in/upi-PSP%263rdpartyApps

Use cases which can be leveraged by the open banking ecosystemhttps://www.sc.com/upi/

Volumes and throughput flows rise when merchants get on-boarded to the ecosystem. Above link has use cases which can be referenced to get merchants interested.

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

39

Kiran Bajaj (Unlicensed)

Multiple

UPI Primer

https://youtu.be/5RNshDcXGjg

https://www.youtube.com/watch?v=aUHiyQfb8s0

UPI Procedural Guidelines (Public Reference) UPI Procedural Guidelines (Nov 2019 Update)

Reference attached UPI Procedural Guidelines - Pg 58: Four Party Model (Complex Flow)

Link to view full image - Four Party Model Figure 1

Link to view full image - Four Party Model Figure 2

UPI (Unified Payment Interface) crossed 1 Bn Transactions in Oct 2019 (142 participating banks and ~50 App first merchants)

https://www.npci.org.in/sites/default/files/UPI%20crosses%201%20billion%20transactions%20in%20October%202019.pdf

Kiran Bajaj (Unlicensed)

Multiple

Other We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

40

Kiran Bajaj (Unlicensed)

Multiple

Other Use Cases with Potential

  • Foreign Inward Remittance - Pg 124 of the procedural guidelines (public reference)

  • Part of UPI 2.0Linking of overdraft account (Credit Facility)

  • One-time mandateInvoice in the inbox

  • Signed intent and QR

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

41

Kiran Bajaj (Unlicensed)

Multiple

Other Aspects to Consider at an Ecosystem Level (so that participants play by the rules)

  • Account Statement Narrations at Banks

  • Transaction Statuses at AISP, PISP, Banks and consistent client facing statusesError Codes & Descriptions: Rejects, Returns

  • Charge Scheme for P2P (Person2Person) and P2M(Person2Merchant) flowsUI/UX guidelines for app developers to ensure consistent use of terminology

  • Open 247365 - Liquidity and Settlement Risk related aspects

  • API’s for fetching participant / member details (Directory)

matt.haigh (Unlicensed)

Westpac

Multiple

View file
nameWESTPAC Feedback on PNZ API Centre Standard 2RC1 DEC2019.pdf

Thank you and noted. The API Centre is working through your feedback. We are pushing to provide you with a full response, and arrange an update on the overall v2.0 We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

However - to address a few of the specific points:

Can you please elaborate on (1) account statement narrations and (2) liquidity and settlement related aspects?

42

matt.haigh (Unlicensed)

Westpac

Multiple

View file
nameWESTPAC Feedback on PNZ API Centre Standard 2RC1 DEC2019.pdf

43

Allister Hunter (Unlicensed)

Merco

View file
nameVersion 2.0 Comments.pdf

Feedback in this document has been separated and responded to below.

44

Allister Hunter (Unlicensed)

Enduring Consent

Enduring Consent

–Threshold Workaround We were advised the Technical Group had taken the decision to remove the previously agreed Threshold from the V2.0Standard for “technical reasons” noneof which have been defined... We note the Threshold has subsequently found its way onto the list of potential future Payment API upgrades?

It is our view the Threshold will be a significant element in the success of Enduring ConsentPayments and in itsabsence,there is little to differentiate the payment processes associated with the existing Direct Debit system from the payment process in the proposed Enduring Consent process. Consequently, without Threshold functionality there is little new to offer our potential customers.

The process around the Enduring Consent(authority) is another matter and obviously there are significant process improvements in what is proposed. Merco is faced now in making theproposed workaround a viable product using the decoupled flow. In short this means potentially:
-Third Party collects an Enduring Consent from a Customer;
-the process by which the Third Party sendsthe Enduring Consent to the API Providerbecomes redundant if it is the intent of the Consent that theCustomer will in all cases “authorise” the paymentby way of the decoupled flow. We say thisis redundant because when a payment is initiated by the Third Party via the decoupled flow there is no linkage at all with any Enduring Consent held by the API Provider.The only way, in our view, the API Provider would know the decoupled flow payment was associated with an enduring consent would be that a flag would be set to denote the customer was not present;
-all payments originating from the consent will be initiated without the Customer beingpresent by way of a decoupled flow thus forcing authentication and authorisation by the API Provider; and
-in this situation, the API Provider is totally reliant upon the Third Party to act in accord with the Consent.

It is our view this is a significant departure from any existing banking practice in that the Customer could be of the view they were Consenting to a “bank authority” whereas potentially the bank could process many payments which can’t possibly be associatedwith the authority. This is totally at odds with the defining features of anyOBIE API solutions.It is our view that such a process is a new concept in payments where a Third Party initiates payments in terms of an authority the Bank is potentially NOT a party to (in terms of thepayment instruction) and the Bank thus becomestotally reliant upon the Third Partyacting in accord with the Consent.In a technical sense Merco believes it can build a workable product using the workaround. Merco however hasreservations whether the workaround is consistentwith the API Centres terms and conditions or whether a bank would pay away in such a scenario.We have been seeking PNZ assurances that the workaround is consistent with the API Centre’s terms and conditions as well as common banking practice since early November2019. We have not received any such assurances to date.Without thoseassurances Merco does not consider the workaround a viable solution.

Within the standards there is already capability to link (1) a one-off payment for a Customer (that is over an enduring payment consent threshold) using a decoupled authorisation request, to (2) a previously authorised enduring payment consent.

All these specific circumstances must be in play together - e.g., if an API Provider does not support the decoupled flow - then the Third Party cannot initiate a decoupled flow linking the authorised enduring payment consent. Equally, if there is not previously authorised enduring payment consent. As this is specific behaviour and not generic behaviour - the clear design preferences is not to make generic API changes (like Status changes for the entire payment flow, or a new flag for the entire payment flow) to satisfy this requirement.

Linking a (1) one off decoupled domestic payment to (2) a previous enduring payment consent is achieved by:

  • Creating a single one-off domestic-payment-consents resource (for the payment over the threshold)

  • Initiating a decoupled authorisation request for the domestic payment consent - using the ID Token from a previously authorised enduring-payment-consents - this is documented here in the Standard https://paymentsnz.atlassian.net/wiki/spaces/ACSC/pages/49283453/NZ+Banking+Data+API+Specification+v2.0-rc1#ID-Token-Hint

  • The ID Token from the previous enduring-payment-consents authorisation contains the ConsentId that identifies the Customer’s enduring-payment-consent - allowing the API Provider to match a previous enduring payment-consent to the one-off payment.

Further - the principle we have kept in the design of the APIs is explicitness. The ability for a Customer and Third Party to agree a defined enduring payment consent with fixed limits promotes more explicitness in the APIs.

Previous discussions on using the decoupled flow for threshold flows are here:

/wiki/spaces/PaymentsDirectionAPIStandardsDevelopment/pages/2196805

45

Allister Hunter (Unlicensed)

Merco

Naming Conventions

Naming Conventions DebtorAccount

In the Swagger Specifications the name DebtorAccout is defined as:Unambiguous identification of the account of the debtor to which a debit entry will be made asa result of the transaction.

In many use cases payments will originate from accounts other than that of the Debtor (as defined in Commercial Law in New Zealand). The use of the term DebtorAccount to define the bank account from which payments will be made is misleading. The debtor and payer could be separate individualsand the name of the debtor known by the Payee in a commercial sense and the name of the underlying bank account from which payments will originate could certainly be different. The use of the term PayerAccount to define the bank account name from which payments will be made would provide unambiguous identification of the bank accountname as opposed to the debtor’s name..

Principles we have carried over from v1.0 to v2.0 of the NZ API Standard are:

The use of the field DebtorAccount is consistent with both (1) ISO 20022 and (2) Open Banking UK. So the definitions are well known.

The alignment to ISO 20022 and Open Banking UK may be re-assessed for future versions of the standard.

46

Allister Hunter (Unlicensed)

Merco

BACHO

Handling of the Payer Data in the BECS BACHO Payee (Creditor) RecordTo provide consistency with existing payments practice and to ensure meaningful data is provided on Payee’s bank statements in the “Other Party” field,API providers need populate the outward BACHO credit payment record correctly. Either the DebtorName can be used if present in the API Calls orthe Payer Bank account name can be used if theDebtorName is not present. If the Third Party has supplied the DebtorName it must be used in preference to the Payer Bank account name. The field we refer to in the BACHO record is that referred to as the “OtherPartyName” field, position 108.
This is not a matter relating to the Standard BUT a necessary clarification for API Providers to ensure consistent and the correct information is available to Payees from their bankers’ irrespective of the bank from which the API payment record originated.

As noted - this is a matter relating outside of the Standard - however, we can seek clarification with API Providers.

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

47

Allister Hunter (Unlicensed)

Merco

Authentication

Authenticationand AuthorisationTimeoutsWe wish to discuss the timeoutwithin which the customer mustrespond to the authentication and authorisation request from the API Provider.

In talking with the BNZ this timeoutis set at 5 minutes. We believe this timing is adequate based onMerco’s experience where we set this time out to 30 minutes. In our experience 8% of initiated transactions timeout for the non-completion of this stepwhere the payer has initiated the transactions. For enduring consent payments, the incidence of timeouts would be much higher where the Decoupled workaround is used to effect authorisation (i.e. Threshold processing). It is therefore significant and needs to be properly considered. If all API providers have differing timeouts for this process the Third Party will have difficulty managing the resubmission of the Consentacross many API Providers. We’d like an industry agreed timeout periodfor all API Providers for this step.

We will be incorporating all feedback received on the pipeline, through the Business and Technical working group(s) and relevant governance processes following the consultation period.

48

ANZ

The following interim feedback was received by ANZ.  Note that the API centre has granted an extension to ANZ to enable them to provide additional feedback in early January.

ANZ believe that supporting content is required to help participants of the standards understand how to navigate and use them.   More specifically, we suggest that there would be high value in a separate onboarding playbook for API Providers and Third Parties, that would allow someone new to the standards to quickly develop their mental model of the domain.  This could be achieved through example reference architecture, wayfinding support through the standards, consent and security constructs, and clear and specific interaction requirements:  all leading to a broad understanding of the implementation requirements for participants.

A response is due in January 2020 upon the submission of ANZ’s final feedback.