FCE has contributed its views on the European Banking Authority (EBA)’s Draft Guidelines on the Limited Network Exclusion (LNE) under PSD2.

FCE members have been able to gather extensive experience on how the application of LNE (under Article 3(k)(ii) on the limited range of goods or services) is assessed across a wide range of EU Member States, and FCE strongly supports the EBA’s aim to contribute to the convergence of supervisory practices. 

FCE also made some targeted suggestions, including introducing the principle of a functionally connected “purpose” to establish exemptions on the basis of a limited range of goods or services; on branding; and on notifications