So, after weeks of conversations with various regulators across Europe, I am delighted to be able to share the views of the Central Bank of Ireland towards UK payment and e-money institutions looking to set up a new office in Ireland as part of their Brexit strategy. Since firms started thinking about their Brexit strategies, Ireland has often been mentioned by clients of fscom as their first consideration, principally based on common language and proximity. Indeed, being based in Belfast, we find our own proximity to Dublin to be particularly helpful in helping firms with the Central Bank. As we have seen though, there are many other factors that need to be taken into account. As ever though, I do not pass comment on the Central Bank’s views in this article, preferring to simply pass them on to help you make up your own mind. So, thanks again to the Central Bank for granting me access and, in particular, to Russell Burke from the Payments Authorisation Team.
Following my well-received blog about the ACPR’s approach to UK payment/e-money institutions applying for authorisation in France as part of their Brexit strategy, it was almost obvious that I should follow this up with consideration of near-neighbours Belgium.
For some, Brexit may still seem like something out of a fairy tale but, whether you are for or against, it will become a reality next March 2019.
The third in my trilogy of PSD2 blogs from ‘Inside the Regulator’. However, as we are now entering uncertain and uncharted territory, in terms of firms that failed to submit applications for re-authorisation in time, my insights are more presumptive than previously.
Drawing on my experience of heading up the Payment Services Authorisations Team at the FCA for many years, I spoke last week (http://blog.fscom.co.uk/psd2-a-glimpse-inside-the-regulator) about the FCA’s expectations for authorisations and re-authorisations, and offered some insight into how they might approach the challenges brought about by PSD2. I now explore the risks inherent in firms wishing to ‘upgrade’ their licences, the new entrants under PSD2 and the FCA’s approach to supervision.
Much of our time is, and seems always to have been, spent trying to interpret exactly what the regulations or, more importantly, the Regulator is expecting. A leading question asked by many compliance officers is, 'what do they expect of my company?'. This is often where the compliance consultant comes in.