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.
With the vast majority of e-money and payment institutions successfully re-authorised, let’s take a look at how the FCA intends to monitor this growing population of firms.
With all the excitement around re-authorisation, the ban on credit card surcharges and the new payment services activities, the less headline grabbing regulatory changes introduced by the second payment services directive (PSD2) have been somewhat overlooked. One of these changes relates to complaint handling.
In a previous blog post, I took a look at the upcoming access changes to the UK’s RTGS system (the Clearing House Automated Payment System) and, in the blog post before that, the UK’s new payment architecture. In the latter, you might remember, we touched on the consolidation of three separate payment service operators (PSOs) – Bacs, Faster Payments Service and the Cheque & Credit Clearing Company – under a New Payments Service Operator (NPSO).
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.
It’s been five months since the FCA’s doors opened to applications from the new payment service providers, often referred to as third party providers (TPPs), and two months since they could appear on the Register so it’s a good time to ask how many have seized the opportunity presented by the second payment services directive (PSD2).
The answer is: ‘not so many’.