Discussing reporting obligations with our payments clients recently has revealed a lack of awareness of REP018, a report driven by the requirements of the second payment services directive (PSD2). PSD2 included Article 95(2), which requires payment services providers (PSPs) to report to the competent authority with an operational and security risk assessment. So, what is REP018 and why has it caught so many by surprise?
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.
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.
There has been a lot of talk in the financial sector surrounding the topic of PSD2; flagging deadlines, the implications of non-compliance and the opportunities open banking presents. But what about the other industries affected by the new regulation? From the charities and even the accountancy firms that now fall under the FCA’s watchful eye? Have they been forgotten about amid the vicissitudes?