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?
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.