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The Voice of Payment Institutions across Europe

EPIF Position Papers

  • 16.03.2017

    EPIF response to EBA consultation on GL on PI Authorisation

    EPIF is glad to share its response to the EBA consultation on the draft Guidelines on the information to be provided for the authorisation as payment institutions and emoney institutions and for the registration as account information service providers.

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  • 16.03.2017

    EPIF response to the EBA GL on major incident reporting

    EPIF is pleased to share its response to the EBA Guidelines on major incident reporting under the PSD2.

    These draft Guidelines set out the criteria, thresholds and methodology to be used by payment service providers in order to determine whether an operational or security incident should be considered as major and, therefore, be notified to the Competent Authorities.

    » Download (PDF, 499.22 kB)
  • 16.03.2017

    EPIF response to the EBA consultation on the draft RTS on SCA and Secure Communications

    EPIF is pleased to share its response to the EBA consultation on the Regulatory Technical Standards on strong customer authentication and secure communications under the PSD2. 

    EPIF is supportive of initiatives that introduce more choice to innovation in the European payments sector and believes that we should adapt to customer needs and the rapid pace of change in the market.

    EPIF believes that Strong Authentication requirements should carefully balance security and user friendliness, taking into account payment service users’ desire for convenience. 

    EPIF is strong supporter of the risk based approach. We believe the RTS should be less prescriptive and more business-model and technology neutral in order not to hamper innovation and the development of the EU Digital Single Market. Moreover, the RTS should be fully consistent with the provisions and spirit of the revised Payment Services Directive (PSD2) and its implied mandates given to the EBA.

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  • 28.11.2016

    EPIF Position Paper on the Commission’s proposal to amend the 4th AMLD

    EPIF is pleased to share its position paper on the Commission;s proposal to amend the 4th AMLD. 

    » Download (PDF, 518.47 kB)
  • 12.10.2016

    EPIF Response to the EBA Consultation on the RTS on Strong Customer Authentication and Secure Communication under PSD2

    The European Payment Institutions Federation is pleased to share its responses to the EBA Consultation on the RTS on Strong Customer Authentication and Secure Communication under PSD2.

    » Download (PDF, 600.66 kB)
  • 08.08.2016

    EPIF Response to the EBA Discussion paper on innovative uses of consumer data by Financial Institutions

    The European Payment Institutions Federation is pleased to share its responses to the EBA discussion paper on innovative uses of consumer data by financial institutions.

    » Download (PDF, 515.94 kB)
  • 08.08.2016

    EPIF Position Paper on the EBA Guidelines on PI Insurance for PSPS’

    EPIF is pleased to share its position paper on the EBA Guidelines on PI Insurance  for PSPS’.

    There appears an over-reliance on insurance to underpin the new TPP market. This appears to be the assumed solution even in the title of the ‘Guidelines on Professional Indemnity (PI) insurance for PSPs’.
    This is unfortunate since there is no such market existing today. If this unavailability becomes a barrier to entry to small TPPs this would seem directly contrary to the intentions of PSD2 to encourage TPPs to flourish.

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  • 22.03.2016

    EPIF Response to EBA consultation on draft regulatory standards on separation of card schemes and processing entities

    EPIF welcomes the publication of the EBA’s Consultation Paper on Draft Regulatory Standards on separation of payment card schemes and processing entities: a common feature of our membership is a dependence upon fair access to domestic and international payment schemes/networks; domestic interbank settlement systems and bank accounts. Therefore we have a special interest in the proposed split of schemes’ branding and processing activities.

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  • 22.03.2016

    EPIF Response to the Green Paper on Retail Financial Services

    EPIF is glad to share its response to consultation the Green Paper on Retail Financial Services

    » Download (PDF, 629.46 kB)
  • 22.03.2016

    EPIF Response to EBA consultation on Regulatory Technical Standards on passporting under PSD2

    The European Payment Institutions Federation is pleased to share its responses to the EBA consultation on Regulatory Technical Standards on passporting under the PSD2.

    » Download (PDF, 419.71 kB)
  • 09.02.2016

    EPIF Response to EBA Consultation on Strong Consumer Authentication

    EPIF welcomes the publication of the EBA’s Discussion Paper on strong authentication as part of the RTS for the revised Payment Services Directive (PSD2). We also welcome its focus on enhancing consumer protection, promoting innovation and improving the security of payment services across the European Union.

    » Download (PDF, 559.66 kB)
  • 03.02.2016

    EPIF Response to consultation on ESAS’ Draft Guidelines on Risk Factors

    EPIF is glad to share its response to consultation on  ESAS’ Draft Guidelines on Risk Factors

    » Download (PDF, 457.66 kB)
  • 03.02.2016

    EPIF Response to the call for evidence on cumulative impact

    For this call for evidence EPIF gladly provides examples concerning the Payment Services Directive (PSD II), the Interchange Fee Regulation and the Consumer Credit Directive (CDD). 

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  • 08.12.2015

    EPIF Position Paper on Safe Harbour 2.0

    EPIF is pleased to share its position paper on Safe Harbour 2.0. 

    In the context of the recent ruling of the CJEU in the Max Schrems case and the discourse which has surrounded it, EPIF would like to take the opportunity to highlight the importance of the Safe Harbour Agreement for the functioning of modern digital economies and the impact on EU and US businesses alike. Therefore, EPIF calls on the negotiators to conclude by the end of January 2016 deadline to avoid creating unintended barriers to growth, innovation and global engagement.

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  • 29.09.2015

    EPIF Position Paper on the EU General Data Protection Regulation

    EPIF  welcomes  the  European  Commission’s  proposal  for  greater  harmonisation  of  the  EU data protection regime within the internal market with regard to the processing of EU personal data. With this position paper, EPIF seeks to address the concerns it has identified in the draft Regulation.

    A number of provisions lead in their current form to legal uncertainty as they seem to be in conflict  with  the  requirements  under  applicable  Anti-Money  Laundering  and  Counter-Terrorism Financing  rules  (AML/CFT). Also,  some  provisions  significantly  increase  of  costs  and bureaucracy  for  companies.

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  • 22.10.2014

    EPIF Position Paper on the recent development on the 4th Anti-Money Laundering Directive

    EPIF is pleased to share its recent position paper on the 4th Anti-Money Laundering Directive. The paper is demonstrating EPIF's views on the key issues of interest on the 4th Anti-Money Laundering Directive and the Funds Transfer Regulation at the current level of the negotiation process.

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  • 14.10.2014

    EPIF Position on the recent developments in Council re the Payment Services Directive 2

    EPIF is glad to share its views on the key issues of the PSD2 as currently being discussed at Council level. The paper illustrated among others the scope, the use of agents, the revocation of consent recurring transactions, access to bank  services in home and host Member State for PIs, the passporting regime and others.

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  • 20.09.2014

    EPIF Position Paper on the Interchange Fee Regulation

    The European Payment Institutions Federation is pleased to share its views on the draft Interchange Fees Regulation. In its paper, EPIF articulates how a number of the central proposals in the draft Regulation would impact small market players and what this would mean for competition and consumer choice in the payments sector.

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  • 21.05.2014

    EPIF Position Paper on Access to Bank Services

    EPIF is pleased to share its Position Paper on Access to Bank Services.  This position paper identifies the various issues and concens of PIs in terms of accessing bank services.

    » Download (PDF, 595.28 kB)
  • 16.04.2014

    EPIF Position Paper on the PSD2

    EPIF welcomes the publication of the proposal for a Payment Services Directive 2 (PSD 2). EPIF is hereby identifying some key issues that need to be addressed in order to improve the current proposal.  This  includes,  amongst  other  topics,  the passporting regime, the use of agents, the access to bank services for payment institutions, safeguarding of merchant funds and surcharging.

    » Download (PDF, 737.90 kB)
  • 28.10.2013

    EPIF views on key developments on the 4th AML Directive

    EPIF is glad to share its views on two main issues currently discussed at Council level with regards to the review of the 3rd Anti-Money Laundering Directive: i) the introduction of CDD requirements for transfer of funds exceeding 1,000 EUR and ii) the possible re-introduction of an optional exemption for electronic money products from CDD requirements if certain thresholds are observed. 

    » Download (PDF, 331.74 kB)
  • 29.07.2013

    EPIF position paper on Payment Initiation Service

    EPIF is glad to share its views on the topic of third parties accessing payment accounts to effect payments on behalf of European consumers (also called Payment Initiation Services) as well as to make four recommendations in respect of Payment Initiation Services (“PIS”).

    Thanks to their safety, convenience and economic efficiency, we expect PIS to bring significant benefits to European consumers and contribute to the integration of the European payments market. In order for this to happen, consumer interests need to be safe-guarded and it needs to be ensured that third-party providers and bank-sponsored providers of PIS compete on a level playing field.

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  • 08.05.2013

    EPIF position on the proposed 4th Anti-Money Laundering Directive

    EPIF welcomes the publication of proposals for the 4 th Anti-Money Laundering Directive (4AMLD). AML rules need to be calibrated to reflect the reality of PI’s operating models.

    EPIF would like to take the opportunity to identify some key areas that EPIF believes the 4AMLD should seek  to  address  but  currently  does  not.  This  includes,  amongst  other  things,  the  legislative  method applied  (minimum  harmonisation  as  opposed  to  maximum  harmonization),  risk  based  approach, customer due diligence measures, approach towards non face to face (online) transactions and data protection issues.

    » Download (PDF, 155.88 kB)
  • 08.05.2013

    EPIF Position on the review of the PSD and the follow up to the Green Paper on innovative payments

    EPIF is glad to share its high-level views on the review of the PSD and the follow-up to the Green Paper on payment  innovation.  EPIF  is  addressing  below  several  issues  of  concern  resulting  from  both instruments.

    » Download (PDF, 152.19 kB)
  • 01.10.2012

    EPIF position Paper on the European Supervisory Agencies AML Supervisory Protocol

    EPIF welcomes that the European Supervisory Authorities (ESA) have recently started to provide specific guidance to the financial industry regarding the supervisory, passporting and reporting regime applicable to Payment Institutions (PI) and their agent network. The new supervisory protocol (the ‘Protocol’) provides helpful clarifications, in particular from  an  Anti-Money  Laundering  and  Counter-Terrorism Financing  (AML/CFT)  perspective.  On  the  other  hand,  the Protocol contains various proposals which are a matter of concern to EPIF due to their unnecessary restrictive nature and potential severe impact on the business models of non-bank remittance service providers in Europe.

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  • 01.04.2012

    EPIF position on the review of the 3rd Anti-Money Laundering Directive

    The European Payment Institutions Federation (EPIF) welcomes and encourages the private stakeholder consultation that is currently taking place concerning a review of the 3rd Anti-Money Laundering (AML) Directive.

    Payment Institutions' (PI) compliance with anti-money laundering and counter terrorist financing obligations is a prerequisite for their authorisation under the Payment Services Directive (PSD). The current anti-money laundering framework was, however, established prior to the opening of the payment institutions market and subsequently is arguably not catered to the needs of their various business models.

    » Download (PDF, 352.41 kB)
  • 01.04.2012

    EPIF position on the European Commission Staff Paper on Anti-Money Laundering Supervision

    Commission Staff Working Paper on AML Supervision Of, and Reporting By, Payment Institutions in Various Cross-Border Situations

    » Download (PDF, 438.39 kB)