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The Voice of Payment Institutions across Europe

EPIF Position Papers

  • 15.06.2017

    EPIF response to the European Commission's Fintech consultation

    Financial  technology  has  the  potential  to  democratise  financial  services  across  the  EU.  Consumers expect to be able to shop online, transfer money, and purchase financial services products online and cross-border as quickly and as easily as sending an email or a text message. With the right technical and regulatory pan-European framework, financial technology companies can provide consumers with the flexible, convenient and safe level of service that they now expect from any other industry.

     

    » Download (PDF, 686.47 kB)
  • 14.06.2017

    EPIF’s contribution to the public consultation on the operations of the ESAs

    We would like to thank the European Commission for the opportunity of commenting on the Public  consultation  on  the  operations  of  the  European  Supervisory  Authorities. 

    EPIF would hope that  the  ESA  review  will  provide  the  opportunity  to  implement  the  following  three suggestions:
    -  The  EBA  Regulation  should  enshrine  binding  wording  giving  the  EBA  a  clear mandate  to  promote  supervisory  convergence  between  the  national  competent authorities  responsible  for  overseeing  payment  institutions  and  to  coordinate  policy issues  between  ‘home’  and  ‘host’  state  supervisors.  If  appropriate,  this  should  also include  the  continued  ability  to  adopt  Technical  Regulatory  Standards,  develop guidance or oversee a mediation mechanism;
    -  In  line  with  other  sectors  and  activities  falling  under  the  remit  of  the  EBA  and  the other  respective  European  Supervisory  Authorities,  the  EBA  should  convene  a Stakeholder Group representing the payment institution sector. This Group should be consulted on all aspects of the EBA's work in relation to payments, including its work carried out as part of the Joint Committee.
    -  Finally, appropriate resources should be made available to the EBA to carry out its above functions effectively.

     

    » Download (PDF, 166.73 kB)
  • 14.06.2017

    EPIF comments on the revised draft RTS on strong customer authentication and secure communication

    EPIF has highly appreciated the constructive dialogue with the European Commission and the EBA during this process but nonetheless has some final remakrs on the revised draft. 

    EPIF is of the view that card-based transactiobs should be exempt from the dynamic linking requirement. 

    EPIF suggesting relacinx the requirements to keep the maximum transaction amount to EUR 50 and not introduce prescriptive thresholds. 

    » Download (PDF, 485.93 kB)
  • 06.06.2017

    EPIF response to consultation on preventing terrorist financing and money laundering in electronic fund transfers

    EPIF is pleased to share its response with the ESAs emphasising the need to ensure that the legislation in practice works also when non-bank PSPs are involved in the payment chain.

    EPIF is of the view that the following two principles must be made clear: 1) The bank where the Payer initiates a payment transaction needs to provide a sufficient amount of input/templates to allow it to obtain sufficient information about the Payee aso when non-bank PSSs act as intermediary PSPs or PSPs of the Payee. 2) Banks that take reciept of payments (intermediary PSPs) need to provide or make available to the holder of the account where the transfer is recieved the same information about the identity of the Payer that the banks have recieved from the Payer's bank, so as to allow non-bank PSPs to act as PSP of the Payee.

    » Download (PDF, 328.54 kB)
  • 06.06.2017

    EPIF response to consultation on combatting fraud and counterfeiting of non-cash means of payment

    EPIF welcomes the European Commission’s work to update the framework sanctioning criminal activity where non-cash means of payment fraud are concerned. By improving the effectiveness of prosecution of criminal activity where prevention has failed is, this initiative will foster trust and security in the online environment and contribute to the EU’s Digital Single Market.

    » Download (PDF, 485.72 kB)
  • 31.05.2017

    EPIF response to consultation on restrictions on payments in cash

    EPIF is pleased to share its response to the Commission consultation on restrictions on payments in cash.

    EPIF believes that EU-wide action to restrict payments in cash is unnecessary at this time. Cash remains  the payment  method of choice for many people, due to its convenience, its portability and its universal acceptance.

    » Download (PDF, 322.18 kB)
  • 23.05.2017

    EPIF Response to the Article 29 Working Party Guidelines on Data Protection Impact Assessment (DPIA)

    EPIF is pleased to share its response to the Article 29 Working Party Guidelines on Data Protection Impact Assessment (DPIA).

    For EPIF, the central question is what ‘high risk’ means to the regulators and to companies. Companies need legal certainty of how the rules will be applied.

    » Download (PDF, 444.51 kB)
  • 16.05.2017

    EPIF Response to EBA consultation on procedures for complaints of alleged infringements of the PSD2

    EPIF generally agrees with the proposed Guidelines 1-6 but underlines the importance of the Home State Principle and its application to the complaints procedure for alleged infringements of the PSD2. 

    » Download (PDF, 320.74 kB)
  • 05.05.2017

    EPIF’s repsonse to the consultation on Central Contact Points

    EPIF is glad to share its response to the consultation on Central Contact Points. EPID agree with the princple of CCP but is of the view that it is crucial that the EBA provides guidance to Member States on the form of CCPs to avoid Member States to take on different approaches. 

     

    » Download (PDF, 543.32 kB)
  • 13.04.2017

    EPIF response to Questionnaire on the EBA Register

    EPIFsupports the PSD2’s creation of a central EBA Register, which will serve as a one-stop-shop for consumers and businesses alike to access up-to-date information about the Payment Service Providers (PSPs) they interact with.

    From a Payment Institution’s (PI) perspective, EPIF is of the view that the Register should provide capabilities for real-time partner verifications through fast and directly accessible APIs. 

    » Download (DOCX, 85.97 kB)
  • 13.04.2017

    EPIF response to EBA Questionnaire related to the RTS on CCPs

    EPIF would welcome confirmation as to whether agents who are not acting on behalf of a PI in providing payment services.

    The CCP should be able to manage country level reporting to the regulator but it is not necessary for the CCP to conduct its own additional offsite or onsite audits or investigations.   

    EPIF would welcome the EBA recommendations as to the form of the CCP, to avoid lack of harmonisation across Member States. 

     

    » Download (PDF, 432.19 kB)
  • 07.04.2017

    Co-signed letter to Commissioner Dombrovskis on RTS on SCA

    EPIF is pleased to have co-signed a letter together with 18 other associations on the draft RTS on SCA. The letter provides the high-level postion of major payments industry operators with regards to the draft RTS on SCA. The letter ackknowledges the need for a Transaction Risk Analysis (TRS), supports a result-oriented approach and encourages the Commission to host a multistakeholder workshop. 

    » Download (PDF, 333.17 kB)
  • 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.

    » Download (PDF, 339.58 kB)
  • 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.

    » Download (PDF, 600.66 kB)
  • 02.12.2016

    EPIF Position Paper On The EBA Gl ON PI Insurance

    EPIF does not agree on the requirement of undertakings and believe that the minimum monetary amount  should always cover the potential liabilities.

    EPIF does not agree on the indicators under the type of activity criteria should be calculated and believes that the size of activity indicator is exaggerated.

    » Download (PDF, 365.17 kB)
  • 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. 

    EPIF is supportive of the initiatives that introduces a more robust legal environment and measures to counter terrorist financing and money laundering.

    EPIF suggests putting together the different existing lists of high risk third countries to avoid contradictions among EU Member States 

    » 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.

    » Download (PDF, 326.00 kB)
  • 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.

    » Download (PDF, 441.65 kB)
  • 22.03.2016

    EPIF Response to the Green Paper on Retail Financial Services

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

    EPIF strongly supports a single market in payments although the diverse business models of payment institutions needs to be taken into account also from a regualtory perspective. 

    » 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.

    EPIF suggests that Host State competent authorities should provide reference to applicable main regulations and reporting requirements for Payment Insitutions using their passporting rights in the Host Country. EPIF strongly suggest no using the post which will introduce delays and risks where electonic means are quicker and safer. 

     

    » 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.

    EPIF believes that there should be a unified framework for a risk-based approach amd that the diversity of the payments industry needs to be takeni nto acocund when formulating an RBA. 

    » 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). 

    » Download (PDF, 345.86 kB)
  • 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.

    » Download (PDF, 352.06 kB)
  • 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.

    » Download (PDF, 489.83 kB)
  • 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.

    » Download (PDF, 520.25 kB)
  • 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.

    » Download (PDF, 655.17 kB)
  • 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.

    » Download (PDF, 473.69 kB)
  • 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.

    » Download (PDF, 141.72 kB)
  • 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.

    » Download (PDF, 115.91 kB)
  • 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)