Liability for indirect access to payment systems scenarios implies risk if not well considered - study

Among other highlights, the whitepaper draws attention upon teh fact that whilst the lack of bank account provision may be seen as stifling competition for new entrants into the payments market, there is no evidence that this is because of a fear of competition by the provider banks.

Rather it appears that the impacts of regulation have caused the costs and complexities involved in engaging with and monitoring the activities of the new and smaller regulated entities, to become less commercial and at the same time, still with risk attached.

The paper proposes actions, which it is considered may lead to a more normalised business environment, but which will require pan-industry and regulator engagement to achieve progress:
• Updated current guidance together with supporting business and transactional, specific guidance
• Clearer guidance from regulators of ‘what constitutes failure’
• Open discussion on the costs of monitoring and how to cover them
• Co-ordinated development of Best Practice Guidance on developing working relationships with the Banks and
what constitutes a ‘good risk profile’ for the PSP type and its transactions

For more information on the whitepaper please download the full version available here.