Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS. Dear sir / madam. Payment systems regulation call for inputs
|
|
- Allan Lindsey
- 5 years ago
- Views:
Transcription
1 Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Dear sir / madam Payment systems regulation call for inputs We appreciate the opportunity to respond to this consultation. The Association of British Credit Unions Limited (ABCUL) is the main trade association for credit unions in England, Scotland and Wales. Out of the 393 credit unions which choose to be a member of a trade association, 72% choose to be a member of ABCUL. Credit unions are not-for-profit, financial co-operatives owned and controlled by their members. They provide safe savings and affordable loans. Some credit unions offer more sophisticated products such as current accounts, ISAs and mortgages. At 30 September 2013, credit unions in Great Britain were providing financial services to 1,075,951 people, including 122,280 junior savers. The sector held more than 1.1 billion in assets with more than 641 million out on loan to members and 918 million in deposits. 1 Credit unions work to provide inclusive financial services has been valued by successive Governments. Credit unions participation in the Growth Fund from saw over 400,000 affordable loans made with funding from the Financial Inclusion Fund. The DWP has contracted ABCUL to lead a consortium of credit unions under the Credit Union Expansion Project, which will invest up to 38 million in the sector and aims to make significant steps towards sustainability. Response to consultation On behalf of our member credit unions, we would like to express strong overall support for the importance of a payment systems regulator which takes a broad view of its remit and role in order to encompass as wide as possible a range of payment systems and services. Credit unions, as small deposit-taking co-operative financial institutions, increasingly seek to provide payment and transactional banking services to their members through products such as the Credit Union Current Account or the Credit Union Prepaid Card in order to attract a wide range of members and to operate sustainably. The full service model is one that has fuelled success for credit union sectors around the world where, in the US and Canada, for instance, as many as 40% of people 1 Figures from unaudited quarterly returns provided to the Prudential Regulation Authority
2 belong to a credit union. This is the kind of success which we wish to see emulated by credit unions in Great Britain and fair access to payment systems is central to that. Currently, small providers of payment systems, such as credit unions are reliant upon arrangements with sponsoring banks in order to provide payment services. Credit unions have found significant difficulty in reaching agreements with such banks since their willingness to enter into sponsorship and agency arrangements is strictly limited. Where such agreements have, however, been reached it is very difficult for credit unions or similar operators to a. understand whether the access terms they are receiving are competitive since the payments structure and its operation by owner-user banks is so opaque and b. even were full knowledge of comparable terms is available, negotiate competitive terms where the supply of banks willing to facilitate access is so limited given the relative market power of the negotiating parties this necessarily creates. Therefore we would like to see a payments systems regulator which has authority over the full range of payments infrastructure in the UK. We would also like to see it take a far-reaching view of the possible action it might take to reform the landscape keeping radical measures such as divestments on the table as the system and its conflicts of interest are reviewed. It should also look at fundamental structural and minimum capacity barriers within the availability of access arrangements for small players and how the number of willing agency and sponsoring banks can be increased. We are also conscious that the payments infrastructure is critical part of the economic system and innovation within it is vital in this respect. Due attention must be taken to ensure any measures the new regulator pursues do not inadvertently hinder this important process. That said, we also feel that while collaborative action is critical to innovation in payments, there is also the potential for conflicts of interest to stifle innovation and improvement and the new regulator should look closely at these issues. Consultation questions Q1. Do you have any views on which payments systems should be considered for designation? If this includes parties other than the UK payments systems listed above, please explain why. In general, we feel that the entire payments system infrastructure should be brought under the purview of the new regulator. This includes at least all of those payment systems listed. In order for the regulator to ensure a level playing field between payment services providers it is vital that all relevant payment systems are within its remit to review and intervene in. Q2. Where do you believe competition is effective or ineffective within UK payment systems? Competition between payments systems providers is not evident in any great degree given the collaborative development of payment infrastructure and the tendency for the each type of payment system to meet a particular niche need or market. The uniformity across UK payments and in terms of system providers and owners brings some benefits in terms of consistency of service across the country and avoids potential costs of more fragmented and disintegrated payment infrastructure for the consumer. However, there are concerns that this lack of competition
3 might undermine consumer interests in terms of allowing costs to be held up or, critically for our purposes, preventing entry at retail level by small payment providers. We do not attempt to provide a clear answer to these issues but wish primarily to urge that the new regulator looks carefully at these questions and the balance of interests between competition and collaboration without pre-empting the process by taking any early decisions on action. Q3. At which level(s) is there potential for competition to drive benefits for service-users, in terms of costs, quality or innovation? We feel that greater competition has the potential to yield significant benefits at all levels within the payment system infrastructure. Our particular concern is greater competition at retail level driven by measures to ensure fair access to payments infrastructure for small payment service providers, such as credit unions. Better access terms in this respect will drive competition between payment providers which will ultimately improve both outcomes for consumers but also financial stability through improved corporate diversity in financial services. Beyond the case for competition at the retail level, however, there are strong arguments for the new regulator to examine the impact of competition or lack thereof in relation to payments systems themselves and in terms of innovations. Were new payment systems able to set up and integrate with existing systems more easily, for instance, this could increase the competitive pressures driving innovation elsewhere and improvement of services overall. The regulator should examine the full payment infrastructure and how it might respond to greater competition. It should consider the examples of payments internationally both in the developed and developing world where more open regimes are yielding great benefits in terms of innovation and consumer choice. Q4. What are the main factors impeding more effective competition at each level? There are a number of factors here that we would like to highlight. Firstly, there would appear to be signs that the conflict of interest between ownership of payment infrastructure and usage thereof is having a negative effect on competition. Secondly, the lack of competing platforms for different payment instruments is a concern. Thirdly, the market for agency banks, required by small players is particularly stifling of competition since it limits the opportunity to search the market since no real market exists. Fourthly, the lack of transparency around costs and access terms for various providers and a range of levels impedes effective negotiation. Fifthly, there are questions of volume and scale which can present a barrier to entry for small players both in respect of investment capital or lack thereof and in terms of access terms in relation to fees per payment and such like. Sixthly, there are questions about the opportunities for payments innovators to build new payments infrastructure outwith the existing infrastructure owners and structures without the ability to effectively integrate with said systems. While we are in no position to suggest the degree to which each of these factors is stifling competitive forces or to propose clear solutions, we feel all of them are questions which the new regulator should seek to promptly address. Q5. What functions do you think need to be performed collaboratively in the industry? How best can this be achieved?
4 We agree that the payment systems and infrastructure, by their nature, are required to be collaboratively developed at at least the level of setting the key protocols and standards as to how the system operates. However, the precise limits of the collaboration argument against encouraging too much competition in payments infrastructure must be a key task for the regulator to examine and establish. We would suggest that the level of collaboration and integration in UK payments to date is extremely close relative to systems operating in other places and that, therefore, the question should be how far this is necessary and desirable in light of other concerns over competition and consumer outcomes. Q6. Do you think the current ownership structure creates problems? If so, please explain your concerns with the current structure. Yes. Our principal concern is quite clear in that there would appear to be the potential for a conflict of interest since those firms which own the payments infrastructure are its main users in terms of providing payment services to consumers. Therefore, as long as small providers are required to negotiate terms through these same providers, they have no incentive to provide this on a fair and comparable basis. Similarly, there are question marks regarding the minimum benchmarks which are set to access payment infrastructure directly and whether these could be lowered to avoid the need for agency arrangements. Q7. How might the regulator address any issues with the current ownership structure? Please explain how any remedy, including alternate model, might address any or all of the issues you have identified and also highlight any potential concerns associated with such alternate ownership. We do not have any clear preference as to how this might best be resolved. There would appear, however, to be two options the first of these would be divestment and the creation of new payment infrastructure providers in order to create new competition; secondly, one could stop short of divestment but instead create a separate governance structure to oversee payment concerns with a clear focus on enhancing competition and consumer outcomes. In any case, the key criterion of success should be resolving conflicts of interest either through divestment or tighter regulation and the test of this should be the degree to which improved access terms are evident in addition to further innovation and transparency. Q8. Do you have any concerns about the current governance of UK payment systems? We do have concerns relating to payment system governance. Our principal concern is the lack of a clear avenue by which small payment providers without an ownership stake might take a role in payments governance. We would like to see such a role created under any reformed governance structure for payments post-regulation. Q9. What do you believe is the appropriate governance structure for UK payments systems? As above, we would be keen for any reformed governance structure to provide a voice for small payment providers and wider societal and consumer concerns regarding payment infrastructure. Q10. How do you access UK payment systems?
5 Our member credit unions access payment systems in a number of ways and with a range of levels of sophistication. At the most basic level, this amounts to operating through the credit union s own bank account service and operating payments semi-manually in the same way that an ordinary business customer would do. This is limiting for a credit union, as a financial institution, in terms of being able to serve its own members effectively since it builds in extra delays and inefficient processing. At a further level up from this, some credit unions are able to provide payment systems such as the Credit Union Current Account or the Credit Union Prepaid Card which operate through agency bank arrangements. The Credit Union Current Account is hosted on the Co-operative Bank s banking platform and provides full account number and sort code facilities to each credit union which operates the system. The account operates on Visa Debit and therefore allows point of sale and ATM access globally. There are disadvantages to the agency arrangement here since the credit unions do not benefit from multi-interchange fees and the account does not provide the full range of payments and access channels that direct participation might. Furthermore, there are limitations in respect of the fees which credit unions are required to pay for various account operations which we have difficulty in assessing against the market due to lack of clear pricing information. The Credit Union Prepaid Card also has Visa Debit functionality but as a prepaid card does not offer the broader payment options available to the Current Account. The key element of note here is that, fees and charges for this product are tied closely to volumes which credit unions can find difficulty in achieving effectively in order to make the product sustainable. Similarly, we have recently experienced difficulties in relation to the availability of sponsoring banks as the bank we had used decided to withdraw from the market and there is a very limited availability of sponsoring banks in the prepaid card market with whom to partner. ABCUL, as part of the Credit Union Expansion Project, is investing in the development of a banking platform which should provide the processing capacity to engage more closely with payment infrastructure through a collaborative model. Critical to this, however, will be the access terms that the new entity is able to negotiation with the available agency banks. Q11. For the access you describe above, are the access terms and conditions fair and reasonable? If not, please provide details. This is a difficult question to answer definitively. There are a combination of factors at play which partly relate to required capacity for direct participation in payment infrastructure and partly relate to access terms in terms of fees and such. Similarly, the lack of available partner banks puts small providers at a distinct disadvantage in negotiation with sponsoring banks. We believe that it is certainly the case that the terms we enjoy could be improved substantially were any of these key barriers addressed. Q12. Does the access arrangement you currently have limit your ability to compete or impact on the service-users experience in any way? Yes. Credit unions at the most simplistic level i.e. without even indirect access to payment systems other than as a retail customer have very high barriers to fairly compete since their processes are necessarily inefficient and there are extra delays and costs for consumers from the laborious processing that is required. At the more sophisticated level, this is also the case since
6 credit unions are not able to provide the full service that a market-leading provider can provide and also are required to pay higher costs both Current Account and Prepaid Card are fee-charging to members and this is very uncompetitive for those who have options about which provider to use. Q13. If you access payment systems indirectly through a sponsoring agreement with a direct member banks, do you have sufficient choice in sponsoring banks? Would you prefer to access payment systems directly? What do you see as the benefits and risks of doing so? As set out above, credit unions can only access payments systems indirectly and to varying degrees. Where payment services are provided in any significant way, i.e. for those credit unions providing the Credit Union Current Account or the Credit Union Prepaid Card, the credit union sector has faced a strictly limited number of available sponsoring banks willing to facilitate access to payment systems for credit union members. The availability of sponsoring banks, or lack thereof, has been a particular concern in relation to the Prepaid Card service very recently since the credit unions' existing partner has withdrawn from the market with very few others available. The only alternative to agreeing these arrangements as a sector directly with sponsoring banks is to go through a third-party processor and this adds significant extra cost. As a sector we would be very interested in exploring the possibility of accessing payment systems directly or, failing that, for the provision of access to small payment providers to be mandated in some other way. Direct access, in principle, would generally be the favoured approach, however, there are currently obligations and minimum requirements in which must be met and it is not clear whether credit unions would meet these in the short term as they are set. A key task of the new regulator should be in reviewing and testing these minimum requirements to ensure that they are not presenting undue barriers to access and market entry for small payment providers whose presence would otherwise yield competition benefits for the consumer. Q14. Do you act as a sponsoring bank, providing indirect access to any payment system participant in the UK? No Q15. What changes to access rules and conditions would you like to see? Are there any alternative routes to gain access to payment systems that you believe should be developed (e.g. a second tier membership to payment system operators)? We would like to see a new regulator make a detailed examination of the access rules and conditions for payment systems with a view to removing and lowering any barriers to entry for small players such as credit unions. Currently, there are significant barriers, such as the requirement to have access to central bank funds which prevent credit unions' access wholesale. On the basis of such a review, we would hope that either unnecessary barriers could be removed or least that alternative options to give small providers a more-direct access route to payment systems be considered. This could involve a new class of system membership or some other arrangement but the key objective should be to widen access and for access to be made as direct as feasible. Q16. Do you have any other comments regarding access?
7 We would only like to stress the need for greater transparency around payment system access terms because currently it is very difficult to establish how far terms are competitive and fair. Better awareness and standardisation of access costs and such would be extremely beneficial to provide a well-functioning market with well-informed participants. Q17. What improvements or changes do you believe are required in the provision and use of infrastructure in the UK? We would also be interested in your views on the cost of such changes, for you or for the industry as a whole. What considerations, if any, need to be considered regarding the impact of any chances or improvements on the resilience and reliability of payment systems? We feel the payment infrastructure in the UK is in need of significant investment and improvement. Recent examples of banking down time are testament to this. Furthermore, currently the investment requirement for access to payment systems in order to obtain the appropriate level of automation and capacity is very significant. We wonder whether the new regulator could play a role in facilitating cheaper access to banking platform technology in order to address some of these challenges. Q18. What changes, if any, are needed regarding messaging standards in the UK? For example, would the adoption of ISO20022 standards alleviate any concerns or improve any constraints you experience? What timeframe and considerations would need to be taken into account in adopting new standards? We would only say here, in the absence of more detailed knowledge, that messaging standards should always be designed and implemented in order to ensure effective access for small providers. Q19. What solutions can be developed to increase competition in the provision of infrastructure and / or managed services to support the technical and operational functions of agency banks participating in UK payment systems? How can this be achieved and what will the impact and benefits be to your business? There are no clear answers to this question assuming that the regulator would not be willing to take a direct interventionist role in the market in the sense of creating competitors and such. We would urge the new regulator to look at any steps it has available to it to increase the provision of infrastructure for accessing payment systems. There may be a case for some special intervention in order to ensure that all small payment providers can access infrastructure providers. At the least the regulator should examine where any barriers might exist to new providers entering the market. There would be untold benefits for businesses such as our members were the number of available infrastructure providers increased significantly. Q20. Are incentives to innovate clear under current arrangements? Please also include any concerns you may have regarding fee arrangements and the impact of changing fee structures (such as changes to interchange fees).
8 We do not feel that the incentives to innovate are particularly strong under the current arrangements. We feel that questions around ownership, market power and conflicts of interest have a key part to play in this which have already been addressed above. We would also stress here again transparency in the market it is very difficult to establish the true cost or otherwise of running payment systems which is illustrated by the OFT having to operate on inference and appearance, rather than clear data, in assessing the question. We hope that the new regulator will be able to establish more clarity around these questions in order that better policy can be made. Q21. Do any factors limit your ability or incentives, either collectively or unilaterally, to innovate within UK payment systems? Credit unions are limited here firstly due to their size and lack of available funds for investment. For small players more generally, there are barriers due to the difficulty of integrating new systems with the legacy systems which already exist. In other parts of the world particularly the developing world innovating mobile-based payment systems have become established extremely quickly thanks to the lack of legacy infrastructure with which to fit in and learning some of the lessons from this innovative environment will be useful in driving innovation in the UK. Q22. What changes, if any, are needed to facilitate a greater pace of innovation in UK banking and payments? Please refer to your previous answers where relevant. We feel that the issues of ownership, governance, transparency and access should all facilitate a greater pace of innovation in payments. There will be a need to open the market to new entrants and to provide the ability to integrate new systems with existing ones more easily than is currently the case. Q23. What do you believe are the benefits and limitations of collectively-driven innovation vs. unilateral innovation? Clearly, an element of collectivism is critical to the success of payment systems which require multiple parties to co-operate in order to function effectively. However, we feel that there is a greater place for smaller groups or individual innovators to operate more unilaterally in order to create a more competitive environment where incumbents are forced to keep up with more nimble innovators. Q24. Do you have any other comments or concerns that you would like to highlight? No Q25. What, if any, are the significant benefits you see regulation bringing? Regulation should provide an environment in which payment systems are challenged to justify their powerful market position. There are clearly a range of causes for concern which the regulator will be able to address particularly around ownership, competition, innovation, governance and access terms. A regulator able to look at and take action on these areas with a view to improving the experience of end-users should greatly enhance the operation of payment systems in the UK.
9 Q26. What, if any, are the risks arising from regulation of payment systems? There is the possibility that inappropriate intervention in the market could take payment systems backward by not effectively recognising the pressures which payment system providers face and the significant investment requirements, for instance, which are required in improving payment systems. If the regulator is careful about how it addresses these questions, however, it should be able to improve the payment services market without negatively affecting the existing system. Q27. How do you think regulation might affect your business and your participation in UK payment systems? We hope that regulation will greatly improve access terms and availability for small payment providers such as credit unions which will allow us to compete more effectively and, therefore, to provide more effective competition in payment services thereby enhancing our ability to improve the financial well-being of our members. Once again, we are grateful for the opportunity to respond to this consultation. We would be more than happy to discuss any of the points raised above in more detail. Please feel free to contact us. Yours sincerely, Mark Lyonette Chief Executive ABCUL
Contact details.
HM Treasury & Department for Business, Innovation & Skills A new approach to financial regulation: transferring consumer credit regulation to the Financial Conduct Response from the Association of British
More informationCaroline Russell AM Economy Committee London Assembly City Hall The Queen s Walk London, SE1 2AA. 28 September 2017
Caroline Russell AM Economy Committee London Assembly City Hall The Queen s Walk London, SE1 2AA 28 September 2017 Dear Caroline & the Economy Committee The Mayor s role in promoting and supporting financial
More informationOffice of Fair Trading Annual Plan consultation document
Office of Fair Trading Annual Plan consultation document 2012-13 Response from Association of British Credit Unions Limited (ABCUL) Contact details Abbie Shelton Policy & Communications Manager abbie.shelton@abcul.org
More informationHM Treasury & Department for Business, Innovation and Skills
HM Treasury & Department for Business, Innovation and Skills A new approach to financial regulation: consultation on reforming the consumer Response from the Association of British Credit Unions Limited
More informationFCA CP 13/10 Detailed proposals for the FCA regime for consumer credit. Response from the Association of British Credit Unions Limited (ABCUL)
FCA regime for consumer credit Response from the Association of British Credit Unions Limited (ABCUL) Contact details Abbie Shelton Policy & Communications Manager abbie.shelton@abcul.org Or Matt Bland
More informationFinancial Services Authority CP11/29 Deposit protection: raising consumer awareness
Financial Services Authority CP11/29 Deposit protection: raising consumer awareness Response from the Association of British Credit Unions Limited (ABCUL) Contact details Abbie Shelton Policy & Communications
More informationRetirement Outcomes Review Final report: annex 3: Feedback on interim findings and our early thinking on remedies, and our response
MS16/1.3: annex 3 Final report: annex 3: June 2018 1. In this annex, we summarise the feedback we received on the interim findings and our early thinking on potential remedies. We also respond to these.
More informationFinancial Conduct Authority 25 The North Colonnade, Canary Wharf London E14 5HS. Submitted to:
4th floor, Ropemaker Place 25 Ropemaker Street London EC2Y 9LY United Kingdom +44 20 7260 2000 Phone +44 20 7260 2001 Fax ihsmarkit.com Financial Conduct Authority 25 The North Colonnade, Canary Wharf
More informationHMRC and HMT Consultation Document: Taxing Gains Made by Non-Residents on UK Immovable Properties
James Konya NRCG Consultation HM Revenue & Customs Room 3C/04 100 Parliament Street London SW1A 2BQ 15 February 2018 Dear James HMRC and HMT Consultation Document: Taxing Gains Made by Non-Residents on
More informationRE: Wholesale sector competition review call for inputs
9 October 2014 Becky Young Policy, Risk and Research Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted via email to: wholesalecompetition@fca.org.uk RE:
More informationISA qualifying investments: including peer-to-peer loans HM Treasury
ISA qualifying investments: including peer-to-peer loans HM Treasury Visualise your business future with Altus Consulting Reference HMT/P2PISA/RESP Date 09/12/2014 Issue 1.0 Author Bruce Davidson Security
More informationProposal for a regulation on the establishment of a framework to facilitate sustainable investment Contact person:
Position Paper Insurance Europe comments on the European Commission proposal for a regulation on the establishment of a framework to facilitate sustainable investment Our reference: Referring to: ECO-LTI-18-033
More informationDirect Debit Facilities Management: Switching providers
Consultation paper Direct Debit Facilities Management: Switching providers Consultation on provisional conclusions and proposals to change the Direct Debit rules relating to the switching of Facilities
More informationLondon, August 16 th, 2010
CESR The Committee of European Securities Regulators Submitted via www.cesr.eu Standardisation and exchange trading of OTC derivatives London, August 16 th, 2010 Dear Sirs, MarkitSERV welcomes the publication
More informationPrimary Markets Policy team Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 21 July 2017
Primary Markets Policy team Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 21 July 2017 Dear Sir or Madam, Response to Consultation Paper CP17/21: Proposal to create a new
More information1303 J Street, Suite 600, Sacramento, CA T: 916/ F: 916/
1303 J Street, Suite 600, Sacramento, CA 95814-2939 T: 916/438-4400 F: 916/441-5756 Via FedPaymentsImprovement.org Federal Reserve Financial Services Dear Sir/Madam: Re: Payment System Improvement - Public
More informationA response to European Commission consultation Possible initiatives to enhance the resilience of OTC Derivatives Markets by Thomson Reuters
August 2009 A response to European Commission consultation Possible initiatives to enhance the resilience of OTC Derivatives Markets by Thomson Reuters Thomson Reuters (TR) is the world s leading source
More informationFrom cradle to grave - EIOPA s dynamic approach to restoring consumer confidence in the sale of general insurance products.
SPEECH Manuela Zweimueller Director of Regulations From cradle to grave - EIOPA s dynamic approach to restoring consumer confidence in the sale of general insurance products. FCA General Insurance Sector
More informationReview of Barriers to Entry, Expansion and Exit in Retail Banking: Call for Evidence
Barriers to Entry in Banking Review Team 4 th Floor Fleetbank House 2-6 Salisbury Square London EC4Y 8JX 6 th July 2010 Dear sir / madam Review of Barriers to Entry, Expansion and Exit in Retail Banking:
More informationLink Scheme Holdings Ltd CPMI - IOSCO Disclosure for the LINK Payment System 31 st December 2018
Link Scheme Holdings Ltd CPMI - IOSCO Disclosure for the LINK Payment System 31 st December 2018 Responding Institution: Jurisdiction: Authorities Regulating: Link Scheme Holdings Ltd UK (English Law)
More informationAlternative Investment Management Association
CESR 11-13 avenue de Friedland 75008 Paris France Submitted online via CESR s website 16 August 2010 Dear Sirs, The Committee of European Securities Regulators Consultations on: - Standardisation and exchange
More informationShell Energy Europe Ltd
Shell Energy Europe Ltd Via e-mail: consultation2012r10@acer.europa.eu 80 Strand London WC2R 0ZA United Kingdom Tel: +44 20 7546 2460 Email: amrik.bal@shell.com 31 July 2012 ACER Public Consultation Paper
More informationCESR and ERGEG advice to the European Commission in the context of the Third Energy Package (Ref: CESR/ and C08-FIS-07-03)
EnBW Trading GmbH EnBW Trading GmbH Großkunden-PLZ: 76180 Karlsruhe Committee of European Securities Regulators (CESR) European Regulators' Group for Electricity and Gas (ERGEG) Name Dr. Bernhard Walter
More informationConsultation response
Consultation response European Commission DG Markt DATE: 06 April 2009 TO: markt-retailconsultation@ec.europa.eu RESPONSE BY: Vera Cottrell Principal Policy Advisor Which? Re: Financial inclusion: Ensuring
More informationThis final response is in addition to our first stage response submitted to CESR on 10 September and covers the following sections:
17 th September 2004 London Office 114 Middlesex Street London E1 7JH Tel: +44 (0) 20 7247 7080 Fax: +44 (0) 20 7377 0939 Email: info@apcims.co.uk By email to CESR at www.cesr-eu.org Dear Sirs Final Response
More informationESMA s policy orientations on possible implementing measures under the Market Abuse Regulation
24 January 2014 European Securities and Markets Authority 103 rue de Grenelle 75007 Paris France Submitted online at: www.esma.europa.eu RE: ESMA s policy orientations on possible implementing measures
More informationCP19/15: Contractual stays in financial contracts governed by third-country law
Andrew Hoffman and Leanne Ingledew Prudential Regulation Authority 20 Moorgate London EC2R 6DA Cp19_15@bankofengland.co.uk 14 th August 2015 Dear Leanne and Andrew, CP19/15: Contractual stays in financial
More informationPCAOB RELEASE (RULE 4003) of 4 December 2008
KPMG LLP Tel +44 (0) 20 7311 1316 8 Salisbury Square Fax +44 (0) 20 7311 4242 London EC4Y 8BB DX 38050 Blackfriars United Kingdom Office of the Secretary PCAOB 1666 K Street, N.W., Washington, DC 2006
More informationImproving the home buying and selling process: UK Finance response to the DCLG call for evidence
Improving the home buying and selling process: UK Finance response to the DCLG call for evidence 15 December 2017 Introduction UK Finance represents around 300 firms in the UK providing credit, banking,
More informationFinance Committee. Inquiry into methods of funding capital investment projects. Submission from PPP Forum
About Finance Committee Inquiry into methods of funding capital investment projects Submission from Established in 2001, the is an industry body representing over 110 private sector companies involved
More informationQuality Assurance Scheme for Organisations
Quality Assurance Scheme for Organisations New policy proposals by the Professional Regulation Executive Committee Exposure Draft ED 30 Consultation paper May 2013 Contents 1. Introduction and background
More informationRE: Developing our approach to implementing MiFID II conduct of business and organisational requirements
Tom Ward Strategy and Competition Division Financial Conduct Authority 25 The North Colonnade London E14 5HS Email to: dp15-03@fca.org.uk Date: 26 May 2015 Dear Sir RE: Developing our approach to implementing
More informationResponse to the Commission s Communication on An EU Cross-border Crisis Management Framework in the Banking Sector
20/01/2010 ASOCIACIÓN ESPAÑOLA DE BANCA Velázquez, 64-66 28001 Madrid (Spain) ID 08931402101-25 Response to the Commission s Communication on An EU Cross-border Crisis Management Framework in the Banking
More informationEBF contribution to the public consultation on the EU Commission s Green Paper on the Consumer Acquis Review
AMS/DB N 411 European Commission Directorate General Health and Consumer Protection Rue de la Loi 200 B- 1049 Brussels SANCO-B2@ec.europa.eu Email Brussels, 24 May 2007 Subject: EBF contribution to the
More informationINTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS
INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS ISSUES PAPER ON GROUP-WIDE SOLVENCY ASSESSMENT AND SUPERVISION 5 MARCH 2009 This document was prepared jointly by the Solvency and Actuarial Issues Subcommittee
More informationCollective defined contribution pension schemes inquiry Response from the Pensions Policy Institute
Collective defined contribution pension schemes inquiry Response from the Pensions Policy Institute Summary In 2014 the were commissioned by the DWP to construct a model to attempt to replicate the Aon
More informationQ1. Should the PRIPS initiative focus on packaged investments? Please justify or explain your answer.
European Commission 31.01.11 PRIPS -CONSULTATION Dear Sirs, The Federation of International Advisers (FEIFA) represents the interests of Independent Financial Advisers (IFAs) operating across, at present,
More informationThe FCA s response to the CMA s consultation on its provisional decision to refer personal current accounts and SME banking
Financial Conduct Authority The FCA s response to the CMA s consultation on its provisional decision to refer personal current accounts and SME banking September 2014 Contents 1 Executive summary 2 2
More information26 April CarolAnne Macdonald Policy, Risk and Research Division Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS
26 April 2013 CarolAnne Macdonald Policy, Risk and Research Division Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS Email: transparencydp@fsa.gov.uk Dear CarolAnne LMA
More informationWholesale Conduct Policy Team Markets Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS
Wholesale Conduct Policy Team Markets Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted to dp14-03@fca.org.uk London, September 16, 2014 Discussion Paper
More informationCOMMISSION CONSULTATION ON REVIEW OF DIRECTIVE 94/19/EC ON DEPOSIT GUARANTEE SCHEMES
European Commission Internal Market and Services DG Financial Institutions markt-dgs-consultation@ec.europa.eu Interest Representative ID 7328496842-09 COMMISSION CONSULTATION ON REVIEW OF DIRECTIVE 94/19/EC
More informationHigh-cost credit review: Feedback from roundtables
Financial Conduct Authority High-cost credit review: Feedback from roundtables Introduction 1. This paper summarises the issues and ideas raised by participants in our roundtables. These points do not
More informationProposed Criteria and Risk-management Standards for Prominent Payment Systems
Proposed Criteria and Risk-management Standards for Prominent Payment Systems Canadian Payments Association Submission in Response to Bank of Canada August 21, 2015 Note: This submission reflects the views
More informationRe: BEPS Action 4: Interest Deductions and Other Financial Payments
OECD Committee on Fiscal Affairs Working Party No. 11 By email: interestdeductions@oecd.org 6 February 2015 Dear Sirs, Re: BEPS Action 4: Interest Deductions and Other Financial Payments We are writing
More informationDetailed Recommendations 2: Develop Green Funds
Detailed Recommendations 2: Develop Green Funds 2 This is a background paper to the report: Establishing China s Green Financial System published by the Research Bureau of the People s Bank of China and
More informationChapter 16. Universal Service
Chapter 16 Universal Service Nicholas Garnham 1.0 What is Universal Service? There is now widespread agreement on a definition of universal service in telecom which in the words of OFTEL in the UK, is
More informationEU Transparency Register ID Number
EU Transparency Register ID Number 271912611231-56 ESMA S 60747 103 rue de Grenelle 75345 Paris edex 07 France Deutsche Bank AG Winchester ouse 1 Great Winchester Street London E2N 2DB Tel +44 (0) 207
More informationDocket No. OP-1625; Potential Federal Reserve Actions to Support Interbank Settlement of Faster Payments
Via Electronic Submission December 14, 2018 Ms. Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20 th Street and Constitution Avenue, N.W. Washington, DC 20551 Re: Docket No.
More informationThe ABI's registration number on the European Commission's Register of Interest Representatives is:
ASSOCIATION OF BRITISH INSURERS RESPONSE TO THE DRAFT REGULATION ON THE APPLICATION OF ARTICLE 81(3) OF THE TREATY TO CERTAIN CATEGORIES OF AGREEMENTS, DECISIONS AND CONCERTED PRACTICES IN THE INSURANCE
More informationFIRST-NATION GOVERNMENT AND NON-NATIVE TAXPAYERS: HARMONIZING RELATIONSHIPS by Robert L. Bish University of Victoria
FIRST-NATION GOVERNMENT AND NON-NATIVE TAXPAYERS: HARMONIZING RELATIONSHIPS by Robert L. Bish University of Victoria I. INTRODUCTION The power to tax is an important and essential power of any government.
More informationFinancial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS. 26 January 2018
Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 26 January 2018 (Uploaded at the Financial Conduct Authority s website) Dear Sir/Madam, Standard Chartered s Response to the
More informationBank of Mauritius. National Payment Switch
Bank of Mauritius National Payment Switch January 2016 1 Introduction The Bank of Mauritius (Bank) is empowered under the Bank of Mauritius Act to safeguard the safety, soundness and efficiency of payment,
More informationStellungnahme der Deutschen Aktuarvereinigung e.v.
Stellungnahme der Deutschen Aktuarvereinigung e.v. EUROPEAN COMMISSION S CONSULTATION DOCUMENT CAPITAL MARKETS UNION: ACTION ON A POTENTIAL EU PERSONAL PENSION FRAMEWORK Köln, 31. Oktober 2016 A. On the
More informationMahin Choudry Competition Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS
Mahin Choudry Competition Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Submitted via email to assetmanagementmarketstudy@fca.org.uk London, December 18 th 2015
More informationMay 19, Re: Request for Information Regarding Use of Alternative Data and Modeling Techniques in the Credit Process, Docket No.
May 19, 2017 Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Information Regarding Use of Alternative Data
More informationSecurity and Sustainability in Defined Benefit Pension Schemes Green Paper Questions and NFOP Responses
Security and Sustainability in Defined Benefit Pension Schemes Green Paper Questions and NFOP Responses OVERVIEW NFOP represents 65,000 individual pensioners predominantly in three Defined Benefit Pension
More informationEuropean Association of Co-operative Banks Groupement Européen des Banques Coopératives Europäische Vereinigung der Genossenschaftsbanken
Brussels, 21 March 2013 EACB draft position paper on EBA discussion paper on retail deposits subject to higher outflows for the purposes of liquidity reporting under the CRR The voice of 3.800 local and
More informationConsultation response: Financial Capability Strategy for the UK
Consultation response: Financial Capability Strategy for the UK Response by the Money Advice Trust Date: October 2014 Contents Page 2 Page 3 Page 4 Page 5 Contents Introduction / About the Money Advice
More informationInsight into the Current Status of Clearing Members Brexit Contingency Plans
Insight into the Current Status of Clearing Members Brexit Contingency Plans June 2018 CONTENTS EXECUTIVE SUMMARY...2 RECOMMENDATIONS...3 KEY FINDINGS...4 KEY RESPONSES TO FIA S SURVEY QUESTIONS...6 About
More informationNumber portability and technology neutrality Proposals to modify the Number Portability General Condition and the National Telephone Numbering Plan
Number portability and technology neutrality Proposals to modify the Number Portability General Condition and the National Telephone Numbering Plan Consultation Publication date: 3 November 2005 Closing
More informationApril 16, Pension Policy Alberta Finance and Enterprise #402, Terrace Building Street Edmonton, AB T5K 2C3. Dear Sir or Madam:
Advocis 390 Queens Quay West, Suite 209 Toronto, ON M5V 3A2 T 416.444.5251 1.800.563.5822 F 416.444.8031 www.advocis.ca April 16, 2010 Pension Policy Alberta Finance and Enterprise #402, Terrace Building
More informationBBA RESPONSE TO JOINT COMMITTEE CONSULTATION PAPER ON GUIDELINES FOR CROSS-SELLING PRACTICES JC/CP/2014/05
20 March 2015 BBA RESPONSE TO JOINT COMMITTEE CONSULTATION PAPER ON GUIDELINES FOR CROSS-SELLING PRACTICES JC/CP/2014/05 1. The British Bankers Association ( BBA ) welcomes the opportunity to respond to
More informationAlternative Investment Management Association
By email only to: rule-comments@sec.gov Dear Sirs 19 June 2009 AIMA s comments on the new short sale rules proposed by the Securities and Exchange Commission AIMA 1 is pleased to have the opportunity to
More informationCONSULTATION DOCUMENT CAPITAL MARKETS UNION: ACTION ON A POTENTIAL EU PERSONAL PENSION FRAMEWORK
CONSULTATION DOCUMENT CAPITAL MARKETS UNION: ACTION ON A POTENTIAL EU PERSONAL PENSION FRAMEWORK A. INFORMATION ABOUT THE RESPONDENT (p8) 1. Are you replying as: an organisation or a company 2. First Name,
More informationPlease contact me should you wish to discuss any of the points raised in the attached response.
16 April 2008 Our ref: ICAEW Rep 44/08 Adetutu Odutola Markets Policy The Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS By email dp08_1@fsa.gov.uk Dear Ms Odutola FSA
More informationManaging the risks of legacy ICT to public service delivery
Report by the Comptroller and Auditor General Cross-government Managing the risks of legacy ICT to public service delivery HC 539 SESSION 2013-14 11 SEPTEMBER 2013 4 Key facts Managing the risks of legacy
More informationCo-operation between Competition Agencies and Regulators in the Financial Sector - Note by South Africa
Organisation for Economic Co-operation and Development DAF/COMP/WP2/WD(2017)23 English - Or. English DIRECTORATE FOR FINANCIAL AND ENTERPRISE AFFAIRS COMPETITION COMMITTEE 30 November 2017 Working Party
More information12 February International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom. Dear Mr Hoogervorst,
12 February 2016 International Accounting Standards Board 30 Cannon Street London EC4M 6XH United Kingdom Dear Mr Hoogervorst, Re: IASB ED/2015/11 Applying IFRS 9 Financial Instruments with IFRS 4 Insurance
More informationBSA Response to FCA Loan-based ('peer -topeer') platforms consultation. CP18/20. Restricted 25 October 2018
BSA Response to FCA Loan-based ('peer -topeer') and investmentbased crowdfunding platforms consultation. CP18/20 Restricted 25 October 2018 Introduction The Building Societies Association (BSA) represents
More informationABI Response to CESR Consultation Paper on Transaction Reporting
ABI Response to CESR Consultation Paper on Transaction Reporting The ABI s Response to ref CESR/10-292 The Association of British Insurers (ABI) is the voice of the insurance and investment industry. Its
More informationThe Warm Home Discount Scheme Consultation response by National Energy Action (NEA)
The Warm Home Discount Scheme Consultation response by National Energy Action (NEA) 1. About NEA 1.1 NEA is an independent charity working to protect low income and vulnerable households from fuel poverty
More informationD1387D-2012 Brussels, 24 August 2012
D1387D-2012 Brussels, 24 August 2012 Launched in 1960, the European Banking Federation is the voice of the European banking sector from the European Union and European Free Trade Association countries.
More informationFrank Field MP Work & Pensions Select Committee House of Commons LONDON SW1A 0AA. 24 June Dear Mr Field
Frank Field MP Work & Pensions Select Committee House of Commons LONDON SW1A 0AA 24 June 2016 Dear Mr Field 1. Further to our letter to the committee of 20 May, this submission provides some further information
More informationThe Canadian Payments System: Public Policy Objectives and Approaches
Discussion Paper 2 The Canadian Payments System: Public Policy Objectives and Approaches Background Paper for Discussion by the Payments System Advisory Committee Prepared by Staff of the Bank of Canada
More informationWork and Pensions Committee. Inquiry into Collective Defined Contribution Pension Schemes. Response from The Pensions Management Institute
Work and Pensions Committee Inquiry into Collective Defined Contribution Pension Schemes Response from The Pensions Management Institute - 2 - Response from the Pensions Management Institute to Work and
More informationEuropean Commission Consultation on Institutional Investors and Asset Managers Duties Regarding Sustainability
Directorate-General for Financial Stability, Financial Services, and Capital Markets Union European Commission 1049 Bruxelles/Brussel Belgium Re: European Commission Consultation on Institutional Investors
More informationGetting started. Introducing your account
Getting started Introducing your account 2 Welcome to banking designed to suit your taste When it comes to banking, we don t believe one size fits all. That s why in addition to our regular Bank Account,
More informationConsultation Paper: Proposed exemption to facilitate personalised robo-advice
Consultation paper June 2017 Consultation Paper: Proposed exemption to facilitate personalised robo-advice About this consultation paper We are considering using our exemption powers to facilitate the
More informationRe: IIROC Rules Notices Proposed Amendments to the Definition of Basis Order
Kevin McCoy, Director, Market Regulation Policy, Investment Industry Regulatory Organization of Canada, Suite 2000 121 King Street West, Toronto, Ontario, M5H 3T9 Kmccoy@iiroc.ca June 20, 2014 Re: IIROC
More informationSubmitted online and by to
13 th May 2015 The European Commission, Brussels Submitted online and by email to fisma-securitisation-consultation@ec.europa.eu Dear Sirs, Executive Summary of AFME response to the Consultation Document
More informationKeynote address International Investors Conference European Capital Markets Union Update and Future
Date: 18 October 2018 ESMA35-43-1376 Keynote address International Investors Conference European Capital Markets Union Update and Future 27 November 2018, Wiesbaden, Germany Verena Ross ESMA Executive
More informationResponse to DWP Green Paper consultation
Response to DWP Green Paper consultation May 2017 Making Sense of Pensions Security and Sustainability in Defined Benefit Pension Schemes Response to Green Paper Consultation This is a response to the
More informationAssessing Capital Markets Union
6 Assessing Capital Markets Union Quarterly Assessment by Paul Richards Summary It is too early to make an assessment of Capital Markets Union, but not too early to give a market view of the tests by which
More informationInvestor Key Information Understanding your investment
Key Information and Investor Terms Investor Key Information Understanding your investment You should read the following information and the Investor Terms (below) carefully before making your investment.
More informationNovember 12, 2013 By
Hugh Carney Senior Counsel Office of Regulatory Policy 202-663-5324 hcarney@aba.com November 12, 2013 By Email Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation 550 17th Street,
More informationMortgage Market Review: Responsible Lending
Telephone: 020 7066 9346 Email: enquiries@fs-cp.org.uk Ms Lynda Blackwell Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS 30 September 2010 Dear Ms Blackwell Mortgage Market
More informationDear Mr. Ward 1 st June TISA Response to FCA DP15/3. I am pleased to set out below TISA s response to this discussion paper.
Tom Ward Strategy and Competition Division Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS Dear Mr. Ward 1 st June 2015 TISA Response to FCA DP15/3 I am pleased to set out
More informationCompetition: Final report on retail banking inquiry frequently asked questions (see also IP/07/114)
MEMO/07/40 Brussels, 31 st January 2007 Competition: Final report on retail banking inquiry frequently asked questions (see also IP/07/114) General What will be the follow-up to the inquiry? Following
More informationINVESTMENT ADVISORY SERVICE
INVESTMENT ADVISORY SERVICE TERMS AND CONDITIONS Tilney Investment Management Services Limited January 2017 PLANNING ADVISING INVESTING 2 Terms of Business This is an important document so please read
More informationRegistered office address
Response Response to consultation on VAT: Cost Sharing Exemption Contact: Team: John Butler Finance Policy Tel: 020 7067 1177 Email: john.butler@housing.org.uk Date: September 2011 Ref: FP.FI.2011.RS.04
More informationICAEW REPRESENTATION 07/18
ICAEW REPRESENTATION 07/18 Occupational Pension Schemes (Master Trusts) Regulations 2018 ICAEW welcomes the opportunity to comment on the Occupational Pension Schemes (Master Trusts) Regulations 2018 published
More informationDiscussion Paper DP 2014/1 Accounting for Dynamic Risk Management: a Portfolio Revaluation Approach to Macro Hedging
Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ United Kingdom Tel:
More informationStudy of the market for new appointments and variations summary of findings and next steps
10 October 2017 Trust in water Study of the market for new appointments and variations summary of findings and next steps www.ofwat.gov.uk Contents 1. Background and purpose of this document 2 2. Summary
More informationWhile this group have made preparations for retirement, they have not thought through their financial position or their spending needs in any
Executive Summary This report, Supporting DC members with defaults and choices up to, into, and through retirement: Qualitative research with those approaching retirement, is the first stage in a two stage
More informationReporting of Transfers of Value to HCPs and HCOs Methodological Note for Reporting of 2017 Data in 2018
Reporting of Transfers of Value to HCPs and HCOs Methodological Note for Reporting of 2017 Data in 2018 AstraZeneca UK Limited Registered in England No 3674842 Registered Office, 2 Kingdom Street, London,
More informationFinancial Conduct Authority Retirement Outcomes Review. Retirement Outcomes Review At a glance
At a glance 2017 1 Section 01 Introduction Financial Conduct Authority 2 Introduction Our review looked at how the retirement income market is evolving since the pension freedoms were introduced in April
More informationI should firstly like to say that I am entirely supportive of the objectives of the CD, namely:
From: Paul Newson Email: paulnewson@aol.com 27 August 2015 Dear Task Force Members This letter constitutes a response to the BCBS Consultative Document on Interest Rate Risk in the Banking Book (the CD)
More informationPension Schemes Bill Delegated Powers
Pension Schemes Bill Delegated Powers Memorandum from DWP to the Delegated Powers and Regulatory Reform Committee November 2014 1 Introduction The Pension Schemes Bill was introduced in the House of Commons
More informationSupporting Responsible Innovation in the Federal Banking System: An OCC Perspective
May 31, 2016 The Honorable Thomas J. Curry Comptroller of the Currency Office of the Comptroller of the Currency 400 7 th Street, SW Washington, DC 20219 Re: Supporting Responsible Innovation in the Federal
More informationNHS Trade Union response to HMT consultation on reforms to public sector exit payments.
NHS Trade Union response to HMT consultation on reforms to public sector exit payments. Introduction & general comments We are unclear from the consultation the extent to which Government wishes to impose
More information