SEPA DIRECT DEBIT B2B RULEBOOK CHANGE REQUEST - CONSULTATION DOCUMENT COVER PAGE

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1 EPC Version May 2014 EPC SEPA DIRECT DEBIT B2B RULEBOOK CHANGE REQUEST - CONSULTATION DOCUMENT COVER PAGE The Single Euro Payments Area (SEPA) payment schemes, as set out in the SEPA Credit Transfer (SCT), the SEPA Direct Debit Core (SDD Core) and the SEPA Direct Debit Business to Business (SDD B2B) Rulebooks, evolve based on a transparent change management process adhered to by the European Payments Council (EPC). For details on the principles governing the EPC scheme change management process, we refer to sections 5, 6 and 7 in this document and the sources listed at the end of this page. This SDD B2B Change Request 2014 consultation document (document EPC099-14) details suggestions for possible modifications to be introduced into the next version of the SDD B2B Scheme Rulebook. This consultation document builds on suggestions for changes submitted by stakeholder representatives, banking communities and by EPC Working and Support Groups. The SDD B2B Change Request 2014 consultation document offers the analyses and recommendations of the EPC SEPA Payment Schemes Working Group (SPS WG) on the way forward with regard to individual suggestions. A summary overview of the suggestions for changes and related recommendations by the SPS WG is provided in section 1 of this Change Request consultation document. The EPC submits the SDD B2B Change Request 2014 consultation document for public consultation. The public consultation takes place between 19 May and 15 August All Scheme participants and stakeholders are encouraged to provide feedback on the possible changes to be introduced into the next version of the SDD B2B Scheme Rulebook by completing the response template EPC and send it to change-request.epcscheme@epc-cep.eu by 15 August h00 CET at the latest. Proposed changes detailed in this SDD B2B Change Request 2014 consultation document, which are broadly accepted by all Scheme participants and stakeholders, are taken forward. The updated version of the SDD B2B Scheme Rulebook will be published in November 2014 for implementation in November In accordance with industry best practice, payment service providers and their suppliers have a one-year lead time to address rulebook updates prior to such updates taking effect. The following general background information is made available for further information: Extract SEPA Scheme Management Internal Rules (Chapter 3: Development and Evolution) It should be noted that the EPC is under the legal obligation to ensure compliance of the Rulebook with existing EU legislations or to any new EU legislation impacting this Rulebook. Therefore, the EPC reserves the right to make necessary changes to the Rulebook at all times in order to ensure that the Rulebook does comply with changes to existing EU legislation or with the entry into force of any new EU legislation. Please refer to Annex 1 for the original detailed suggestions for changes. This document contains only a summary of each individual suggestion. Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

2 TABLE OF CONTENTS 1 Executive Summary: Suggestions for Major Changes to the SEPA Direct Debit B2B Rulebook Detailed Analysis of Suggestions for Major Changes to the SDD B2B Rulebook # 13: Inclusion of new reason 'Unable to obtain debit authorization from Debtor' in attribute AT-R3 'The Reason Code for Non-Acceptance' # 16: Block 4 - IBAN change by debtor - next recurrent SDD collection under an existing mandate to be presented as a First # 17: Making storage location for additional customer-to-customer information available outside the payment transaction # 18: Corrections on the definition of 'refusal by the Debtor' # 22: End-to-End (E2E) identification optional instead of mandatory in C2B and Interbank Implementation Guidelines # 24: Block 2 - Make sequence type FRST optional instead of mandatory # 25: Deletion of all Creditor related reasons from attribute AT-24 ('Reason for amendment of the mandate') # 26: Block 4 - Debtor amends IBAN on mandate - next recurrent SDD collection under an existing mandate to be presented as a First # 27: Extra reasoncodes for white/blacklisting and other Debtor-driven reasons in AT- R3 The Reason Code for Non-Acceptance # 28: This suggestion has been withdrawn by the contributor # 29: Wording change on 'form of mandate' in section 5.7 "Obligations of a Creditor Bank" # 30: Removal references to 'qualified electronic signature' in section 4.1 "The Mandate" and section 7 "Definitions" # 38: Make pre-notification more convenient and optional # 39: The unique mandate reference (AT-01) to become space insensitive # 40: Clarifications for the use of the SDD collection sequence type and of the amendment indicator # 41: Harmonising pain format in the customer-to-bank (C2B) xml interfaces # 42: Block 3 - Adapt section 4.1 (The Mandate) of the SDD B2B Rulebook to the contents EPC clarification letter on electronic mandates (Letter EPC098-13) # 44: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate # 45: Block 2 - Turn the current SDD sequence types into optional data sequence types # 46: Extend SDD B2B collection return period to 3 Interbank Business Days # 48: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate # 50: Block 2 - Simplification of the mandate life cycle and collection sequence type # 51: This suggestion has been withdrawn by the contributor # 52: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate # 54: Mandate methods not restricted to paper mandate & EPC e-mandate # 64: Make fields Creditor Reference Party and Debtor Reference Party" more visible # 65: Simplification of r-transaction codes and harmonization in their use # 66: Add clarification on the use of attribute AT-25 (date of signing the Mandate) # 69: Create a specific reason code to highlight sequence error in SDD # 71: Update of the Rulebook section 5.4 Eligibility for Participation # 72: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate # 74: Extend SDD B2B collection return period to 3 Interbank Business Days # 75: Simplify the use of a shorter timeline for sending a pre-notification # 76: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate.. 44 EPC SDD B2B Rulebook Change Request Consultation Document 2

3 2.35 # 79: Block 4 - IBAN change by Debtor - next recurrent SDD collection under an existing mandate to be presented as a First # 84: Make AT-59 'category purpose of the collection' mandatory instead of optional # 86: Allow a last collection (final) with a zero amount for mandate cancellation purposes # 88: Removal of SDD Mandate illustration in DS-01The Mandate # 89: Extension of mandate amendment combinations in AT-24 The Reason for Amendment of the Mandate # 90: Representation of a first collection after being returned Changes pertaining to the impact of the SEPA Regulation or of any other EU Legislation Detailed Analysis of Minor Changes to the SDD B2B Rulebook Proposed change Principles governing the Change Request Process Change Request Structure of the Change Request Change management process in respect of Major Changes Consideration of Suggestions Change Request Cost-benefit analysis and business case for the Change Request Consultation on the Change Request Feedback from consultation Next steps SPS WG recommendation Further information Change management process in respect of Minor Changes Publication of list of minor changes Comments on the minor changes Submission of the list of minor changes to the EPC Plenary Publication of changes Annex 1 - Original Change Requests EPC SDD B2B Rulebook Change Request Consultation Document 3

4 1 EXECUTIVE SUMMARY: SUGGESTIONS FOR MAJOR CHANGES TO THE SEPA DIRECT DEBIT B2B RULEBOOK The principles governing the evolution of the Single Euro Payments Area (SEPA) payment schemes as set out in the SEPA Credit Transfer (SCT) and SEPA Direct Debit (SDD) Scheme Rulebooks are detailed in the SEPA Scheme Management Internal Rules (the Internal Rules). These Internal Rules are available for download on the European Payments Council (EPC) Website. Sections 5, 6 and 7 in this SDD B2B Change Request 2014 consultation document detail the application of the Internal Rules in the EPC scheme change management process. The Internal Rules differentiate between so called major and minor changes to the scheme rulebooks. A major change is a change that affects or proposes to alter the substance of the rulebooks and the schemes. Any change to chapters 5 and 6 of the rulebooks are always considered a major change. A minor change is a change of an uncontroversial and usually technical nature that facilitates the comprehension and use of the rulebooks. This executive summary of the SDD B2B Change Request 2014 consultation document highlights suggestions for major changes to the SDD B2B Rulebook received in this scheme change management cycle. Suggestions for minor changes to the SDD B2B Rulebook are set out in section 4 of this Change Request consultation document. All suggestions for changes to the SDD B2B Rulebook are submitted for public consultation between 19 May and 15 August Information on how to share feedback with the EPC is included on the cover page of this Change Request consultation document. The EPC received 40 suggestions for major changes to be introduced into the SDD B2B Scheme Rulebook. The suggestions for changes submitted to the EPC are included in Annex 1 to this document. A first block of change requests proposes to simplify the use of sequence types with proposals ranging from the optional use of certain sequence types to abandoning the use of the sequence type First. A second block of proposals wishes to adapt the SDD Rulebook section 4.1 (The Mandate) following the publication of a clarification letter on electronic mandates to SEPA Direct Debit Scheme Participants (Letter EPC098-13) on the EPC public website. A third block of change requests proposes that if the Debtor reports a change of the IBAN to be debited for an existing mandate used for recurrent SDD collections, the next recurrent SDD collection should then be presented as a First. A further suggestion deals with making additional customer-to-customer information available outside of the SDD collection message. Another change contribution proposes to turn the current recommended-only Customer-to-Bank Implementation Guidelines (C2B IGs) into mandatory IGs. Various contributors suggest making changes or providing clarifications on the r-transaction reason codes and other SDD Rulebook attributes. Certain contributors further suggest extending the SDD B2B collection return period to 3 Interbank Business Days. Other suggestions relate to changes in the pre-notification phase. All suggestions for changes to the SDD B2B Rulebook received were reviewed by the EPC SEPA Payment Schemes Working Group (SPS WG). These Change Requests include the recommendations of the SPS WG with regard to each of these suggestions. Each recommendation reflects one of the options detailed in items a) through f) below: a) The suggestion for change is already provided for in the scheme. No action is necessary for the EPC. b) The suggestion for change should be incorporated into the scheme. EPC SDD B2B Rulebook Change Request Consultation Document 4

5 The suggestion for change becomes part of the scheme and the rulebook is amended accordingly. c) The suggestion for change should be included in the scheme as an optional feature. The new feature is optional and the rulebook will be amended accordingly. Each scheme participant 1 may decide to offer the feature to its customers, or not. d) The suggestion for change is not considered fit for SEPA wide use and could be handled as an additional optional service (AOS) by interested communities. The proposed new feature is not included in the rulebook or in the implementation guidelines released by the EPC with regard to the rulebooks. The development of AOS is out of scope of the EPC. The EPC does however publish declared AOS arrangements on its website for information. The EPC may consider the inclusion of AOS arrangements, if supported by a sufficient number of communities, in a future version of the rulebook. e) The suggestion for change cannot be part of the existing scheme. It is technically impossible. It is not feasible (explained on a case by case basis). It is out of scope of the EPC. It does not comply with the SEPA Regulation 2 or any other relevant EU legislation. f) The suggestion for change may be considered for the development of a new scheme. The suggestion reflects major changes which cannot be integrated into an existing scheme To develop the suggestion for change further, i.e. to develop a new scheme, the following requirements should be met: The benefits of the new scheme for bank customers are demonstrated prior to the launch of the development phase. It is demonstrated that a sufficient number of stakeholders will make use of the new scheme. A cost-benefit analysis is provided. It complies with the SEPA Regulation or any other relevant Regulation. Summary of suggestions for changes and proposed way forward for consideration by respondents to this public consultation The below table lists all the received suggestions for change which are submitted for public consultation. The SPS WG has issued a recommendation on the way forward with regard to each suggestion; the reasons underlying each recommendation are detailed in chapter 2. The final decision whether a suggested change will be incorporated into the rulebook is however subject to the outcome of the public consultation. 1 A scheme participant is a payment service provider which has formally adhered to a SEPA Scheme. 2 Regulation (EU) No 260/2012 establishing technical and business requirements for credit transfers and direct debits in euro and amending Regulation (EC) No 924/2009 EPC SDD B2B Rulebook Change Request Consultation Document 5

6 The contributors to this public consultation are requested to indicate whether they agree with the recommendation of the SPS WG on the way forward. In case the contributors do not agree with the SPS WG recommendation, they are requested to indicate in the comments section their preferred way forward (e. g. support of the original change request/ selecting another option as defined on page 4 and 5). Furthermore any additional comments are welcome in the comments section.. Change Request item Topic Contributor Recommendation of the SPS WG on the proposed way forward. The final decision is subject to the outcome of the public consultation. 13 Inclusion of new reason 'Unable to obtain debit authorization from Debtor' in attribute AT-R3 'The Reason Code for Non-Acceptance' Spanish banking community Should be incorporated into the scheme - option b 16 Block 4 - IBAN change by debtor - next recurrent SDD collection under an existing mandate to be presented as a First 17 Making storage location for additional customer-tocustomer information available outside the payment transaction 18 Corrections on the definition of 'refusal by the Debtor' 22 End-to-End (E2E) identification optional instead of mandatory in C2B and Interbank Implementation Guidelines 24 Block 2 - Make sequence type FRST optional instead of mandatory 25 Deletion of all Creditor related reasons from attribute AT-24 ('Reason for amendment of the mandate') SPS WG SPS WG SPS WG Betaalvereniging Nederland Betaalvereniging Nederland Betaalvereniging Nederland Should be incorporated into the scheme - option b Should be included in the scheme as an optional feature - option c Should be incorporated into the scheme - option b Cannot be part of the existing scheme option e Should be incorporated into the scheme as of Nov option b Cannot be part of the existing scheme option e EPC SDD B2B Rulebook Change Request Consultation Document 6

7 Change Request item Topic Contributor Recommendation of the SPS WG on the proposed way forward. The final decision is subject to the outcome of the public consultation. 26 Block 4 - Debtor amends IBAN on mandate - next recurrent SDD collection under an existing mandate to be presented as a First 27 Extra reasoncodes for white/blacklisting and other debtor-driven reasons in AT- R3 The Reason Code for Non-Acceptance 28 This suggestion has been withdrawn by the contributor 29 Wording change on 'form of mandate' in section 5.7 "Obligations of a Creditor Bank" 30 Block 3 - Removal references to 'qualified electronic signature' in section 4.1 "The Mandate" and section 7 "Definitions" 38 Make pre-notification more convenient and optional 39 The unique mandate reference (AT-01) to become space insensitive (suggestion applies only on the Implementation Guidelines) 40 Clarifications/guidance for the use of the SDD collection sequence type and the amendment indicator 41 Harmonising pain format in the customer-to-bank (C2B) xml interfaces Betaalvereniging Nederland Betaalvereniging Nederland SPS WG SPS WG BITKOM BITKOM BITKOM BITKOM Should be incorporated into the scheme - option b Already provided for in the scheme option a Should be incorporated into the scheme - option b The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b Cannot be part of the existing scheme option e Cannot be part of the existing scheme option e Cannot be part of the existing scheme option e No SPS WG recommendation defined EPC SDD B2B Rulebook Change Request Consultation Document 7

8 Change Request item Topic Contributor Recommendation of the SPS WG on the proposed way forward. The final decision is subject to the outcome of the public consultation. 42 Block 3 - Adapt section 4.1 (The Mandate) of the SDD B2B Rulebook to the contents EPC clarification letter on electronic mandates (Letter EPC098-13) 44 Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate 45 Block 2 - Turn the current SDD sequence types into optional data sequence types 46 Extend SDD B2B collection return period to 3 Interbank Business Days 48 Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate 50 Block 2 - Simplification of the mandate life cycle and collection sequence type 51 This suggestion has been withdrawn by the contributor 52 Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate BITKOM Médecins Sans Frontières Germany Spanish Banking community Spanish banking community Fundraising Verband Austria Febelfin Médecins Sans Frontières Austria The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b Should be incorporated into the scheme - option b for the sequence type First only as of Nov 2016 No SPS WG recommendation defined The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b Should be incorporated into the scheme as of Nov option b The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b EPC SDD B2B Rulebook Change Request Consultation Document 8

9 Change Request item Topic Contributor Recommendation of the SPS WG on the proposed way forward. The final decision is subject to the outcome of the public consultation. 54 Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate 64 Make fields Creditor Reference Party" and Debtor Reference Party" more visible 65 Simplification of r-transaction codes and harmonization in their use 66 Add clarification on the use of attribute AT-25 (date of signing the Mandate) 69 Create a specific reason code to highlight sequence error in SDD 71 Update of the Rulebook section 5.4 Eligibility for Participation 72 Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate 74 Extend SDD B2B collection return period to 3 Interbank Business Days 75 Simplify the use of a shorter timeline for sending a prenotification European Fundraising Association Association Française des Trésoriers d Entreprises Association Française des Trésoriers d Entreprises Laya Healthcare Payment Advisory Group LSG WWF Deutschland German Banking Industry Committee German Banking Industry Committee The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b Already provided for in the scheme option a Cannot be part of the existing scheme option e Should be incorporated into the scheme - option b Already provided for in the scheme option a Should be incorporated into the scheme - option b The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b No SPS WG recommendation defined Cannot be part of the existing scheme option e EPC SDD B2B Rulebook Change Request Consultation Document 9

10 Change Request item Topic Contributor Recommendation of the SPS WG on the proposed way forward. The final decision is subject to the outcome of the public consultation. 76 Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate 79 Block 4 - IBAN change by Debtor - next recurrent SDD collection under an existing mandate to be presented as a First 84 Make AT-59 'category purpose of the collection' mandatory instead of optional 86 Allow a last collection (final) with a zero amount for mandate cancellation purposes 88 Removal of SDD Mandate illustration in DS-01 The Mandate 89 Extension of mandate amendment combinations in AT-24 The Reason for Amendment of the Mandate 90 Representation of a first collection after being returned Coalition for Electronic SDD Mandates (Germany) Worldline Portuguese banking community Portuguese banking community SPS WG SPS WG SPS WG The contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the scheme - option b Should be incorporated into the scheme - option b Cannot be part of the existing scheme option e Cannot be part of the existing scheme option e Should be incorporated into the Scheme (option b). Should be incorporated into the Scheme (option b). Should be incorporated into the Scheme (option b). Summary of changes which will be included in the next version of the SDD B2B Rulebook to align the rulebook with the SEPA Regulation or with any other relevant EU legislation (e.g., PSD) The contributors to this public consultation are welcome to comment on these changes. Ref. Topic Contributor Way forward No items were identified that required a change to the rulebook due to any particular EU legislation EPC SDD B2B Rulebook Change Request Consultation Document 10

11 2 DETAILED ANALYSIS OF SUGGESTIONS FOR MAJOR CHANGES TO THE SDD B2B RULEBOOK 2.1 # 13: Inclusion of new reason 'Unable to obtain debit authorization from Debtor' in attribute AT-R3 'The Reason Code for Non-Acceptance' Description This suggestion was made by the Spanish banking community. It is proposed to include the following new reject/return reason in the attribute AT-R3 The Reason Code for Non-Acceptance (Reject or Return): Unable to obtain debit authorization from Debtor. For SDD B2B, the Debtor must provide an authorization in order that the SDD B2B collection can eventually be executed. Sometimes, the Debtor Bank is not able to locate the Debtor in the short period of time determined in the SDD Rulebook and the collection is rejected or returned. Currently, there appears to be no specific reject/return reason indicating that the Debtor Bank was unable to obtain debit authorization from the Debtor. This new code would clarify the reason for reject/ return and avoid the use of other codes that may not correspond SPS WG analysis and recommendation The SPS WG recommends that the suggestion for change should be incorporated into the scheme (option b). The SPS WG proposes to extend the explanation of reason code MD01 to No Mandate or unable to obtain debit authorization from Debtor" Rulebook impact If this suggestion for change is supported, this will impact the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 11

12 2.2 # 16: Block 4 - IBAN change by debtor - next recurrent SDD collection under an existing mandate to be presented as a First Description This suggestion was made by the SPS WG. It is suggested applying a unique rule: in case the Debtor informs the Creditor of a change of account number (whether held in the same Debtor Bank or in another Debtor Bank), the next collection under an existing mandate should be presented as a first SDD collection to this new IBAN. Currently, an issue does arise in relation to a debtor who changes its IBAN at the same PSP or wishes to use a new IBAN at another PSP. The current SDD rulebooks do not cater sufficient guidance for the creditor to determine all possible cases (e.g., debtor prefers now another payment account to be used at the same debtor bank or held at another debtor bank, change of IBAN within the same debtor bank as the debtor relocates to another region in the same country, a merger of current debtor bank with another debtor bank occurred). Furthermore, the situation will become more complicated due to the SEPA End-Date Regulation, which makes the BIC optional at national level in 2014 and at cross-border level in SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b). Other contributors have provided a similar change request with the indication Block 4 (i.e. the items # 26 and 79). If this change suggestion is supported, the following business rule will be added in the description under process step PT in section 4.6.2: in case the Debtor informs the Creditor of a change of IBAN (whether held in the same Debtor Bank or in another Debtor Bank), the next collection under an existing mandate should be presented as a first SDD collection to this new IBAN Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 12

13 2.3 # 17: Making storage location for additional customer-to-customer information available outside the payment transaction Description This suggestion was made by the SPS WG. The current SDD B2B Scheme permits the end-to-end carrying of remittance data on a structured or unstructured basis. The scheme rules allow for one repetition of the remittance information field of up to 140 characters to be included with the remittance information. Earlier change requests from different stakeholder groups and banking communities asked for a possibility to use significantly larger remittance information. The present 140 characters of remittance information appear to be not enough for some users or communities in the SEPA area. It is proposed to make additional customer-to-customer information available outside of the SDD B2B collection message. The payment message would only carry the information of the location where the additional customer-to-customer information is stored. The additional data separated from the 140 characters of the remittance information can then be sent separately from the SDD B2B collection message. Additional data elements/ attributes that already exist in ISO (e.g., ISO Extended Remittance Advice message) can be taken up in the SDD B2B Rulebook. These new attributes will store details of the location from where the additional customer-to-customer information can be retrieved. It is emphasized that the current limited character set to be used in the SDD B2B Scheme will remain unchanged. Furthermore, the additional attributes storing the location of the additional customer-tocustomer information will be optional fields. This means that only when the Creditor provides information about the storage location of the additional customer-to-customer information in these optional fields, it is mandatory for the Creditor Bank to transport this storage location information in these fields to the Debtor Bank. In case of an arrangement between the Debtor Bank and the Debtor, the information about the storage location could be made available. These details are sent together with the SDD message but are not part of the SDD collection SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the scheme as an optional feature (option c) and more specifically through the use of optional fields Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 13

14 2.4 # 18: Corrections on the definition of 'refusal by the Debtor' Description This suggestion was made by the SPS WG. It is proposed to update the SDD Rulebook in a way that a refusal is always based on a request of the Debtor before due date/ settlement date not to pay a collection. The technical r-transaction could be either a reject (which is the preference) or if technically not feasible before settlement a return. Only refusals returned by a reject or by a return would use the proper reason code refusal by the Debtor. With the proposed way forward no change in today s practice by PSPs is required. Furthermore, rewording proposals in the description of attribute AT-R3 The Reason Code for Non- Acceptance are made. Currently, different interpretations of the term refusal (i.e. it is the debtor who initiates the refusal) and the technical aspects of treating such refusal (as a reject before settlement or as return/refund after settlement) had been reported. The main issue is whether such refusal can be processed either as reject, return or refund SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b) Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 14

15 2.5 # 22: End-to-End (E2E) identification optional instead of mandatory in C2B and Interbank Implementation Guidelines Description This suggestion was made by the Betaalvereniging Nederland. The End-to-End (E2E) identification is mandatory in the Customer-to-Bank (C2B) Implementation Guidelines (IGs). If this E2E identification is not given, the Interbank IGs of the Rulebook prescribe to provide Not Provided in the E2E identification field. The suggestion considers that the attribute AT-10 The Creditor s Reference of the Direct Debit Transaction contains a wrong description in respect to the use of the default value Not Provided. As the C2B IGs indicate that the E2E identification is mandatory, it would not be the case that the Creditor Bank must fill this field with Not Provided when left blank by the Creditor as the Creditor is obliged to provide a value. It is suggested to delete in AT-10 the provision of the default value Not Provided if the Creditor provides no reference and to make the E2E identification optional in the C2B and Interbank IGs SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). The E2E identification field is currently mandatory in ISO Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 15

16 2.6 # 24: Block 2 - Make sequence type FRST optional instead of mandatory Description This suggestion was made by the Betaalvereniging Nederland. The contributor proposes to make the sequence type FRST optional instead of mandatory. The reason is that the registration of the mandate information at the Debtor Bank is a requirement before any B2B-transaction can be processed. A distinction between a FRST and a RCUR transaction would have no additional value as they are both initiated on D-1 at the latest SPS WG analysis and recommendation The SPS WG recommends that the suggestion should be incorporated into the Scheme (option b) with effective date in November The SPS WG draws the attention to other change requests (see change requests with indication Block 2 i.e. the items 45 and 50) suggesting either a simplification of the current range of sequence types, making certain sequence types optional or the elimination of a particular sequence type. With regard to this specific block of change requests, the SPS WG recommends that the sequence type First is no longer mandatory in the SDD Core and SDD B2B Rulebooks with an effective date in November This should allow all Scheme participants and end-users of the two SDD Schemes sufficient time to prepare themselves for such change in November 2016 subject to support during this public consultation. The respondent should indicate 1. If the respondent agrees that the sequence type First should no longer be mandatory (Yes/No). 2. If answered with Yes, does the respondent support the effective date of November 2016 (Yes/No)? 3. If answered with No on question 2, the respondent should indicate an alternative date (e.g., November 2015, November 2017 or later) Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 16

17 2.7 # 25: Deletion of all Creditor related reasons from attribute AT-24 ('Reason for amendment of the mandate') Description This suggestion was made by Betaalvereniging Nederland. It is suggested to delete all Creditor related reasons from AT ('Reason for amendment of the mandate'). This would then lead to the usage rule that the Creditor issues a new mandate if the Creditor wants to change his name, Creditor identifier and/or unique mandate reference. The statement is made that the existing amendment procedure of the mandate is experienced as complex and leads to many questions and errors SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). As a new mandate requires a new signature of the Debtor it is recommended leaving the decision to the Creditor to ask the Debtor to sign for a new mandate or to amend the mandate-related data combined with an upfront communication to the Debtor. The SEPA Regulation (Annex Technical Requirements) does already cover Creditor-related changes in the mandate Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 17

18 2.8 # 26: Block 4 - Debtor amends IBAN on mandate - next recurrent SDD collection under an existing mandate to be presented as a First Description This suggestion was made by Betaalvereniging Nederland. The contributor suggests that if the Debtor amends the IBAN on the mandate, the Creditor should always present the next recurrent collection with sequence type FRST respecting the time-cycle of a first direct debit collection. The same mandate reference can be used. Currently, Creditors are not able to determine with certainty if the new IBAN is held with the same or with another Debtor Bank SPS WG analysis and recommendation The SPS WG recommends that the suggestion should be incorporated into the Scheme (option b). Other contributors have provided a similar change request with the indication Block 4 (i.e. the items # 16 and 79). If this change suggestion is supported, the following business rule will be added in the description under process step PT in section 4.6.2: in case the Debtor informs the Creditor of a change of IBAN (whether held in the same Debtor Bank or in another Debtor Bank), the next collection under an existing mandate should be presented as a First SDD collection to this new IBAN Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 18

19 2.9 # 27: Extra reasoncodes for white/blacklisting and other Debtor-driven reasons in AT- R3 The Reason Code for Non-Acceptance Description This suggestion was made by Betaalvereniging Nederland. It is suggested to add new reasoncodes to specify the different reasons as stipulated in article 5 (3.) (d) of the SEPA Regulation (Regulation 260/2012 of March 14th 2012). It is stated that using these new reason codes will give Creditors more useful information about white/blacklist settings and/or other specific SDD services provided by the Debtor Bank SPS WG analysis and recommendation The SPS WG considers that the change suggestion is already provided for in the Scheme (option a). The SPS WG recommends instead of extending the list of reason codes in AT-R3 to use the existing reason code SL01 ( Specific Service offered by the Debtor Bank ) for this group of reasons. This should help to limit the complexity of managing and applying reason codes. Note: The SEPA Regulation does not apply to B2B collections in this context Rulebook impact The SPS WG considers there is no impact as the suggestion is already covered by the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 19

20 2.10 # 28: This suggestion has been withdrawn by the contributor Description This suggestion has been withdrawn by the contributor. EPC SDD B2B Rulebook Change Request Consultation Document 20

21 2.11 # 29: Wording change on 'form of mandate' in section 5.7 "Obligations of a Creditor Bank" Description This suggestion was made by the SPS WG. Section 5.7 Obligations of a Creditor Bank of the SDD Rulebook contains the following wording: A Creditor Bank shall oblige each of its Creditors, in accordance with the relevant requirements set out in the Rulebook: ( ) to use a form (underscore added) of Mandate which complies with the Rulebook The notion form here might be misinterpreted as a specific concrete format or template. Instead, it should be understood that the chosen mandate has to fulfil a set of requirements. Therefore a rewording is proposed SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b) Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 21

22 2.12 # 30: Removal references to 'qualified electronic signature' in section 4.1 "The Mandate" and section 7 "Definitions" Description This suggestion was made by the SPS WG. In October 2013, the EPC published a clarification letter on electronic mandates to SEPA Direct Debit Scheme Participants (Letter EPC098-13) on the EPC public website. The clarification letter highlights that the signature methods as described in section 4.1 of the SDD Rulebooks are not exhaustive. SDD scheme participants may consider allowing continued usage of other legally binding methods of signature including those that were used under the local legacy scheme rules. With the publication of this letter, the current specification that only a qualified electronic signature can be used to sign an electronic mandate should be removed in the SDD Rulebook. Deletions are suggested in the section 4.1 and section SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b). The SPS WG draws the attention to other change requests (see change requests with indication Block 3 i.e. the items 42, 44, 48, 52, 54, 72 and 76) suggesting also changes to the SDD Rulebook section Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 22

23 2.13 # 38: Make pre-notification more convenient and optional Description This suggestion was made by BITKOM e.v.. It is proposed to simplify the pre-notification process and to allow the pre-notification to become optional if agreed between the Creditor and the Debtor SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). Pre-notification is very important for the Debtor to be informed about and to react to an upcoming collection. It is a consumer protection measure. Furthermore, the SDD Rulebook does not prescribe how the pre-notification should be done as various pre-notification means do already exist or can be further developed Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 23

24 2.14 # 39: The unique mandate reference (AT-01) to become space insensitive Description This suggestion was made by BITKOM e.v. It is suggested to make the unique mandate reference (AT-01) space insensitive whereby blank spaces in AT-01 would not be considered as a character SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). Blank spaces are permitted in the unique mandate reference (UMR) and are considered as meaningful characters. Therefore not taking the blanks into account would mean creating a different UMR than the original one. Furthermore the current practice is in conformity with ISO: ISO20022 uses the character set UTF-8 and a blank space forms a character in UTF Rulebook impact If this suggestion for change is supported, this will impact only the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 24

25 2.15 # 40: Clarifications for the use of the SDD collection sequence type and of the amendment indicator Description This suggestion was made by BITKOM e.v. The contributor proposes to include an annex clarifying the use of the sequence type and of the amendment indicator SPS WG analysis and recommendation The SPS WG recommends that the suggestion should not be incorporated into the Scheme (option e). The SPS WG considers that the EPC SCT-SDD clarification paper (EPC348-12) already provides guidance on sequence types. The SPS WG will review this clarification paper based on the comments described in this change suggestion Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 25

26 2.16 # 41: Harmonising pain format in the customer-to-bank (C2B) xml interfaces Description This suggestion was made by BITKOM e.v.. The ISO Standard forms the basis for the EPC SEPA xml format and the EPC SDD B2B Implementation Guidelines provide a general template of possible data fields. A variety of national configurations of the payment initiation files (pain.x) had been created. These national variations need to be implemented in the customer-to-bank space. The change suggestion is to narrow the EPC SEPA xml format down to those fields that covers the majority of payments in Europe and to change the current recommended-only customer-to-bank Implementation Guidelines (C2B IGs) into mandatory IGs SPS WG analysis and recommendation With regard to the change request proposal it seems too challenging to harmonise all existing national variations of the C2B implementation Guidelines for the next Rulebook version. Therefore it could be considered that Scheme participants should accept the C2B messages based on the EPC data set described in its C2B IGs as a minimum requirement. The Scheme participants still have the possibility to further enrich these C2B messages. The SPS WG does not propose a concrete recommendation for this change request for the public consultation Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 26

27 2.17 # 42: Block 3 - Adapt section 4.1 (The Mandate) of the SDD B2B Rulebook to the contents EPC clarification letter on electronic mandates (Letter EPC098-13) Description This suggestion was made by BITKOM e.v.. The contributor suggests that section 4.1 (The Mandate) of the SDD B2B Rulebook is adapted to the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 44, 48, 52, 54, 72 and 76), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 27

28 2.18 # 44: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate Description This suggestion was made by Médecins Sans Frontières Germany. The contributor suggests that section 4.1 (The Mandate) of the SDD Rulebook is adapted by clarifying that mandating methods are not restricted to physically signed paper documents and the e-mandate in Annex VII. Such amendment should also be reflected in section of the SDD Rulebook SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). The SPS WG emphasizes that the SDD Scheme Rulebook is neutral about mandating methods as they are subject to the applicable law. As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 42, 48, 52, 54, 72 and 76), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature. As for the amendment suggestion in section 4.7.2, this section describes the mandate content itself, irrespective if it is a paper-based or an electronic mandate Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 28

29 2.19 # 45: Block 2 - Turn the current SDD sequence types into optional data sequence types Description This suggestion was made by the Spanish banking community. The contributor proposes to make the sequence type of direct debits as an optional element in the next version of the Rulebook. It is stated that this change will make operations easier, improve interoperability and decrease the number of returns. The contributor considers this proposal absolutely necessary for the SDD Core D-1 scheme SPS WG analysis and recommendation The SPS WG recommends taking forward the suggestion for change (option b) for the sequence type First only. The SPS WG considers that making all other sequence types optional could cause SDD collection processing issues for the Debtor Bank. The SPS WG draws the attention to other change requests (see change requests with indication Block 2 i.e. the items 24 and 50) suggesting either a simplification of the current range of sequence types, making certain sequence types optional or the elimination of a particular sequence type. With regard to this specific block of change requests, the SPS WG that the sequence type First is no longer mandatory in the SDD Core and SDD B2B Rulebooks with an effective date in November This should allow all Scheme participants and end-users of the two SDD Schemes sufficient time to prepare themselves for such change in November 2016 subject to support during this public consultation. The respondent should indicate 1. If the respondent agrees that the sequence type First should no longer be mandatory (Yes/No). 2. If answered with Yes, does the respondent support the effective date of November 2016 (Yes/No)? 3. If answered with No on question 2, the respondent should indicate an alternative date (e.g., November 2015, November 2017 or later) Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 29

30 2.20 # 46: Extend SDD B2B collection return period to 3 Interbank Business Days Description This suggestion was made by the Spanish banking community. The contributor proposes extending the current SDD B2B collection return period from 2 to 3 Interbank Business Days for the acceptance and management of the SDD B2B collection by the Debtor and the scheme participants. It is stated that with the extension of the return time, SDD B2B scheme participants and Debtors would get enough time to manage and to give authorizations for SDD B2B collections which would mean a decrease in SDD B2B returns SPS WG analysis and recommendation The SPS WG does not propose a concrete recommendation for this change request for the public consultation Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 30

31 2.21 # 48: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate Description This suggestion was made by the Fundraising Verband Austria. The contributor suggests that section 4.1 (The Mandate) of the SDD Rulebook is adapted by clarifying that mandating methods are not restricted to physically signed paper documents and the e-mandate in Annex VII. Such amendment should also be reflected in section of the SDD Rulebook SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). The SPS WG emphasizes that the SDD Scheme Rulebook is neutral about mandating methods as they are subject to the applicable law. As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 42, 44, 52, 54, 72 and 76), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature. As for the amendment suggestion in section 4.7.2, this section describes the mandate content itself, irrespective if it is a paper-based or an electronic mandate Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 31

32 2.22 # 50: Block 2 - Simplification of the mandate life cycle and collection sequence type Description This suggestion was made by Febelfin. The contributor suggests that the simplification of the mandate life cycle will help to reduce the number of r-messages and could contribute to the reputation of SDD. It proposes that the use of First as identification as sequence type becomes optional. The presentation of a collection under a new mandate could also start with Recurrent. The contributor indicates that the same timelines should be maintained for a collection based on a new or existing mandate. The sequence types Final (EPC note: the sequence type is called Last in the SDD Scheme Rulebooks) and One Off would remain unchanged SPS WG analysis and recommendation The SPS WG recommends that the suggestion should be incorporated into the Scheme (option b) with effective date in November The SPS WG draws the attention to other change requests (see change requests with indication Block 2 i.e. the items 24 and 45) suggesting either a simplification of the current range of sequence types, making certain sequence types optional or the elimination of a particular sequence type. With regard to this specific block of change requests, the SPS WG that the sequence type First is no longer mandatory in the SDD Core and SDD B2B Rulebooks with an effective date in November This should allow all Scheme participants and end-users of the two SDD Schemes sufficient time to prepare themselves for such change in November 2016 subject to support during this public consultation. The respondent should indicate 1. If the respondent agrees that the sequence type First should no longer be mandatory (Yes/No) 2. If answered with Yes, does the respondent support the effective date of November 2016 (Yes/No)? 3. If answered with No on question 2, the respondent should indicate an alternative date (e.g., November 2015, November 2017 or later) Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 32

33 2.23 # 51: This suggestion has been withdrawn by the contributor Description This suggestion has been withdrawn by the contributor. EPC SDD B2B Rulebook Change Request Consultation Document 33

34 2.24 # 52: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate Description This suggestion was made by Médecins Sans Frontières Austria. The contributor suggests that section 4.1 (The Mandate) of the SDD Rulebook is adapted by clarifying that mandating methods are not restricted to physically signed paper documents and the e-mandate in Annex VII. Such amendment should also be reflected in section of the SDD Rulebook SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). The SPS WG emphasizes that the SDD Scheme Rulebook is neutral about mandating methods as they are subject to the applicable law. As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 42, 44, 48, 54, 72 and 76), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature. As for the amendment suggestion in section 4.7.2, this section describes the mandate content itself, irrespective if it is a paper-based or an electronic mandate Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 34

35 2.25 # 54: Mandate methods not restricted to paper mandate & EPC e-mandate Description This suggestion was made by European Fundraising Association. The contributor suggests that section 4.1 (The Mandate) of the SDD Rulebook is adapted by clarifying that mandating methods are not restricted to physically signed paper documents and the e-mandate in Annex VII. Such amendment should also be reflected in section of the SDD Rulebook SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). The SPS WG emphasizes that the SDD Scheme Rulebook is neutral about mandating methods as they are subject to the applicable law. As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 42, 44, 48, 52, 72 and 76), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature. As for the amendment suggestion in section 4.7.2, this section describes the mandate content itself, irrespective if it is a paper-based or an electronic mandate Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 35

36 2.26 # 64: Make fields Creditor Reference Party and Debtor Reference Party" more visible Description This suggestion was made by the Association Française des Trésoriers d Entreprises. It is expected that companies will implement centralized payment and collection factories. With such a centralized company issuing SDD B2B on behalf of its subsidiaries; this will mean that the transaction will be initiated from an account of the centralized company but the ultimate Creditor (EPC note: The rulebook term is Creditor Reference Party ) or ultimate Debtor (EPC note: Debtor Reference Party ) will be its subsidiaries. In such a case, the Debtor will not be able to identify the ultimate Creditor because its identity is posted in the ultimate Creditor field which is not posted in a visible manner (or vice versa). Only the identity of the account holder, in that case the centralizing company, is posted in a clear manner. It is suggested to make the field Ultimate Creditor and Ultimate Debtor" more visible for the counterparty SPS WG analysis and recommendation The SPS WG considers that the change suggestion is already provided for in the Scheme (option a). The dataset DS-01 (Mandate) and DS-02 (Dematerialised Mandate) allow the possibility to specify the Reference Party details of the Creditor and/ of the Debtor. Reference is made to the attributes AT-15, 37, 38 and 39. When these attributes are present in DS-01 and DS-02, they can then be provided with the collection DS-03 and DS-04 to the Debtor Bank Rulebook impact The SPS WG considers there is no impact as the suggestion is already covered both by the Rulebook and the Implementation Guidelines (IGs) EPC SDD B2B Rulebook Change Request Consultation Document 36

37 2.27 # 65: Simplification of r-transaction codes and harmonization in their use Description This suggestion was made by the Association Française des Trésoriers d Entreprises. The contributor suggests a simplification and reduction of r-transaction codes, by defining clear rules for the use of each code as this would help harmonization. The contributor notes a high number of r-transaction codes and considers some of them redundant. It also reports a heterogeneous use of these codes by the scheme participants SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). The change request does neither specify which concrete reason codes should disappear nor suggest codes simplifications. After the SEPA migration completion end July 2014, the EPC will investigate what reason codes are actually used and if they are used appropriately. Based on this analysis, the EPC will then be able to review if the current set of reason codes still fits the needs Rulebook impact Not applicable. EPC SDD B2B Rulebook Change Request Consultation Document 37

38 2.28 # 66: Add clarification on the use of attribute AT-25 (date of signing the Mandate) Description SPS WG note: the contributor proposed this change suggestion only for the SDD Core Rulebook. However, this change suggestion is also relevant for the SDD B2B Rulebook. Therefore the SPS WG has taken over this change suggestion in the set of change requests for the SDD B2B Rulebook. This suggestion was made by Laya Healthcare. It is suggested to clarify in the SDD Rulebook whether or not the date provided in AT-25 (date of signing the Mandate) should remain the original date of signing the mandate SPS WG analysis and recommendation The SPS WG recommends that the suggestion for change should be incorporated into the scheme (option b). The SPS WG recommendation is to reword AT-25 by specifying that the date refers to the date on which the initial mandate had been signed and that the value of this attribute remains unchanged for the mandate lifecycle Rulebook impact If this suggestion for change is supported, this will impact the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 38

39 2.29 # 69: Create a specific reason code to highlight sequence error in SDD Description This suggestion was made by Payments Advisory Group. It is suggested that one specific reason in the scheme and messages is created for a sequence error in direct debit transactions, which will be mandatory for the Debtor Bank to use in case they reject a transaction for this reason. It appears that it cannot always be correctly communicated to the Creditor whether a SDD collection had been subject to a pre-settlement reject or a post-settlement return. Current practice seems to indicate that Debtor Banks do not react with the same reason codes to these situations and that there is no guaranteed unique way of identifying these kinds of errors SPS WG analysis and recommendation The SPS WG considers that the change suggestion is already provided for in the Scheme (option a). The SPS WG refers to reason code AG02 in the bank-to-bank Implementation Guidelines (IGs) and to attribute AT-R3 in the SDD Scheme Rulebook which cover this reason scenario Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 39

40 2.30 # 71: Update of the Rulebook section 5.4 Eligibility for Participation Description This suggestion was made by the EPC Legal Support Group (LSG). The suggestion covers an update in the category descriptions of Scheme applicants which are deemed automatically to be eligible under Rulebook section 5.4 on eligibility for participation. Among other changes, this suggestion includes banks authorised by the Central Bank of San Marino SPS WG analysis and recommendation The SPS WG recommends that the suggestion should be incorporated into the Scheme (option b) Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 40

41 2.31 # 72: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate Description This suggestion was made by WWF Deutschland. The contributor suggests that section 4.1 (The Mandate) of the SDD Rulebook is adapted by clarifying that mandating methods are not restricted to physically signed paper documents and the e-mandate in Annex VII. Such amendment should also be reflected in section of the SDD Rulebook SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). The SPS WG emphasizes that the SDD Scheme Rulebook is neutral about mandating methods as they are subject to the applicable law. As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 42, 44, 48, 52, 54 and 76), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature. As for the amendment suggestion in section 4.7.2, this section describes the mandate content itself, irrespective if it is a paper-based or an electronic mandate Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 41

42 2.32 # 74: Extend SDD B2B collection return period to 3 Interbank Business Days Description This suggestion was made by the German Banking Industry Committee. The contributor proposes extending the current SDD B2B collection return period from 2 to 3 Interbank Business Days for the acceptance and management of the SDD B2B collection by the Debtor and the scheme participants. It is stated that a longer return period of 3 Interbank Business Days enables the Debtor Bank to agree with the Debtor on necessary funding arrangements or to obtain a missing Debtor confirmation on the mandate-related information (MRI). This would avoid a return of the collection especially if the Due Date or one of the two subsequent Interbank Business Days of a SDD B2B collection is a national or regional banking or public holiday SPS WG analysis and recommendation The SPS WG does not propose a concrete recommendation for this change request for the public consultation Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 42

43 2.33 # 75: Simplify the use of a shorter timeline for sending a pre-notification Description This suggestion was made by the German Banking Industry Committee. It is proposed to rephrase the requirement of a pre-notification in the SDD Rulebook. It would be considered as sufficient when the Creditor Bank obliges the Creditor to pre-notify the Debtor before the due date of a collection according to the stipulations in the SDD Rulebook section 5.7 Obligations of a Creditor Bank. Any timeline for a pre-notification should be considered and no formal agreement of such a timeline should be a Scheme requirement between the Creditor and the Debtor. Rewording in this sense is proposed in section and process step PT SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). Pre-notification is very important for the Debtor to be informed about and to react to an upcoming collection. It is a consumer protection measure. Therefore an agreement between the Creditor and the Debtor is required in case a shorter pre-notification is desired. The SDD Rulebook does not prescribe how the pre-notification should be agreed upon and how the notification itself should be done as various pre-notification means do exist or can be further developed Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 43

44 2.34 # 76: Block 3 - Mandate methods not restricted to paper mandate & EPC e-mandate Description This suggestion was made by Coalition for Electronic SDD Mandates (Germany). The contributor suggests that section 4.1 (The Mandate) of the SDD Rulebook is adapted by clarifying that mandating methods are not restricted to physically signed paper documents and the e-mandate in Annex VII. Such amendment should also be reflected in section of the SDD Rulebook SPS WG analysis and recommendation The SPS WG recommends that the contents of the EPC clarification letter on electronic mandates (Letter EPC098-13) should be incorporated into the Scheme (option b). The SPS WG emphasizes that the SDD Scheme Rulebook is neutral about mandating methods as they are subject to the applicable law. As other contributors have provided alternative rewording suggestions to this particular section (reference is made to the change requests 42, 44, 48, 52, 54 and 72), the SPS WG proposes a change for SDD Scheme Rulebook section 4.1 based on change request #30 whereby the reference to 'qualified electronic signature' is taken out and replaced by the reference to a legally binding method of signature. As for the amendment suggestion in section 4.7.2, this section describes the mandate content itself, irrespective if it is a paper-based or an electronic mandate Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 44

45 2.35 # 79: Block 4 - IBAN change by Debtor - next recurrent SDD collection under an existing mandate to be presented as a First Description SPS WG note: the contributor proposed this change suggestion only for the SDD Core Rulebook. However, this change suggestion is also relevant for the SDD B2B Rulebook. Therefore the SPS WG has taken over this change suggestion in the set of change requests for the SDD B2B Rulebook. This suggestion was made by Wordline. The suggestion is when the Debtor reports an IBAN change for an existing mandate whereby this mandate is used for recurrent SDD collections, the next recurrent SDD collection should be presented as a FRST (and not as RCUR) SPS WG analysis and recommendation The SPS WG recommends that the suggestion should be incorporated into the Scheme (option b). Other contributors have provided a similar change request with the indication Block 4 (i.e. the items # 16 and 26). If this change suggestion is supported, the following business rule will be added in the description under process step PT in section 4.6.2: in case the Debtor informs the Creditor of a change of IBAN (whether held in the same Debtor Bank or in another Debtor Bank), the next collection under an existing mandate should be presented as a first SDD collection to this new IBAN Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 45

46 2.36 # 84: Make AT-59 'category purpose of the collection' mandatory instead of optional Description This suggestion was made by the Portuguese banking community. The proposal is to make the category purpose of the collection mandatory as it appears to help the Debtor Bank and the Creditor Bank to identify correctly the purpose of the SDD collection. It would improve collection market practices SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). Depending on the agreement between the Creditor and the Creditor Bank, the category purpose can be forwarded to the Debtor Bank and the Debtor. Reference is made to the rules applied in DS-04. Therefore the SPS WG recommends that this attribute remains optional Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 46

47 2.37 # 86: Allow a last collection (final) with a zero amount for mandate cancellation purposes Description This suggestion was made by the Portuguese banking community. The proposal is to allow a last collection with a zero amount with the purpose to cancel a mandate that has generated a series of recurrent collections. It allows the Creditor to inform the Debtor, the Creditor Bank and the Debtor Bank about a mandate cancellation. In case of a mandate cancellation without any amount due for the Creditor to receive or for the Debtor to pay, currently the Creditor has no means of communicating this cancellation to the Debtor, the Creditor Bank and/or the Debtor Bank SPS WG analysis and recommendation The SPS WG recommends not taking forward the suggestion for change (option e). For technical reasons, a SDD collection needs to have at least 1 eurocent as transaction amount. The SDD collection cannot be interpreted as a message Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 47

48 2.38 # 88: Removal of SDD Mandate illustration in DS-01The Mandate Description This suggestion was made by the SPS WG. Both SDD Rulebooks contain an illustration of the SDD Mandate in section (DS-01 The Mandate). The EPC has also made available on the EPC website the document Guidelines for the appearance of Mandates (EPC392-08). As section in both SDD Scheme Rulebooks specifies that the SDD Schemes do not standardise the format of the Mandate, it is suggested to take the concerned SDD mandate illustrations out of the two SDD Rulebooks and to include them in the document EPC A single document that covers both guidelines for SDD Mandate appearances and SDD Mandate illustrations whereby this document is separated from the SDD Rulebooks, puts the EPC in a better position to publish updated guidelines and/or new mandate illustrations at any moment than through updated SDD Rulebooks which have to follow a strict change management process. This document will be taken up in the reference list of Section 0.1 of the SDD Rulebook SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b) Rulebook impact If this suggestion for change is supported, this will impact only the Rulebook. EPC SDD B2B Rulebook Change Request Consultation Document 48

49 2.39 # 89: Extension of mandate amendment combinations in AT-24 The Reason for Amendment of the Mandate Description This suggestion was made by the SPS WG. The SDD Rulebook describes under section the process steps for a mandate amendment. Attribute AT-24 gives the Creditor and/or the Debtor the possibility to report a number of mandate amendment reasons: The attribute AT-24 currently permits only a combined amendment for AT-01 (the Creditor defining a new unique Mandate reference) with AT-02 (new Creditor Identifier Information). However, in reality Creditors can take over customer portfolios and related mandates whereby just the attributes AT-02 and AT-03 (The Name of the Creditor) have to be amended. Simultaneous changes may also occur for AT-01, AT-02 and AT-03 combined. The suggestion is to extend the combination of possible mandate amendments under AT-24: Change of AT-01 (the Creditor defining a new unique Mandate reference ) Change of AT-02 (new Creditor Identifier Information) Change of AT-03 (The Name of the Creditor) Change 1 of AT-07 ( the Debtor specifying another account to be debited in the same bank ) Change 2 of AT-07 (the Debtor specifying another account to be debited in another bank) Change of a combination between the attributes AT-01, AT-02 and/or AT-03 Change of AT- 01 and change of AT SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b). This change will allow Creditors to send more combinations of mandate amendment reasons in just one SDD message Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 49

50 2.40 # 90: Representation of a first collection after being returned Description This suggestion was made by the SPS WG. The SDD Rulebook describes in process step PT Debtor Bank Sends Rejected Collections back to the CSM that when a first of a recurrent series of direct debit collections is rejected, the collection, when represented after correction, must be presented as a first of a recurrent series of direct debits respecting the longer time-line for these collections. However the SDD Rulebook appears not to explicitly specify how a collection needs to be represented when it has been the first of a recurrent series of direct debit collections and had been returned. The suggestion is to add the following sentence in process step PT Debtor Bank Sends Returned Collection Back to the CSM :.The Debtor Bank sends the returned Collection back to the CSM. When a returned Collection is a first of a recurrent series of direct debits, the Collection, when represented after correction, must be presented as a recurrent Collection. The aim of this extra sentence is to clearly prescribe how a first collection that has been returned, needs to be represented after correction SPS WG analysis and recommendation The SPS WG suggests incorporating the suggestion into the Scheme (option b) Rulebook impact If this suggestion for change is supported, this will impact both the Rulebook and the Implementation Guidelines (IGs). EPC SDD B2B Rulebook Change Request Consultation Document 50

51 3 CHANGES PERTAINING TO THE IMPACT OF THE SEPA REGULATION OR OF ANY OTHER EU LEGISLATION As the EPC is under the legal obligation to ensure compliance of the rulebooks with the SEPA Regulation or of any other EU legislation, proposed changes to the rulebooks under this section are not subject to public consultation. They are included in this document for information but the contributors to this public consultation are welcome to comment on these changes. For this release management cycle, no changes were deemed required. EPC SDD B2B Rulebook Change Request Consultation Document 51

52 4 DETAILED ANALYSIS OF MINOR CHANGES TO THE SDD B2B RULEBOOK The SPS WG recommends supporting the following suggested minor changes: 4.1 Proposed change Section Description Reason for Change Type of Change 0.1 Reference 15 (Criteria for Participation in SEPA) to be deleted as it has been withdrawn. 0.3 Paragraph 1 and 2: to be taken out completely. These paragraphs concern historical elements/events that are no longer relevant today. 0.5 Rewording from second sentence of first paragraph: In addition to the Rulebook there are a number of key documents which enable support the Scheme to become operational operationally: Removal of references to the SEPA Data Model as it is replaced by the Implementation Guidelines Paragraph 4 rewording: The SEPA Business-to-Business Direct Debit Scheme Implementation Guidelines have now been separated in are available as two complementary documents: the mandatory Gguidelines regarding the Iinter-bank Mmessages (SEPA Business-to-Business Direct Debit Scheme Inter-bank Implementation Guidelines) and the recommended Gguidelines regarding the Ccustomer-to-bank messages (SEPA Business-to-Business Direct Debit Scheme Customer-to-Bbank Implementation Guidelines) Add as new second sentence: The text of the Adherence Agreement is available in Annex Add as last sentence: In addition, a guidance document (Guide to the Adherence Process for the SEPA Direct Debit Schemes [13]) is available. Removal/ rewriting of out-of-date texts Removal/ rewriting of out-of-date texts Removal/ rewriting of out-of-date texts Removal/ rewriting of out-of-date texts Removal/ rewriting of out-of-date texts Text harmonization between the three EPC SEPA Scheme Rulebooks Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN CHAN CHAN CHAN CHAN CHAN CHAN EPC SDD B2B Rulebook Change Request Consultation Document 52

53 Section Description Reason for Change Type of Change 1.1 and 1.2 Merge the sections Introduction and Vision into one section 1.1 Vision. Review the entire section by taking out redundant elements and reword the remaining paragraphs. Removal/ rewriting of out-of-date texts CHAN 1.3 renumber ed to 1.2 Objectives: 1 st bullet point: specify euro direct debits Last bullet point to be removed as it is not considered as an objective Removal/ rewriting of out-of-date texts CHAN 1.5 renumber ed to 1.4 Separation of the Scheme from Infrastructure: 1 st paragraph: individual banks Participants Removal/ rewriting of out-of-date texts CHAN 1.6 renumber ed to 1.5 Other features of the Scheme: 3 rd bullet point: uses.. Removal/ rewriting of out-of-date texts CHAN 1.8 renumber ed to 1.7 Common legal framework: change last part of last sentence into which are listed in the EPC list of SEPA countries reference [17]. Removal/ rewriting of out-of-date texts CHAN 2.1 Footnote: re-use contents of footnote under section #0.4 rather than cross-referencing it Section 3 Take over section 3.3 on CSMs and section 3.4 on Intermediary Banks from the SCT Rulebook and adapt contents where needed Miscellaneous Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN CHAN Section 3.4 into 3.6 Relationship with customers: add as first sentence: The Rulebook does not impose any requirement as to the Terms and Conditions between a Participant and its customer. Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN 4.1 Para 5: include comma after Mandate, remove comma after legal text. Miscellaneous TYPO 4.1 Para 7, first bullet: complyies Miscellaneous TYPO EPC SDD B2B Rulebook Change Request Consultation Document 53

54 Section Description Reason for Change Type of Change 4.1 Paragraph 6: remove following discrepancies which do not align completely with the SDD Core Rulebook: 2 nd sentence:..with any related documents amendments or information relating to concerning its cancellation or lapse.. Last sentence: for as long as may be required under section of the Rulebook for the Debtor is legally entitled to obtain rectification of an unauthorised transaction under the Scheme Payment Services Directive. Paragraph 8: The dematerialised Mandaterelated data information must be transmitted (3) by the Creditor Bank to the Debtor Bank in electronic form 4.2 Para 8: move the reference (4) to the end of the first sentence 4.2 Para 10: insert hyphens before and after before Settlement to improve readability Text harmonization between the three EPC SEPA Scheme Rulebooks Miscellaneous Miscellaneous CHAN CHAN TYPO 4.2 Para 12: capitalise section Miscellaneous TYPO 4.2 Paragraph 17: condense last three sentences into one, as done in the SDD Core Rulebook: The Rulebook does not oblige the Debtor Bank or the Creditor Bank to check the correct application of this rule; it is only an obligation for the Creditor. 4.5 In the sentence preceding the final bullet list, put the correct e-mandate icon Amend title to put PR-06 in brackets at end of title Amend title in box PT06.04 (into Send Mandate copy to Debtor Bank ) to match SDD Core Rulebook PT-04-09: AT-20 put single quotes for B2B AT-21: remove comma after Collection Text harmonization between the three EPC SEPA Scheme Rulebooks Miscellaneous Text harmonization between the three EPC SEPA Scheme Rulebooks Text harmonization between the three EPC SEPA Scheme Rulebooks Miscellaneous CHAN TYPO TYPO TYPO TYPO EPC SDD B2B Rulebook Change Request Consultation Document 54

55 Section Description Reason for Change Type of Change PT-04.05: last sentence of Description does not appear in the Core Rulebook: Only one Collection may be sent to the CSM for each Collection received from the Creditor. This sentence will be taken out from the SDD B2B Rulebook PT-06.03: Under point 2 the bullet should be removed Insert e-mandates icon under the section title as in the SDD Core Rulebook Text harmonization between the three EPC SEPA Scheme Rulebooks Miscellaneous Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN CHAN TYPO 4.7.1, 4.7.3, 4.7.4, 4.7.5, The e-mandates icon is never included in a title Miscellaneous TYPO First 7 attributes should not have numbers but bullets 5.1 Delete 1 st sentence and the last sentence of this section. These sentences concern historical elements/events that are no longer relevant today. 5.4 Paragraph 1, merge 2 nd and 3 rd bullet into a single bullet: Be either incorporated and licensed in a SEPA country or territory, or licensed by an appropriate EEA regulatory body 5.5 Penultimate paragraph: If an the application of an applicant to become a Participant is rejected, the relevant applicant... 6 Add numbering for the subsections (as for the SCT Rulebook). 6 A&C para: 4 th sentence Missing text at end of sentence: as set out in detail in the Internal Rules. Miscellaneous Removal/ rewriting of out-of-date texts Text harmonization between the three EPC SEPA Scheme Rulebooks Text harmonization between the three EPC SEPA Scheme Rulebooks Text harmonization between the three EPC SEPA Scheme Rulebooks Miscellaneous TYPO CHAN CHAN CHAN TYPO CHAN EPC SDD B2B Rulebook Change Request Consultation Document 55

56 Section Description Reason for Change Type of Change Annex VIII 2.2 Chapter 7 Change In Paper to just Paper Miscellaneous TYPO Section Definitions B Correct the alphabetical order of terms under B Text harmonization between the three EPC SEPA Scheme Rulebooks TYPO I Definitions do not respect alphabetical order Miscellaneous TYPO Commenc e-ment date Removal of this definition as no longer used in the Rulebook Removal/ rewriting of out-of-date texts CHAN Customer Account Remove the word SEPA from the definition Text harmonization between the three EPC SEPA Scheme Rulebooks TYPO Cut-off time Take over the definition from the SCT Rulebook and adapt where needed Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN EBA Correct the abbreviation into Euro Banking Association Text harmonization between the three EPC SEPA Scheme Rulebooks TYPO IBAN Apply the following standard definition: International Bank Account Number: an expanded version of the basic bank account number (BBAN) intended for use internationally that uniquely identifies an individual account at a specific financial institution in a particular country (ISO 13616). Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN National Direct Debit Scheme Removal of this definition as no longer used in the Rulebook Removal/ rewriting of out-of-date texts CHAN PSD Definition to be aligned with the definition in the SCT Rulebook Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN EPC SDD B2B Rulebook Change Request Consultation Document 56

57 Section Description Reason for Change Type of Change Remittanc e informati on Apply the following definition: Information supplied by the Creditor in the direct debit collection and transmitted to the Debtor in order to facilitate the payment reconciliation. Text harmonization between the three EPC SEPA Scheme Rulebooks CHAN SEPA Data Model Removal of references to the SEPA Data Model as it is replaced by the Implementation Guidelines Removal/ rewriting of out-of-date texts CHAN SMC Include acronym Text harmonization between the three EPC SEPA Scheme Rulebooks TYPO EPC SDD B2B Rulebook Change Request Consultation Document 57

58 5 PRINCIPLES GOVERNING THE CHANGE REQUEST PROCESS 5.1 Change Request This Change Request is submitted by the SPS WG in accordance with the procedures set out in the Internal Rules in respect of changes to the rulebook. 5.2 Structure of the Change Request Sections 2, 3 and 4 describe the changes to the rulebook which are proposed in this Change Request. These changes fall into three categories: Section 2 covers innovative suggestions for change to technical operations in sections 3 and 4 of the rulebook and other significant non-technical changes which fall within the definition of major changes Section 3 covers suggestions to align the scheme rulebook with the SEPA Regulation and any other EU legislation Section 4 proposes changes to correct typing errors and provide additional clarification to the rulebook. These changes consist of minor changes to the rulebook or major changes which are uncontroversial in nature and do not affect technical operations. Annex 1 contains the original change requests. EPC SDD B2B Rulebook Change Request Consultation Document 58

59 6 CHANGE MANAGEMENT PROCESS IN RESPECT OF MAJOR CHANGES 6.1 Consideration of Suggestions In accordance with chapter of the Internal Rules, a number of suggestions in respect of changes to the SDD B2B Rulebook have been submitted for consideration to the SPS WG. 40 of these are applicable to the SDD B2B Scheme. Following consideration of these suggestions as required under chapter of the Internal Rules, the SPS WG has determined: (a) that the changes set out in section 2 and 3 meet the criteria for acceptance into the change management process; and (b) that the changes set out in section 4 constitute minor changes invoking the procedures set out in Chapter 3.3 of the Internal Rules or uncontroversial major changes. 6.2 Change Request The SPS WG is responsible for preparation and development of a Change Request in respect of the major changes referred to in section 2 above, and guiding the changes through the change management process. The SPS WG has therefore formulated this Change Request under chapter 3.2 of the Internal Rules. In accordance with chapter 3.2, this Change Request analyses the major changes which have been proposed, and attaches at Annex 1 the original suggestions. 6.3 Cost-benefit analysis and business case for the Change Request The SPS WG is required under chapter of the Internal Rules to conduct research and carry out a cost-benefit analysis on the suggestions accepted, including developing a business case for making a Change Request. The SPS WG has examined the costs and benefits arising from the suggestions raised in this Change Request. In carrying out its examination of costs and benefits of the proposed changes, the SPS WG has concluded that a formal monetary cost-benefit analysis in accordance with Appendix 1 to the Internal Rules is not appropriate since each of the proposed changes meets at least one of the following criteria: the change has been mandated by a change in law; the change implements policies decided by prior approved EPC Resolutions; the change meets a demand from Participants and Scheme users for improvement to technical aspects of the Rulebook; or the change is to add clarification or explanation or to amend typing errors in the Rulebook. The SPS WG has accordingly concluded that the requirements of chapter of Annex 1 of the Internal Rules have been met. 6.4 Consultation on the Change Request The EPC encourages all SEPA stakeholders to provide feedback during the public consultation. Banking communities are asked to consult all of their members who are involved in the SDD B2B Scheme to ensure that the views of the payment services constituency are considered in the consultation process. The SPS WG encourages the banking communities to consult as wide a range of stakeholders as possible, including participants, end users and service suppliers. All stakeholders should provide feedback to the EPC on the change request by 15 August Feedback from consultation The EPC shall collect and analyse the comments from all stakeholders and prepare a feedback report on the consultation. The report will be published on the EPC website. EPC SDD B2B Rulebook Change Request Consultation Document 59

60 6.6 Next steps Taking into account comments received during the consultation, the SPS WG will complete a change proposal per rulebook for approval by the EPC Plenary in September Approved changes will be incorporated into version 6.0 of the rulebook and published in November 2014 with the intention that they become effective in November SPS WG recommendation The SPS WG has issued a recommendation on the way forward with regard to each suggestion; the reasons underlying each recommendation are detailed in section 2. The final decision whether a suggested change will be incorporated into the rulebook is however subject to the outcome of the public consultation. The contributors to this public consultation are requested to indicate whether they agree with the recommendation of the SPS WG on the way forward. In case the contributors do not agree with the SPS WG recommendation, they are requested to indicate their preferred way forward. 6.8 Further information The above is a summary of the change management process. If you would like further information please refer to the Internal Rules or contact the EPC Secretariat. EPC SDD B2B Rulebook Change Request Consultation Document 60

61 7 CHANGE MANAGEMENT PROCESS IN RESPECT OF MINOR CHANGES 7.1 Publication of list of minor changes The SPS WG has identified certain minor changes which they consider necessary for the Rulebook. The SPS WG is required under the Internal Rules to publish a list of minor changes on the EPC website and to ensure that the list may be viewed by all stakeholders. This obligation shall be met by the publication of this Change Request, and in particular the provisions of section 4 of this Change Request noting certain changes as 'minor'. 7.2 Comments on the minor changes All stakeholders may submit comments on the list of minor changes with feedback to this Change Request. 7.3 Submission of the list of minor changes to the EPC Plenary The list of minor changes shall be submitted to the EPC Plenary for determination. The EPC Plenary shall determine whether or not to accept the changes proposed in the list of minor changes by resolution. 7.4 Publication of changes A list of minor changes that has been considered at the EPC Plenary shall be published on the EPC website together with the decision of the Plenary on those proposals. It is intended that such minor changes take effect in November 2015 alongside any major changes approved in accordance with the procedure explained in section 6 of this Change Request. EPC SDD B2B Rulebook Change Request Consultation Document 61

62 ANNEX 1 - ORIGINAL CHANGE REQUESTS EPC SDD B2B Rulebook Change Request Consultation Document 62

63 EPC KR Suggestions for Change related to harmonisation of the Rulebook texts Name of contributor: EPC Secretariat Organisation: EPC Address: Contact details: Your reference: Scheme and document and version number: See below See below #3 SDD B2B Rulebook Version 5.0 Date: August 2013 Conseil Européen des Paiements AISBL Cours Saint Michel 30 B 1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

64 1 GENERAL DESCRIPTION OF THE SUGGESTION Suggested launch date: 2015 Rulebook 1.1 Description of the suggestion: In order to take advantage of a year without an official change cycle, the Secretariat has conducted a review of the three Rulebooks in order to harmonise texts across the documents and to remove much of the forward looking texts remaining from the pre-launch versions of the Rulebooks and also to reflect the fact that migration should have taken place by the time the 2015 Rulebooks are published. This suggestion for change lists a number of texts which are not consistent across the Rulebooks. 1.2 Impact on the Scheme in general None of these changes materially affects operational or legal aspects of the Schemes. 1.3 Impact on the interbank space None of these changes materially affects operational or legal aspects of the Schemes. 1.4 Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards) There is no impact on message standards. 1.5 Impact on the legal rules as defined in Chapter 5 of the Scheme Rulebooks The proposed changes for Chapter 5 are listed in Section 3 of this document. 1.6 The nature of the suggestion This suggestion is neither a change nor a proposal for a variant, merely a collation of texts which read differently in the Rulebooks and which could be harmonised. #3 SDD B2B-Secretariat-Change Request Harmonisation 2/26 August 2013

65 2 ELEMENTS FOR EVALUATION Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? Not applicable Not applicable Not applicable Yes Yes Yes #3 SDD B2B-Secretariat-Change Request Harmonisation 3/26 August 2013

66 3 LIST OF TEXTS TO BE HARMONISED Section Description Type of Change Add as new second sentence: The text of the Adherence Agreement is available in Annex Add as last sentence: In addition, a guidance document (Guide to the Adherence Process for the SEPA Direct Debit Schemes [13]) is available. CHAN CHAN Section 3 Section 3.4 into 3.6 Take over section 3.3 on CSMs and section 3.4 on Intermediary Banks from the SCT Rulebook and adapt contents where needed Relationship with customers: add as first sentence: The Rulebook does not impose any requirement as to the Terms and Conditions between a Participant and its customer. CHAN CHAN 4.1 Paragraph 6: remove following discrepancies which do not align completely with the SDD Core Rulebook: 2 nd sentence:..with any related documents amendments or information relating to concerning its cancellation or lapse.. Last sentence: for as long as may be required under section of the Rulebook for the Debtor is legally entitled to obtain rectification of an unauthorised transaction under the Scheme Payment Services Directive. Paragraph 8: The dematerialised Mandate-related data information must be transmitted (3) by the Creditor Bank to the Debtor Bank in electronic form 4.2 Paragraph 17: condense last three sentences into one, as done in the SDD Core Rulebook: The Rulebook does not oblige the Debtor Bank or the Creditor Bank to check the correct application of this rule; it is only an obligation for the Creditor. CHAN CHAN Amend title to put PR-06 in brackets at end of title TYPO Amend title in box PT06.04 (into Send Mandate copy to Debtor Bank ) to match SDD Core Rulebook PT-04.05: last sentence of Description does not appear in the Core Rulebook: Only one Collection may be sent to the CSM for each Collection received from the Creditor. This sentence will be taken out from the SDD B2B Rulebook Insert e-mandates icon under the section title as in the SDD Core Rulebook 5.4 Paragraph 1, merge 2 nd and 3 rd bullet into a single bullet: Be either incorporated and licensed in a SEPA country or territory, or licensed by an appropriate EEA regulatory body TYPO CHAN TYPO CHAN #3 SDD B2B-Secretariat-Change Request Harmonisation 4/26 August 2013

67 Section Description Type of Change 5.5 Penultimate paragraph: If an the application of an applicant to become a Participant is rejected, the relevant applicant... CHAN 6 Add numbering for the subsections (as for the SCT Rulebook). TYPO Chapter 7 Section Definitions B Correct the alphabetical order of terms under B TYPO Customer Account Cut-off time Remove the word SEPA from the definition Take over the definition from the SCT Rulebook and adapt where needed TYPO CHAN EBA Correct the abbreviation into Euro Banking Association TYPO Apply the following standard definition: CHAN IBAN International Bank Account Number: an expanded version of the basic bank account number (BBAN) intended for use internationally that uniquely identifies an individual account at a specific financial institution in a particular country (ISO 13616). PSD Definition to be aligned with the definition in the SCT Rulebook CHAN Remittance information Apply the following definition: Information supplied by the Creditor in the direct debit collection and transmitted to the Debtor in order to facilitate the payment reconciliation. CHAN SMC Include acronym TYPO #3 SDD B2B-Secretariat-Change Request Harmonisation 5/26 August 2013

68 EPC KR Suggestions for Change related to removal/rewriting of out-ofdate texts Name of contributor: EPC Secretariat Organisation: EPC Address: Contact details: Your reference: Scheme and document and version number: See below See below #6 SDD B2B Rulebook Version 5.0 Date: July 2013 Conseil Européen des Paiements AISBL Cours Saint Michel 30 B 1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

69 1 GENERAL DESCRIPTION OF THE SUGGESTION Suggested launch date: 2015 Rulebook 1.1 Description of the suggestion: In order to take advantage of a year without an official change cycle, the Secretariat has conducted a review of the three Rulebooks in order to harmonise texts across the documents and to remove much of the forward looking texts remaining from the pre-launch versions of the Rulebooks and also to reflect the fact that migration should have taken place by the time the 2015 Rulebooks are published. This suggestion for change lists a number of texts which are no longer relevant in the post-migration era. 1.2 Impact on the Scheme in general None of these changes materially affects operational or legal aspects of the Schemes. 1.3 Impact on the interbank space None of these changes materially affects operational or legal aspects of the Schemes. 1.4 Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards) There is no impact on message standards. 1.5 Impact on the legal rules as defined in Chapter 5 of the Scheme Rulebooks The proposed changes for Chapter 5 are listed in Section 3 of this document. 1.6 The nature of the suggestion This suggestion is neither a change nor a proposal for a variant, merely the removal of historical texts which are no longer relevant. #6 SDD B2B-Secretariat-Change Request Historical 2/24 July 2013

70 2 ELEMENTS FOR EVALUATION Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? Not applicable Not applicable Not applicable Yes Yes Yes #6 SDD B2B-Secretariat-Change Request Historical 3/24 July 2013

71 3 LIST OF OUT-OF-DATE TEXTS Section Description Type of Change 0.1 Reference 15 (Criteria for Participation in SEPA) to be deleted as it has been withdrawn. 0.3 Paragraph 1 and 2: to be taken out completely. These paragraphs concern historical elements/events that are no longer relevant today. 0.5 Rewording from second sentence of first paragraph: In addition to the Rulebook there are a number of key documents which enable support the Scheme to become operational operationally: Removal of references to the SEPA Data Model as it is replaced by the Implementation Guidelines Paragraph 4 rewording: The SEPA Business-to-Business Direct Debit Scheme Implementation Guidelines have now been separated in are available as two complementary documents: the mandatory Gguidelines regarding the Iinter-bank Mmessages (SEPA Business-to-Business Direct Debit Scheme Inter-bank Implementation Guidelines) and the recommended Gguidelines regarding the Ccustomer-to-bank messages (SEPA Business-to-Business Direct Debit Scheme Customer-to-Bbank Implementation Guidelines). 1.1 and 1.2 Merge the sections Introduction and Vision into one section 1.1 Vision. Review the entire section by taking out redundant elements and reword the remaining paragraphs. CHAN CHAN CHAN CHAN CHAN CHAN 1.3 renumbered to renumbered to renumbered to renumbered to 1.7 Objectives: 1 st bullet point: specify euro direct debits Last bullet point to be removed as it is not considered as an objective Separation of the Scheme from Infrastructure: 1 st paragraph: individual banks Participants Other features of the Scheme: 3 rd bullet point: uses.. Common legal framework: change last part of last sentence into which are listed in the EPC list of SEPA countries reference [17]. CHAN CHAN CHAN CHAN 5.1 Delete 1 st sentence and the last sentence of this section. These sentences concern historical elements/events that are no longer relevant today. CHAN #6 SDD B2B-Secretariat-Change Request Historical 4/24 July 2013

72 Section Description Type of Change 7 Section Definitions Commencement date National Direct Debit Scheme Removal of this definition as no longer used in the Rulebook Removal of this definition as no longer used in the Rulebook CHAN CHAN SEPA Model Data Removal of references to the SEPA Data Model as it is replaced by the Implementation Guidelines CHAN #6 SDD B2B-Secretariat-Change Request Historical 5/24 July 2013

73 EPC KR Suggestions for Change - Miscellaneous Name of contributor: EPC Secretariat Organisation: EPC Address: Contact details: Your reference: Scheme and document and version number: See below See below #12 SDD B2B Rulebook Version 5.0 Date: August 2013 Conseil Européen des Paiements AISBL Cours Saint Michel 30 B 1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

74 1 GENERAL DESCRIPTION OF THE SUGGESTION Suggested launch date: 2015 Rulebook 1.1 Description of the suggestion: In order to take advantage of a year without an official change cycle, the Secretariat has conducted a review of the three Rulebooks in order to harmonise texts across the documents and to remove much of the forward looking texts remaining from the pre-launch versions of the Rulebooks and also to reflect the fact that migration should have taken place by the time the 2015 Rulebooks are published. All of these suggestions for change have been documented separately. This suggestion for change lists a number of miscellaneous and minor corrections that need to be made. 1.2 Impact on the Scheme in general None of these changes materially affects operational or legal aspects of the Schemes. 1.3 Impact on the interbank space None of these changes materially affects operational or legal aspects of the Schemes. 1.4 Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards) There is no impact on message standards. 1.5 Impact on the legal rules as defined in Chapter 5 of the Scheme Rulebooks No changes are proposed in Chapter The nature of the suggestion This suggestion is neither a change nor a proposal for a variant, merely the correction of a number of small typos. #12 SDD B2B-Secretariat-Change Request Misc 2/27 August 2013

75 2 ELEMENTS FOR EVALUATION Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? Not applicable Not applicable Not applicable Yes Yes Yes #12 SDD B2B-Secretariat-Change Request Misc 3/27 August 2013

76 3 LIST OF SUGGESTIONS FOR CHANGE Section Description Type of Change 2.1 Footnote: re-use contents of footnote under section #0.4 rather than cross-referencing it 4.1 Para 5: include comma after Mandate, remove comma after legal text. CHAN TYPO 4.1 Para 7, first bullet: complyies TYPO 4.2 Para 8: move the reference (4) to the end of the first sentence CHAN 4.2 Para 10: insert hyphens before and after before Settlement to improve readability TYPO 4.2 Para 12: capitalise section TYPO 4.5 In the sentence preceding the final bullet list, put the correct e- Mandate icon PT-04-09: AT-20 put single quotes for B2B AT-21: remove comma after Collection TYPO TYPO PT-06.03: Under point 2 the bullet should be removed CHAN 4.7.1, 4.7.3, 4.7.4, 4.7.5, The e-mandates icon is never included in a title TYPO First 7 attributes should not have numbers but bullets TYPO 6 A&C para: 4 th sentence Missing text at end of sentence: as set out in detail in the Internal Rules. CHAN 7 I definitions do not respect alphabetical order TYPO Annex 2.2 VIII Change In Paper to just Paper TYPO #12 SDD B2B-Secretariat-Change Request Misc 4/27 August 2013

77 Doc:EPC November 2011 (Version 1.1) EPC Template Name of contributor: for proposing a suggestion for a change in a SEPA Payment Scheme (Responses by to: info@epc-cep.eu or by mail to the address at the foot of this page) Organisation: Spanish Banking Community Address: Contact details: Clara del Rey, 26 - Planta 5, Madrid BBVA jfernandezi@bbva.com Mobile Phone Your reference: Scheme and document and version number: EPC SDD B2B RB v4.1 Date: December 2013 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: _id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

78 1 GENERAL DESCRIPTION OF THE SUGGESTION Suggested launch date: (if any): Description of the suggestion: When a B2B direct debit is received, the debtor must authorize the debit into his account. Sometimes, the debtor bank is not able to locate the debtor in such short period of time. In this case, the debit is rejected to creditor s bank before settlement, or returned after settlement. Today, there is not any specific reject/return reason to inform in the message in this case, therefore, we propose the inclusion of a new reject/return reason in AT-R3 The Reason Code for Non-Acceptance (Reject or Return): Unable to obtain debit authorization from debtor. This new code would clarify the reason for reject / return and avoid the use of other codes that may not correspond (unauthorized transaction/reason not specified) Wherever possible, please indicate: 1. Impact on the Scheme in general Minimum 2. Impact on the interbank space Minimum 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards) Scheme Implementation Guidelines: Inter-bank: to include the new reason for a Reject/Return, in the relevant epigraph. Customer to bank: to include the new reason for a Reject/Return, in the relevant epigraph. 4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks None 5. The nature of the suggestion: a. A change (replacing an existing Rulebook element by a new one) b. A variant (adding an alternative optional rule alongside an existing Rulebook element) #13 SDD B2B-Spain- new r-reason in AT-R3 2 of 3

79 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? Yes No No Yes Yes, It does not impede SEPA-wide interoperability Yes #13 SDD B2B-Spain- new r-reason in AT-R3 3 of 3

80 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: SEPA Payment Schemes Working Group (SPS WG) EPC Address: -- Contact details: Your reference: Scheme and document and version number: -- #16 EPC SEPA Credit Transfer Rulebook Version 7.1 EPC SEPA Direct Debit Core Rulebook Version 7.1 EPC SEPA Direct Debit Business to Business Rulebook Version 5.1 Request Date: 30/01/2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

81 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): November 2015 for the following Rulebooks: EPC SEPA Direct Debit Core Rulebook Version 8.0 EPC SEPA Direct Debit Business to Business Rulebook Version Description of the suggestion: An issue does arise in relation to a debtor who changes its IBAN at the same PSP or wishes to use a new IBAN at another PSP. The current SDD rulebooks do not cater sufficient guidance for all possible cases (e.g., debtor prefers now another payment account to be used at the same debtor bank or held at another debtor bank, change of IBAN within the same debtor bank as the debtor relocates to another region in the same country, a merger of current debtor bank with another debtor bank occurred). Furthermore, the situation will become more complicated due to the SEPA End-Date Regulation, which makes the BIC optional at national level in 2014 and also at cross-border level in Especially the creditors would not be sure if the new IBAN would mean that the debtor had changed to another PSP. This could lead to complications when presenting the next collection to the debtor bank managing this other IBAN. Debtor banks apply different treatments related to the sequence type ( first" or "recurrent") they have to control. This may result in rejecting the collection which can be felt as unjustified. The current rules in both SDD rulebooks are not explicit enough and this leads to different interpretations. It is suggested applying a unique rule: in case the debtor informs the creditor of a change of account number (whether held in the same debtor bank or in another debtor bank), the next collection under an existing mandate should be presented as a first SDD collection to this new IBAN. 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: The description under process step PT in the SDD Core and in SDD B2B rulebooks will have to be amended 2. Impact on the interbank space: In case an IBAN change is communicated by the debtor to the creditor under an existing mandate, the creditor bank will have to present the next SDD Core or SDD B2B collection according to the First cycle timeline to the debtor bank irrespective if the debtor bank has remained the same or not. 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): No impact. It concerns a change in the business rules of the SDD Core and SDD B2B Rulebooks. 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: No impact. 5. The nature of the suggestion: #16 SDD Core & B2B-EPC SPS WG- IBAN change by debtor - next SDD collection as FIRST 2 of 4

82 a. A change (deleting or replacing an existing Rulebook element by a new one) YES b. A variant (adding an alternative optional rule alongside an existing Rulebook element) NO #16 SDD Core & B2B-EPC SPS WG- IBAN change by debtor - next SDD collection as FIRST 3 of 4

83 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES It will improve STP as the amended business rule removes any misinterpretation on the collection time cycle to be followed for a SDD collection after an IBAN change communicated by the debtor YES YES YES YES #16 SDD Core & B2B-EPC SPS WG- IBAN change by debtor - next SDD collection as FIRST 4 of 4

84 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: SEPA Payment Schemes Working Group (SPS WG) EPC Address: -- Contact details: Your reference: Scheme and document and version number: -- #17 EPC SEPA Credit Transfer Rulebook Version 7.1 EPC SEPA Direct Debit Core Rulebook Version 7.1 EPC SEPA Direct Debit Business to Business Rulebook Version 5.1 Request Date: 31/01/2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

85 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): November 2015 for the following Rulebooks: EPC SEPA Credit Transfer Rulebook Version 8.0 EPC SEPA Direct Debit Core Rulebook Version 8.0 EPC SEPA Direct Debit Business to Business Rulebook Version Description of the suggestion: The current EPC SEPA schemes permit the end-to-end carrying of remittance data on a structured or unstructured basis (AT-05 remittance information, AT-22 the remittance information sent by the Creditor to the Debtor in the Collection). The scheme rules allow for one repetition of the remittance information field of up to 140 characters to be included with the remittance information. While this has generally been considered sufficient for most retail payment needs, during the last couple of years there have been several change requests by different stakeholder groups and banking communities asking for a possibility to use significantly larger remittance information. It indicates that the present 140 characters of remittance information are not enough for all users or communities in the SEPA area. The ISO enables unlimited number of repetitions of the unstructured 140 character remittance information field or an unlimited number of structured remittance information instances. The SEPA End-Date Regulation sets the similar 140 characters end-to-end requirement but does not prohibit the transmission of longer remittance information. It is proposed to make additional customer-to-customer information available outside of the payment transaction from the SCT or SDD message. The payment message would only carry the information of the location where the additional customer-to-customer information is stored. The additional data exceeding 140 characters can then be sent separately from the SCT or SDD payment message. Additional data elements/ attributes that already exist in ISO (e.g., ISO Extended Remittance Advice message) can be taken up in the three EPC SEPA scheme rulebooks. These new attributes will store details of the location from where the additional customer-to-customer information can be retrieved. It is emphasized that the current limited character set to be used in the three EPC SEPA schemes will remain unchanged. Furthermore, the additional attributes storing the location of the additional customer-to-customer information will be optional fields. This means that only when the Originator or the Creditor provides information about the storage location of the additional customer-to-customer information in these optional fields, it is mandatory for the Originator Bank or Creditor Bank to transport this storage location information in these fields to the Beneficiary Bank or to the Debtor Bank. In case of an arrangement between Beneficiary Bank and the Beneficiary/ between the Debtor Bank and the Debtor, the information about the storage location could be made available. These details are sent together with the SCT or SDD message but are not part of the SCT or SDD payment. The diagram below provides an illustration about the concept of making additional customer-tocustomer information (AC2CI) available: #17 All Rulebooks-EPC SPS WG- additional customer-to-customer information 2 of 5

86 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: SCT Rulebook: Section 2.7 remittance data: additional wording indicating the option to indicate the storage location of extended remittance information via a message other than the SCT payment message DS-01, DS-02 and DS-04: inclusion of new optional attributes to be used for the identification and the location of the extended remittance information Section 4.6: o Additional wording in AT-05 indicating the option to indicate the storage location of extended remittance information via a message other than the SCT payment message o Description of the new optional attributes to needed to facilitate the optional exchange of extended remittance information Section 7: definition of the term remittance information (extended) SDD Core Rulebook and SDD B2B Rulebook: DS-03, DS-04 and DS-06: inclusion of new optional attributes to be used for the identification and the location of the extended remittance information Section 4.8: Description of the new optional attributes to needed to facilitate the optional exchange of extended remittance information Section 7: definition of the term remittance information (extended) 2. Impact on the interbank space: It means that only when the Originator/ Creditor provides information about the storage location of the additional customer-to-customer information in these optional fields, it is mandatory for the Originator Bank/ Creditor Bank to transport this storage location information in these fields to the Beneficiary Bank/ Debtor Bank. In case of an arrangement between the Beneficiary Bank/ Debtor Bank and the Beneficiary/ Debtor, the information about the storage location could be made available. 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): SCT Customer-to-Bank IGs: Customer Credit Transfer Initiation (pain ): 2.1.3, Index 2.91 #17 All Rulebooks-EPC SPS WG- additional customer-to-customer information 3 of 5

87 SCT Inter-Bank IGs: FI to FI Customer Credit Transfer (pacs ) , Index 2.68 SDD Core Inter-Bank IGs: FI to FI Customer Direct Debit (pacs ) , Index 2.74 SDD Core Customer-to-Bank IGs: Customer Direct Debit Initiation (pain ) , Index 2.81 SDD B2B Inter-Bank IGs: FI to FI Customer Direct Debit (pacs ) , Index 2.74 SDD B2B Customer-to-Bank IGs: Customer Direct Debit Initiation (pain ) , Index Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: No impact. 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) YES b. A variant (adding an alternative optional rule alongside an existing Rulebook element) YES #17 All Rulebooks-EPC SPS WG- additional customer-to-customer information 4 of 5

88 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES In the last years, several change requests by different stakeholder groups and banking communities had been made asking for a possibility to use additional customer-tocustomer information. YES YES YES YES #17 All Rulebooks-EPC SPS WG- additional customer-to-customer information 5 of 5

89 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: SEPA Payment Schemes Working Group (SPS WG) EPC Address: -- Contact details: Your reference: Scheme and document and version number: -- #18 EPC SEPA Credit Transfer Rulebook Version 7.1 EPC SEPA Direct Debit Core Rulebook Version 7.1 EPC SEPA Direct Debit Business to Business Rulebook Version 5.1 Request Date: 31/01/2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

90 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): November 2015 for the following Rulebooks: EPC SEPA Direct Debit Core Rulebook Version 8.0 EPC SEPA Direct Debit Business to Business Rulebook Version Description of the suggestion: The SDD Core and B2B Rulebook cover the possibility for a refusal of SDD collection. Different interpretations of the term refusal (i.e. it is the debtor who initiates the refusal) and the technical aspects of treating such refusal (as a reject before settlement or as return/refund after settlement) had been reported. The main issue is whether such refusal can be processed either as reject, return or refund. The Rulebooks also provide contradictory information: A. Current status in SDD Core Rulebook: 1. Section 4.2, p.24 2 nd par.: The Debtor Bank may return a Collection after Settlement up to five Inter-Bank Business Days after the Settlement Date, either for technical reasons or because the Debtor Bank is unable to accept the Collection for other reasons, e.g. account closed, Customer deceased, account does not accept direct debit, or for reasons pursuant to Article 78 of the Payment Services Directive, or because the Debtor wishes to refuse the debit. 2. Section 4.4, p.30 definition Reject : Rejects are Collections that are diverted from normal execution, prior to inter-bank Settlement, for the following reasons: Technical reasons detected by the Creditor Bank, the CSM, or the Debtor Bank, such as invalid format, wrong IBAN check digit The Debtor Bank is unable to process the Collection for such reasons as are set out in Article 78 of the Payment Services Directive. The Debtor Bank is unable to process the Collection for such reasons as are set out in section 4.2 of the Rulebook (e.g. account closed, Customer deceased, account does not accept direct debits). The Debtor made a Refusal request to the Debtor Bank. The Debtor Bank will generate a Reject of the Collection being refused. 3. Section 4.4, p.30 definition Refusal : Refusals are claims initiated by the Debtor before Settlement, for any reason, requesting the Debtor Bank not to pay a Collection. This Refusal must be handled by the Debtor Bank in accordance with the conditions agreed with the Debtor. If the Debtor Bank agrees to handle the claim prior to inter-bank settlement, the Refusal results in the Debtor Bank rejecting the associated Collection. (Note: In addition to this ability to refuse individual transactions, the Debtor has the right to instruct the Debtor Bank to prohibit any direct debits from his bank account). When handled after Settlement this Refusal is referred to as a Refund claim. (See description underneath in the Refund section). Thus not considered as a return #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 2 of 8

91 4. PT bis Debtor May Instruct Refusal to Debtor Bank The Debtor may instruct the Debtor Bank to refuse any future Collection, based on information received through Pre-notification. This Refusal must be handled by the Debtor Bank, but only in accordance with the conditions sent to the Debtor : If the Debtor Bank agrees to handle the claim prior to inter-bank Settlement, the Refusal results in the Debtor Bank rejecting the associated Collection: see PT When handled after inter-bank Settlement, the Refusal is handled as a Refund claim: see PT Thus not considered as a return 5. AT-R3 The Reason Code for Non-Acceptance (Reject, Return or Refund) a) Value range: The reasons for a Reject, Return or Refund by the Creditor Bank need not be specified, they are left to a bilateral agreement between Creditor s bank and its customer (Creditor). Would it not be rather the debtor bank and the debtor? (Except that a creditor bank can only reject) b) The reasons for a Reject by the CSM or the Debtor s bank are as follows: ( ) Refusal by the Debtor c) The reasons for a Return by the Debtor s bank are as follows ( ) Refusal by the Debtor Refusal leads to a return d) The reasons for a Refund are as follows: Unauthorised Transaction Disputed authorised transaction (can only be used within the eight-week no-questions-asked Refund period) There is no notion of Refusal which contradicts with points 3. and Annex V 2. The time-line of the Collections (Differences SDD Core with SDD B2B) 2. The time-line of the Collections 2.1 Refusal of a Collection The Debtor may, before Settlement, initiate a Refusal, requesting the Debtor Bank not to pay a Collection. This Refusal may be handled prior to interbank settlement generating a Reject, or after Settlement generating a Return. Refusal leads to a return. The Debtor may, before Settlement, initiate a Refusal, requesting the Debtor Bank not to pay a Collection. This Refusal must be handled prior to interbank settlement generating a Reject, or after Settlement, by preference on due date, generating a Return. #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 3 of 8

92 B. Current status in SDD B2B Rulebook 1. Section 4.2, p.26 6 th par.: The Debtor Bank may return a Collection after Settlement up to two Inter-Bank Business Days after the Settlement Date, either for technical reasons or because the Debtor Bank is unable to accept the Collection for other reasons, e.g. account closed, Customer deceased, account does not accept direct debit, or because the Debtor wishes to refuse the debit. 2. Section 4.3.4, p.30 2nd bullet: Refusals may be initiated by the Debtor and must be executed by the Debtor Bank prior to interbank Settlement (generating a Reject) or after Settlement (generating a Return). Returns must be executed by the Debtor Bank as soon as possible and ideally by day D. 3. Section 4.4, p.31 definition Reject : Rejects are Collections that are diverted from normal execution, prior to inter-bank Settlement, for the following reasons: ( ) The Debtor made a Refusal request to the Debtor Bank. The Debtor Bank will generate a Reject of the Collection being refused 4. Section 4.4, p.31 definition Refusal : Refusals are claims initiated by the Debtor before Settlement, for any reason, requesting the Debtor Bank not to pay a Collection. By way of derogation from Article 66 of the Payment Services Directive, the time period for Refusal of a Collection also includes day D. This Refusal must be handled by the Debtor Bank in accordance with the conditions agreed with the Debtor. The Debtor Bank should handle the Refusal claim by preference prior to inter-bank settlement, resulting in the Debtor Bank rejecting the associated Collection. (Note: In addition to this ability to refuse individual transactions, the Debtor has the right to instruct the Debtor Bank to prohibit any direct debits from his bank account). When handled after Settlement, this Refusal is referred to as a Return. Under SDD Core, this is a refund 5. PT bis Debtor May Instruct Refusal to Debtor Bank The Debtor may instruct the Debtor Bank to refuse any future Collection, based on any information received. This Refusal must be made before Settlement. When the Debtor Bank handles the instruction prior to inter-bank Settlement, the Refusal results in the Debtor Bank rejecting the associated Collection: see PT When handled after inter-bank Settlement, the Refusal results in a Return of the associated Collection, to be settled by preference on Due Date, but never later than D+2 Inter-Bank Business Days. Under SDD Core, this is a refund 6. AT-R3 The Reason Code for Non-Acceptance (Reject or Return) a) Value range: The reasons for a Reject or Return by the Creditor Bank need not be specified, they are left to a bilateral agreement between Creditor s bank and its Business Customer (Creditor). #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 4 of 8

93 Would it not be rather the debtor bank and the debtor? (Except that a creditor bank can only reject) b) The reasons for a Reject by the CSM or the Debtor s bank are as follows: ( ) Refusal by the Debtor c) The reasons for a Return by the Debtor s bank are as follows ( ) Refusal by the Debtor Refusal leads to a return 7. Annex V 2. The time-line of the Collections (Differences SDD Core with SDD B2B) 2. The time-line of the Collections 2.1 Refusal of a Collection The Debtor may, before Settlement, initiate a Refusal, requesting the Debtor Bank not to pay a Collection. This Refusal may be handled prior to interbank settlement generating a Reject, or after Settlement generating a Return. The Debtor may, before Settlement, initiate a Refusal, requesting the Debtor Bank not to pay a Collection. This Refusal must be handled prior to interbank settlement generating a Reject, or after Settlement, by preference on due date, generating a Return. Refusal leads to a return. #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 5 of 8

94 C. Proposed change suggestion: It is proposed to update the Rulebooks in a way that a Refusal is always based on a request of the Debtor before Due Date/ Settlement Date not to pay a collection. The technical R-transaction could be either a Reject (which is the preference) or if technically not feasible before Settlement a Return. Only Refusals returned by a Reject or by a Return allow the proper reason code Refusal by the Debtor. With the way forward no change in today s practice by PSPs is required. Wording corrections are proposed to attribute AT-R3 in both SDD Rulebooks. D. Resulting Rulebook changes SDD Core: 1. Section 4.4, p.30 definition Refusal : Refusals are claims initiated by the Debtor before Settlement for any reason, requesting the Debtor Bank not to pay a Collection. This Refusal must be handled by the Debtor Bank in accordance with the conditions agreed with the Debtor. If the Debtor Bank agrees decides to handle the claim prior to inter-bank settlement, which should be preferred, the Refusal results in the Debtor Bank rejecting the associated Collection. (Note: In addition to this ability to refuse individual transactions, the Debtor has the right to instruct the Debtor Bank to prohibit any direct debits from his bank account). When handled after Settlement, this Refusal is referred to could be processed either as a Return Refund claim.(see description underneath in the Refund section). 2. PT bis Debtor May Instruct Refusal to Debtor Bank The Debtor may instruct the Debtor Bank to refuse any future Collection, based on information received through Pre-notification. This Refusal must be handled by the Debtor Bank, but only in accordance with the conditions sent to the Debtor: If the Debtor Bank agrees to handle the claim prior to inter-bank Settlement, the Refusal results in the Debtor Bank rejecting the associated Collection: see PT When handled after inter-bank Settlement, the Refusal is handled as a ReturnRefund claim: see PT AT-R3 The Reason Code for Non-Acceptance (Reject, Return or Refund) a) Value range: The reasons for a Reject, Return or Refund by the Creditor Bank need not to be specified, they are left to a bilateral agreement between the Creditor s Bbank and its customer (the Creditor). The reasons for a Reject, Return or Refund by the Debtor Bank need not to be specified, they are left to a bilateral agreement between the Debtorr s Bbank and the its customer (Debtor). b) The reasons for a Reject by the CSM, the Creditor Bank or the Debtor s Bbank are as follows: ( ) Refusal by the Debtor c) The reasons for a Return by the Debtor s Bbank are as follows ( ) #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 6 of 8

95 Refusal by the Debtor E. Resulting Rulebook changes SDD B2B: 1. AT-R3 The Reason Code for Non-Acceptance (Reject or Return) a) Value range: The reasons for a Reject or Return by the Creditor Bank need not to be specified, they are left to a bilateral agreement between the Creditor s Bbank and the Creditor being a its Business Customer (Creditor). The reasons for a Reject or Return by the Debtor Bank need not to be specified, they are left to a bilateral agreement between the Debtor Bbank and the Debtor being a its Business Customer (Debtor). b) The reasons for a Reject by the CSM, the Creditor Bank or the Debtor s Bbank are as follows: ( ) Refusal by the Debtor c) The reasons for a Return by the Debtor s Bbank are as follows ( ) Refusal by the Debtor 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: See resulting Rulebook changes. 2. Impact on the interbank space: The refund option is no longer allowed for collection refusals by the debtor. 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): No change as the list of reasons under AT-R3 remains unchanged. 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: No impact. 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) YES b. A variant (adding an alternative optional rule alongside an existing Rulebook element) NO #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 7 of 8

96 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES No, it will provide further clarification of the business rules to be followed in case of a collection refusal by the debtor YES YES YES YES #18 SDD Core & B2B-EPC SPS WG- clarification on refusal -- AT-R3 v1.0 8 of 8

97 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: C. Bastian Betaalvereniging Nederland Address: Postbus Contact details: Your reference: Scheme and document and version number: c.bastian@betaalvereniging.nl Change03_SDD B2B_ : End-to-end identification optional instead of mandatory SDD B2B Rulebook 5.0 Request Date: January 23 th, 2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

98 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): Effective as from November 2015 (=SDD B2B Rulebook 6.0) 1.2 Description of the suggestion: The End-to-End identification is mandatory in the Customer-to-Bank Implementation Guidelines. If this end-to-end identification is not given, the Interbank Implementation Guidelines of the Rulebook prescribe to provide NOTPROVIDED (see Usage rule) in the End-to_End identification. Assuming the Customer-to-Bank Implementation Guidelines contains the correct usage of mandatory/optional fields, Rulebook has a wrong description in The Creditor s Reference of the Direct Debit Transaction (AT-10) regarding the usage of the default value. As the Customer-to-Bank IG states this Index 2.31 is mandatory it cannot be the case that the Creditor Bank must fill this field with not provided when left blank by the Creditor as the Creditor is obliged to provide a value. Suggestion 1: Delete If no reference is provided by the Creditor, the Creditor Bank has to fill in the default value Not Provided in AT-10 Suggestion 2:. Make End-to-End Identification optional instead of mandatory 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: Improving efficiency 2. Impact on the interbank space: Improving efficiency 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): Yes. Rulebook: In AT-10: If no reference is provided by the Creditor, this attribute has default value Not Provided to be deleted. IG Customer-to-Bank: Index 2.31, Index 3.16 and Index 3.18 becomes optional IG Bank-tot-Bank: - Index 2.3 becomes optional - Index 2.3: delete Usage Rule - Transaction Information: Index 3.3 becomes optional - Transaction Information and Status: Index 3.7 becomes optional Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: None 4. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) CHANGE Change03_SDD_B2B_Endtoend_identification_optional_ docx 2 of 4

99 b. A variant (adding an alternative optional rule alongside an existing Rulebook element) n.a. Change03_SDD_B2B_Endtoend_identification_optional_ docx 3 of 4

100 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES NO YES YES YES YES Change03_SDD_B2B_Endtoend_identification_optional_ docx 4 of 4

101 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: C. Bastian Betaalvereniging Nederland Address: Postbus Contact details: Your reference: Scheme and document and version number: c.bastian@betaalvereniging.nl Change05_SDD B2B_ Make sequence type FRST optional instead of mandatory SDD B2B Rulebook 5.0 Request Date: January 23 th, 2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

102 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): Effective from November 2015 (=SDD B2B Rulebook 6.0) 1.2 Description of the suggestion: Make sequence type FRST optional instead of mandatory. Can be implemented by using only RCUR or OOFF. Arguments in favour of this change are: As registration of the mandate information at the Debtor Bank is already a requirement before any B2B-transaction can be processed, distinction in sequence type has no additional value. Therefore there is no business logic to make a distinction between a FRST and RCUR transaction, as they are both initiated on D-1 at the latest. Abandoning the difference between FRST and RCUR prevents unnecessary sequence errors. 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: Processing will be simplified. 2. Impact on the interbank space: Less R-transactions will be generated 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): None 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: None 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) CHANGE b. A variant (adding an alternative optional rule alongside an existing Rulebook element) n.a. Change05_SDD_B2B_FRST_optional_ docx 2 of 3

103 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES NO; number of R-transactions will decrease YES YES YES YES Change05_SDD_B2B_FRST_optional_ docx 3 of 3

104 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: Address: Contact details: Your reference: Scheme and document and version number: C. Bastian Betaalvereniging Nederland (Dutch Payments Association) Postbus 83073, 1080 AB Amsterdam c.bastian@betaalvereniging.nl, +31(0) Change06A_SDD Core_B2B_ Amendment reasons for Creditor to be removed from AT-24 SDD Core Rulebook 7.0 and SDD B2B 5.0 Request Date: January 23 th, 2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

105 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): Effective from November 2015 (=SDD Core Rulebook 8.0 and SDD B2B Rulebook 6.0) 1.2 Description of the suggestion: The existing amendment procedure of the mandate is experienced as complex (even confusing) and leads to many questions and errors in processing. Especially if amendments are driven by the Creditor (e.g. defining a new CreditorID, an other unique mandate reference and/or an other Creditor name) it is not always clear how to act. In practice, this leads often to misunderstandings (e.g. wrong usage of SMNDA and/or sequence types). As a result unnecessary R-messages are processed. A more simple usage rule: Creditor issues a new mandate if the Creditor wants to change his name, CreditorID and/or unique mandate reference. This is more clear to all parties involved (Creditors, Debtors and their Banks). This will contribute to a more unambiguous and clear operation for all. So we do suggest following: Delete all Creditor related reasons from AT Wherever possible, please indicate: 1. Impact on the Scheme in general: Creditors must obtain a new mandate from the Debtor in case they want to change the mandate for one of the four reasons as mentioned in AT Impact on the interbank space: Less checks and errors on SMNDA 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): Yes. Delete from AT-24: Change of AT-01 (the Creditor defining a new unique Mandate reference ) Change of AT-02 (new Creditor Identifier Information) Change of AT-03 (The Name of the Creditor) Change of AT-01 and change of AT Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: None 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) CHANGE: deleting all amendment related procedures and elements. b. A variant (adding an alternative optional rule alongside an existing Rulebook element) Change06A_SDD_Core_B2B_AT24_NO_amendments_byCreditor_ docx 2 of 3

106 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES NO YES YES YES YES Change06A_SDD_Core_B2B_AT24_NO_amendments_byCreditor_ docx 3 of 3

107 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: Address: Contact details: Your reference: Scheme and document and version number: C. Bastian Betaalvereniging Nederland (Dutch Payments Association) Postbus 83073, 1080 AB Amsterdam c.bastian@betaalvereniging.nl, +31(0) Change06B_SDD Core_B2B_ Debtor amends IBAN on mandate. Creditor must always use sequence type FRST for next Collection based on same mandate SDD Core Rulebook 7.0 and SDD B2B Rulebook 5.0 Request Date: January 23 th, 2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

108 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): Effective from November 2015 (=SDD Core Rulebook 8.0 and SDD B2B Rulebook 6.0) 1.2 Description of the suggestion: The Rulebooks prescribes different procedures for amending the mandate for new Debtor accounts within the same bank and for new Debtor accounts within an other bank. The Creditor must issue a direct debit respecting the time-cycle of the first direct debit ( FRST ), when the cause of the amendment is that the Debtor decides to use another account in another bank. If the account stays within the same bank/entity this is not necessary. Furthermore Debtor Banks which have changed their BIC and / or the IBAN of the Debtor but which remain the same entity should not reject a Collection due to sequence type FRST. In practice Creditors are not able to determine if the new account is held with the same or with an other Bank with certainty (e.g. different BIC-codes, IBAN-only). So the procedures are confusing and are leading to misunderstandings and errors in processing (e.g. wrong sequence types). As a result unnecessary R-messages are processed. A more simple usage rule: If Debtor amends IBAN on the mandate, Creditor must always issue the next Collection as sequence type FRST respecting the time-cycle of the first direct debit. The same mandate reference can be used. In other words do always sent a new FRST-transaction based on the same mandate if Debtor amends IBAN (On D-5 with SDD Core and with SDD B2B on D-1 )). This is more clear to all parties involved (Creditors, Debtors and their Banks) and will contribute to a more unambiguous and clear operation for all. So we do suggest following: Do treat Change 1 of AT-07 (the Debtor specifying another account to be debited in the same bank) and Change 2 of AT-07 (the Debtor specifying another account to be debited in another bank) both in the same way. As a consequence Debtor Banks may not reject Collections due to the sequence type FRST (This is comparable if they should have changed their own BIC and/or IBAN s of their Debtors). CLARIFICATION 1: FRST after FRST will not be rejected CLARIFICATION 2: FRST after RCUR will not be rejected Wherever possible, please indicate: 1. Impact on the Scheme in general: Creditors and Debtors and their banks can use one simple and clear instruction if the Debtor wants to change his IBAN. 2. Impact on the interbank space: Change06B_SDD_Core_Creditor must always use sequence type FRST for next Collection based on same mandate_ docx 2 of 4

109 Less errors on SMNDA 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): Yes. AT-07 and AT-24 must be adjusted accordingly 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: None 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) CHANGE: all amendment related procedures and elements must be replaced accordingly. b. A variant (adding an alternative optional rule alongside an existing Rulebook element) Change06B_SDD_Core_Creditor must always use sequence type FRST for next Collection based on same mandate_ docx 3 of 4

110 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES NO YES YES YES YES Change06B_SDD_Core_Creditor must always use sequence type FRST for next Collection based on same mandate_ docx 4 of 4

111 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: Address: Contact details: Your reference: Scheme and document and version number: C. Bastian Betaalvereniging Nederland (Dutch Payments Association) Postbus 83073, 1080 AB Amsterdam c.bastian@betaalvereniging.nl, +31(0) SDD_Core_B2B_Change07_ ADD extra reasoncodes for whitelisting/debtor driven reasons SDD Core Rulebook 7.0 an SDD B2B Rulebook 5.0 Request Date: January 23 th, 2014 For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

112 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): Effective from November 2015 (=SDD Core Rulebook 8.0 and SDD B2B Rulebook 6.0) 1.2 Description of the suggestion: ADD five new reasoncodes to specify the different reasons as mentioned in Regulation 260/2012 of March 14 th 2012 (+article 5.3.d) and add one reasoncode for specifying B2B-mandate is cancelled by Debtor. Reasoncode for: SDD Core SDD B2B 1 Debtor has not posted Creditor on his Whitelist (yet) YES N.A. 2 Debtor did post Creditor on his Blacklist YES N.A. 3 Transaction exceeds maximum amount YES YES 4 Maximum number of Direct Debit transactions within certain period is exceeded 5 Maximum amount and maximum number of Direct Debit transactions within certain period are exceeded YES YES YES YES 6 Mandate is cancelled by Debtor N.A. YES 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: No 2. Impact on the interbank space: Set of reasoncodes will be extended 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): Yes 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: None 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) b. A variant (adding an alternative optional rule alongside an existing Rulebook element) Change07_SDD_Core_B2B_extra_reasoncodes_ docx 2 of 4

113 Variant: Adding new reasoncodes will supply Creditors with more useful information in case of Whitelisting and/or services provided by Debtor Banks Change07_SDD_Core_B2B_extra_reasoncodes_ docx 3 of 4

114 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES NO YES YES YES YES Change07_SDD_Core_B2B_extra_reasoncodes_ docx 4 of 4

115 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: SEPA Payment Schemes Working Group (SPS WG) EPC Address: -- Contact details: Your reference: Scheme and document and version number: -- #29 EPC SEPA Credit Transfer Rulebook Version 7.1 EPC SEPA Direct Debit Core Rulebook Version 7.1 EPC SEPA Direct Debit Business to Business Rulebook Version 5.1 Request Date: For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

116 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): EPC SEPA Direct Debit Core Rulebook Version 8.0 EPC SEPA Direct Debit Business to Business Rulebook Version Description of the suggestion: Section 5.7 Obligations of a Creditor Bank of both SDD Rulebooks contains the following wording: A Creditor Bank shall oblige each of its Creditors, in accordance with the relevant requirements set out in the Rulebook: ( ) to use a form (underscore added) of Mandate which complies with the Rulebook The notion form here might be misinterpreted as a specific concrete format or template. Instead, it should be understood that the chosen mandate has to fulfil a set of requirements. Therefore the following rewording is proposed: ( ) to use a form of Mandate that complies with the set of requirements defined by the Rulebook 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: No impact 2. Impact on the interbank space: No impact 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): No impact 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: No impact this change suggestion does not relate to any change in the legal rules 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) Yes b. A variant (adding an alternative optional rule alongside an existing Rulebook element) No #29 SDD Core & B2B-EPC SPS WG-wording change on 'form of mandate' section of 3

117 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES NO YES YES YES YES #29 SDD Core & B2B-EPC SPS WG-wording change on 'form of mandate' section of 3

118 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: SEPA Payment Schemes Working Group (SPS WG) EPC Address: -- Contact details: Your reference: Scheme and document and version number: -- #30 EPC SEPA Credit Transfer Rulebook Version 7.1 EPC SEPA Direct Debit Core Rulebook Version 7.1 EPC SEPA Direct Debit Business to Business Rulebook Version 5.1 Request Date: For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

119 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): EPC SEPA Direct Debit Core Rulebook Version 8.0 EPC SEPA Direct Debit Business to Business Rulebook Version Description of the suggestion: In October 2013, the EPC published a clarification letter on electronic mandates to SEPA Direct Debit Scheme Participants (Letter EPC098-13) on the EPC public website. The clarification letter highlights that the signature methods as described in section 4.1 of the SDD Core and B2B Rulebooks are not exhaustive. SDD scheme participants may consider allowing continued usage of other legally binding methods of signature including those that were used under the local legacy scheme rules. With the publication of this letter, the current specification that only a qualified electronic signature can be used to sign an electronic mandate should be removed in the two SDD Rulebooks. The following deletions are suggested in the two SDD Rulebooks: Section 4.1: A Mandate may exist as a paper document which is physically signed by the Debtor. The paper mandate can be stored either as the original document or in any digitalised format subject to the national legal requirements. Alternatively, the Mandate may be an electronic document which is created and signed using a legally binding method of signature with a Qualified Electronic Signature agreed between the Creditor and the Creditor Bank. Section 7: Complete deletion of the definition Qualified Electronic Signature 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: No impact 2. Impact on the interbank space: No impact 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): No impact 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: No impact 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) YES b. A variant (adding an alternative optional rule alongside an existing Rulebook element) NO #30 SDD Core & B2B-EPC SPS WG-removal references to 'qualified electronic signature' v1.0 2 of 3

120 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? YES: SDD scheme participants can consider allowing the continued use of other legally binding methods of signature including those that were used under the local legacy scheme rules provided that they comply with the SEPA End-Date Regulation. No Yes Yes No Yes #30 SDD Core & B2B-EPC SPS WG-removal references to 'qualified electronic signature' v1.0 3 of 3

121 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: Address: Contact details: Your reference: Scheme and document and version number: Hans-Rainer van den Berg BITKOM e.v.* Albrechtstraße 10a, D Berlin Head of the SEPA Working Group BITKOM-B2B-02 SEPA BUSINESS TO BUSINESS DIRECT DEBIT SCHEME RULEBOOK EPC Version 5.0 Approved Date issued: 30 November 2012 Request Date: For information: *Remarks This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 The proposal is also supported by the following associations / company: Bundesverband des Deutschen Versandhandels e.v. (bvh) Taubenstraße (Am Gendarmenmarkt) Berlin Frau Ingmar Böckmann Bundesverband Deutscher Inkasso-Unternehmen e.v. Friedrichstr Berlin Herr Axel Schlicht Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

122 Bundesverband Deutscher Leasing-Unternehmen e.v. Markgrafenstr Berlin Frau Claudia Rautenberg Handelsverband Deutschland (HDE) e.v. Am Weidendamm 1A Berlin Herr Ulrich Binnebößel #38 SDD B2B-BITKOM-enhanced convenience of pre-notification 2 of 7

123 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): November Description of the suggestion: Enhanced Convenience of pre-notification for CORE-SDD For the benefit of customers (debtors) and corporates (creditors) the convenience of pre-notification should be enhanced and requirements on pre-notification should be simplified,. The pre-notification should be optional if agreed between the creditor and the debtor. The following simplifications are recommended sending of an additional pre-notification should not be mandatory when re-presenting a direct debit after a reject or return if the amount is reduced regarding the former pre-notification for direct debits with small amounts a pre-notification should not be mandatory No mandatory pre-notification for direct debits, which are combined into one direct debit from several already pre-notified single direct debits with same due date and mandate. Naming a period of up to 5 TARGET days for the collection date instead of a fixed due date. Change suggestion 1: For EPC Version 5.0 chapter 4.2 (Collections) is to be amended to: The Creditor must sends a Pre-notification (0) to the Debtor according to the time frame defined in Section Change suggestion 2: For EPC Version 5.0 chapter (Time Cycle) is to be amended to: The direct debit processes respect the following time-cycle rules: The Pre-notification must be sent by the Creditor at the latest 14 Calendar Days before the Due Date unless another time-line is agreed between the Debtor and the Creditor. The pre-notification is not mandatory if so agreed between debtor and creditor or for direct debits with small amounts if compliant with the national law. Sending of an additional pre-notification is not mandatory when re-presenting a direct debit after a reject or return if the amount is reduced regarding the former pre-notification (if compliant with the national law). Sending of a pre-notification for a direct debit is not mandatory, when combined into one direct debit from several already pre-notified single direct debits with the same due date or due date period and mandate (if compliant with the national law). Change suggestion 3: #38 SDD B2B-BITKOM-enhanced convenience of pre-notification 3 of 7

124 For EPC Version 5.0 chapter (Collection of the Direct Debit Transaction (PR- 04)) is to be amended to: Collection of the Direct Debit Transaction (PR-04) PT Creditor to Debtor Pre-notification Description Prior to the sending of the Collection to the Creditor Bank, the Creditor notifies the Debtor of the amount and due date or due period. This notification may be sent together with or as part of other commercial documents (e.g. an invoice) or separately. One or more pre-notifications can be used to notify one direct debit, if each pre-notification has the same due date or due period and the sum of the amounts of the pre-notifications equals or is smaller than the amount of the one direct debit. The Pre-notification could also include: The schedule of payments for a number of repetitive direct debits for an agreed period of time An individual advice of a Collection for collection on a specified Due Date or a specified due period, which must not exceed 5 TARGET days The Creditor and the Debtor may agree on another time-line for the sending of the prenotification. The pre-notification should be optional if agreed between the creditor and the debtor, if compliant with the national law. For direct debits with small amounts a prenotification should not be mandatory (if compliant with the national law). Sending of an additional pre-notification should not be mandatory when re-presenting a direct debit after a reject or return if the amount is reduced regarding the former pre-notification (if compliant with the national law.) for direct debits with small amounts a pre-notification should not be mandatory (if compliant with the national law.) Duration No limit. Closing day/time The Pre-notification must be sent by the Creditor at the latest 14 Calendar Days before the Due Date if necessary, unless another time-line is agreed between the Debtor and the Creditor. Rules applied: See Section 4.3 for the general time cycle of the direct debit process. PT Creditor Sends Collection Data to Creditor Bank, Including the Mandate-Related Information The Creditor is allowed to send the Collection to the Creditor Bank once the Mandate has been signed and when the Pre-notification, if nessecary, has been sent in time (see PT-04.02) to the Debtor. #38 SDD B2B-BITKOM-enhanced convenience of pre-notification 4 of 7

125 Change suggestion 4: For EPC Version 5.0 chapter 5.7. (Obligations of a Creditor Bank) is to be amended to: A Creditor Bank shall oblige each of its Creditors, in accordance with the relevant requirements set out in the Rulebook: to pre-notify its Debtors, if necessary, in relation to Collections it proposes to initiate in accordance with the relevant Mandate Reason: The customer (debtor) does not expect a pre-notification in case of - re-presented direct debits, - reduced amounts - small amounts - aggregated direct debits. The pre-notification should not be mandatory in these cases. Moreover, many business processes between customer and corporate do not require a fix due date. Therefor a period of 5 TARGET days for the due date should be allowed in the pre-notification. The customer does not expect an additional pre-notification for every transaction in case of periodic advance payments even if varying in amount based on a contract that assures a complete declaration of all costs, delivered goods and services at the end of a specified period, e.g. agreement about periodic advance payments for long-term consulting projects. Therefore an agreement about not pre-notifying should be an option. In another area the customer does not expect an additional pre-notification for goods and services consumed e.g. in a fitness center or beauty parlour varying in amount and date if based on a long-term contract and an agreement between debtor and creditor. As a measure of cost savings public authorities should be allowed to declare the amount of taxes or charges by publishing the computations of contributions by public announcement as a substitute for individual pre-notification. 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: The change will improve the scheme 2. Impact on the interbank space: no impact 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): no impact #38 SDD B2B-BITKOM-enhanced convenience of pre-notification 5 of 7

126 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: 5. no impact 6. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) #38 SDD B2B-BITKOM-enhanced convenience of pre-notification 6 of 7

127 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? yes no yes yes yes yes #38 SDD B2B-BITKOM-enhanced convenience of pre-notification 7 of 7

128 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: Address: Contact details: Your reference: Scheme and document and version number: Hans-Rainer van den Berg BITKOM e.v. Albrechtstraße 10a, D Berlin Head of the SEPA Working Group BITKOM-B2B-04 SEPA BUSINESS TO BUSINESS DIRECT DEBIT SCHEME RULEBOOK EPC Version 5.0 Approved Date issued: 30 November 2012 Request Date: For information: *Remarks This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 The proposal is also supported by the following associations / company: Bundesverband Deutscher Inkasso-Unternehmen e.v. Friedrichstr Berlin Herr Axel Schlicht Bundesverband des Deutschen Versandhandels e.v. (bvh) Taubenstraße (Am Gendarmenmarkt) Berlin Frau Ingmar Böckmann Conseil Européen des Paiements AISBL Cours Saint-Michel 30A, B-1040 Brussels Tel: Fax: Enterprise N secretariat@epc-cep.eu

129 Handelsverband Deutschland (HDE) e.v. Am Weidendamm 1A Berlin Herr Ulrich Binnebößel #39 SDD B2B-BITKOM-blanks in the unique mandate reference (AT-01) 2 of 4

130 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): November Description of the suggestion: No consideration of blanks in the unique mandate reference (AT-01) Reason: It is not possible to identify leading and following blanks as well as the number of blanks on the paper mandate. If the payer wants to refuse a SDD, he needs to specify the mandate ID. If the blanks are considered, the debtors rights would be ineffective. There is no impact on the ISO20022 standard. Only the method for the interpretation of the unique mandate reference should be amended. This change of the implementation guideline would be analogue with the change in chapter of the Implementation guideline of 1 November 2010 (Version 3.0 Approved EPC301-07). Here the rule was added that the Mandate Identification (AT-01 Unique Mandate Reference) is case in-sensitive. Change suggestion 1: For EPC (Chapter 1.5.3) and EPC (Chapter 1.5.3) is to be amended: Mandate Identification (AT-01 Unique Mandate Reference) This data element is case and space insensitive. For example: Mandate Identification 123AAa45678, 123aaA45678, 123aaa45678 and, 123AAA45678, 123 AAa45678, 123 AAa45678 and 123 AAa shall be considered identical. 1.3 Wherever possible, please indicate: 1. Impact on the Scheme in general: The change will improve the scheme 2. Impact on the interbank space: The algorithm for checking the mandate reference needs to be updated. 3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other standards): There is no impact on the ISO standard. The Format Rule in the Implementation Guidelines has to be changed. 4. Impact on the legal rules as defined in chapter 5 of the EPC SEPA Scheme Rulebooks: no impact 5. The nature of the suggestion: a. A change (deleting or replacing an existing Rulebook element by a new one) A change of the Implementation Guidelines #39 SDD B2B-BITKOM-blanks in the unique mandate reference (AT-01) 3 of 4

131 2 Elements for evaluation The submitting party is requested to give an appropriate answer to each of these questions with sufficient detail to allow the EPC to make an evaluation of the suggestion submitted. Is the suggestion a case for SEPA wide acceptance? Is the suggestion underpinned by a cost-benefit analysis? Does the change fit in the strategic objectives for SEPA? Do you consider that the implementation of the change resulting from the acceptance of the suggestion is feasible? Do you consider that the suggestion does not impede SEPA-wide interoperability? Do you consider that the suggestion is in the scope of the scheme involved? yes no yes yes yes yes #39 SDD B2B-BITKOM-blanks in the unique mandate reference (AT-01) 4 of 4

132 Doc: EPC September 2013 (Version 1.0) EPC Template for proposing a suggestion for a change in a SEPA Payment Scheme Responses by to: change-request.epc-scheme@epc-cep.eu by 28 February 2014 Name of contributor: Organisation: Address: Contact details: Your reference: Scheme and document and version number: Hans-Rainer van den Berg BITKOM e.v. Albrechtstraße 10a, D Berlin Head of the SEPA Working Group BITKOM-B2B-06 SEPA BUSINESS TO BUSINESS DIRECT DEBIT SCHEME RULEBOOK EPC Version 5.0 Approved Date issued: 30 November 2012 Request Date: For information: This template is provided by EPC to allow any person or organisation to submit a suggestion for making a change to the SEPA Schemes in accordance with the rules set out in the document SEPA Scheme Management Internal Rules (SMIRs) available on the EPC Website: nts_id=535 #40 SDD B2B-BITKOM-Clarifications for use of SDD collection sequence type and amendment indicator 1 of 12

133 1 GENERAL DESCRIPTION OF THE SUGGESTION 1.1 Suggested launch date (if any): November Description of the suggestion: The Scheme caters for both recurrent and one-off Collections. Recurrent direct debits are those where the authorisation by the Debtor is used for regular direct debits initiated by the Creditor. One-off direct debits are those where the authorisation is given once by the Debtor to collect only one single direct debit, an authorisation which cannot be used for any subsequent transaction. The following suggestion is only in respect of the recurrent direct debits. The sequence type can be - FRST: the first of a recurrent series of direct debits - LAST: the last of a recurrent series of direct debits - RCUR: not the first and not the last direct debit of a recurrent series of direct debits A first of a recurrent series of direct debits can be cancelled, rejected, returned, refused, refunded or reversed. The question arising is if the next direct debit is to be processed as a FRST - direct debit or as a RCUR-direct debit. Do other rules apply, if - after the FRST -direct debit other RCUR -direct debits were processed - and, if so, the FRST -direct debit and/or a part of the RCUR -direct debits were cancelled, rejected, returned, refused, refunded or reversed. Neither the rulebook nor the implementation guidelines gives a clear answer. The Clarification Paper SEPA Credit Transfer and SEPA Direct Debit of 16 May 2013 provides vague answers to some examples. Therefor an extensive guideline for the sequence type is required. The sequence type can be - FRST: The purpose of this type is o to notify that a new SEPA mandate was issued. Once notified the sequence type FRST is not allowed for the following direct debits. An exception is if the debtor changed his bank (see next point) o to notify that the debtor changed his bank. Has this been notified the sequence type FRST is not allowed for the following direct debits. - LAST: to notify that the mandate will be cancelled after processing this direct debit. - RCUR: to mark all the direct debits that are not a FRST - or a LAST direct debit. It is to be determined in respect to R-transaction if the notification was successful. The notification is designated to the debtor and/or the debtor s bank. Therefore it is obvious the notification was not successful if the R-transaction was initiated by the creditor s bank or the CSM and that the direct debit didn t reach either the debtor or the debtor s bank. #40 SDD B2B-BITKOM-Clarifications for use of SDD collection sequence type and amendment indicator 2 of 12

134 If the FRST -direct debit reaches the bank and then an R-Transaction is initiated, was the notification in this case successful? Is there a difference if the R-transaction is initiated before or after settlement? Is there a difference regarding the code of R-transaction? Can the notification of a new mandate or the change of the debtor bank be executed by an accepted RCUR -direct debit if the FRST -direct debit is cancelled, rejected, returned, refused, refunded or reversed? Clear rules need to be implemented in the rulebooks. Otherwise it is to fear that the debtor banks apply differing, unequal standards. This Change request was made in 2012 but it was not open for commentary. Only select elements were addressed in the Clarification Paper SEPA Credit Transfer and SEPA Direct Debit issued 16 May 2013 (EPC348-12). The following functions as a possible solution: The notification of a new mandate will be given if - there is no R-Transaction for the direct debit with the sequence type FRST or - the direct debit with the sequence type FRST was cancelled by the creditor or the creditors s bank with one of the following cancelation reasons: <list of reasons> or - the direct debit with the sequence type FRST was rejected by the debtor s bank with one of the following rejection reasons: <list of reasons> or - the direct debit with the sequence type FRST was refused by the debtor with one of the following refusal reasons: <list of reasons> or - the direct debit with the sequence type FRST was returned by the debtor s bank with one of the following return reasons: <list of reasons> or - the direct debit with the sequence type FRST was refunded by the debtor with one of the following refund reasons: <list of reasons> or - the direct debit with the sequence type FRST was reversed by the creditor with one of the following reversal reasons: <list of reasons> or - the direct debit with the sequence type FRST was reversed by the creditor s bank with one of the following reversal reasons: <list of reasons> or - if there is no R-Transaction for a direct debit with the sequence type RCUR following the direct debit with the sequence type FRST or - there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type RCUR was cancelled by the creditor or the creditors s bank with one of the following cancelation reasons: <list of reasons> or - there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type #40 SDD B2B-BITKOM-Clarifications for use of SDD collection sequence type and amendment indicator 3 of 12

135 RCUR was rejected by the debtor s bank with one of the following rejection reasons: <list of reasons> or - there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type RCUR was refused by the debtor with one of the following refusal reasons: <list of reasons> or - there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type RCUR was returned by the debtor s bank with one of the following return reasons: <list of reasons> or - there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type RCUR was refunded by the debtor with one of the following refund reasons: <list of reasons> or - there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type RCUR was reversed by the creditor with one of the following reversal reasons: <list of reasons> or o there is one direct debit with the sequence type RCUR following the direct debit with the sequence type FRST and the direct debit with the sequence type RCUR was reversed by the creditor s bank with one of the following reversal reasons: <list of reasons> Referring to the Clarification Paper SEPA Credit Transfer and SEPA Direct Debit of 16 May 2013 the following conclusions can be made: The notification of a new mandate will be given if #40 SDD B2B-BITKOM-Clarifications for use of SDD collection sequence type and amendment indicator 4 of 12