DOM2009 to SDD migration principles, proposal to the involved creditors (PSU)

Transcription

1 DOM2009 to migration principles, proposal to the involved creditors (PSU) Deliverable n 2 Assist the migration from the Luxembourg Direct Debit (DOM2009) to the European SEPA Direct Debit schemes, & V1.2 Luxembourg migrates to SEPA direct debit 27 h September 2012

2 Prologue of the presentation : the migration from the National direct debit payment instrument (DOM2009) to the European SEPA Direct Debit schemes () in Luxembourg 1 February 2014 is set as the end-date for national payment schemes (credit transfers and direct debits) by the European Regulation n 260/2012, Launch of SEPA Direct Debit () for domestic payments by October 2012, The Luxembourg banking community (through the ABBL) proposes a migration process for Domiciliation nationale (DOM2009) and emphasizes the following key points: Existing mandates remain valid for, Creditor choice to migrate either to or, Validation service for legacy mandates, Usage of standardised mandate formula. Page 2

3 Agenda Introduction to SEPA From the Debtor to the Creditor Flow The Creditor decision process The migration Contacts Annex & References Page 3

4 Introduction to SEPA 4 questions to understand SEPA in Luxembourg 1 Who is concerned by SEPA? 2 What is SEPA? 3 Why do you have to act now? 4 When has it started? Page 4

5 1 Introduction to SEPA Who is concerned by SEPA? Banks A Creditor Bank, also known as Payment Service Provider (PSP) that provides a euro payment account. A Debtor Bank also known as a Payment Service Provider (PSP) that provides a euro payment account. Creditors A Creditor (seller) who is a Payment Service User (PSU) that provides a service and/or a product to the Debtor and who is the beneficiary of the payment. Debtors A Debtor (buyer) who is also a Payment Service User (PSU) that buys a service and/or a product from a Creditor and who is the payer. Page 5

6 2 Introduction to SEPA What is SEPA? Harmonization of euro payments in Luxembourg Subjects Past Future Payment Instruments and Schemes National payment instruments (LIPS-Net, DOM2009,...) SEPA Direct Debit () SEPA Credit Transfer (SCT) Payment Standards and format National payment standards (National Bank account number, DOM2009 mandate,...) [ BIC (Bank Identifier Code) ] IBAN (International Bank Account Number) Harmonized data elements based on ISO XML formats Harmonized rules (mandate, collection, R-transactions) Page 6

7 2 Introduction to SEPA What is SEPA? Harmonization of Direct Debit payment instruments What is a SEPA Direct Debit payment? A transfer in euro initiated by the Creditor (seller) via his bank. Direct debits are often used by Creditors for recurring payments, such as utility bills. They require a pre-authorisation ( mandate ) from the Debtor (buyer). SEPA Direct Debits may also be used for one-off payments. In this case, the Debtor authorises an individual payment. 2 types of SEPA Direct Debit (): The allows a Creditor to collect funds from a Debtor's account, if a signed mandate has been granted by the Debtor (consumer or non-consumer) to the Creditor. The Debtor benefits from an unconditional refund right during 8 weeks after the date of debit from the account of the Debtor. The Scheme enables Creditors to collect funds through direct debit. The payment is final and there is no refund right for the Debtors (non-consumers). features: SEPA-wide reachability, Covers both recurrent and one-off payments in euro, IBAN and BIC are used as account and bank identifiers all over the SEPA zone, Rules for handling payment collections and R-transactions are homogenous. Page 7 Source : European Central Bank

8 3 Introduction to SEPA Why do you have to act now? The EU Regulation EC 260/2012 (End-date) came into force on 31 March 2012 and establishes: Art. 3 Reachability obligations for PSPs with regard to credit transfers (CT) and direct debits (DD) Art. 4 Conditions for CT and DD schemes and technical interoperability requirements for retail payment systems Art. 5 Art. 6 Requirements for PSPs and/or PSUs with regard to the use and/or provision of payment account identifiers and BIC, message formats, data elements, mandate-related information and consent. Elimination of the BIC in the PSU-to-PSU and PSU-to-PSP space (national: 2014 / cross-border: 2016) Consumer protection obligations for PSPs with regard to DD End-dates for CT and DD that do not comply with the technical requirements stipulated by the Regulation (1 February 2014 ) End-dates for interchange fees for DD Art. 7 Art. 9 Legacy DD mandates / authorisations and related refund conditions will continue to be valid PSUs will not be allowed to specify in which Member State the payment account of their counterparty should be located, as long as the account is reachable Page 8 Source : Euro Banking Association

9 4 Introduction to SEPA When has it started? Single Payment Market Implementation Timeline euro as cash SEPA SEPA credit transfers (SCT) SEPA direct debits () PSD 11/2009 EC 64/2007 Payment Service Directive in effect Introduction of the euro Regulation / directive EPC SEPA Schemes Implementation date in Lux EMD Review of PSD EC 110/ nd E-money Directive in effect 05/ /2012 EC 260/2012 Reg; on technical and business requirements for CTs and DDs in euro in effect END-DATE REGULATION 01/2008 Luxembourg SCT 10/2012 Luxembourg Page 9

10 Agenda Introduction to SEPA From the Debtor to the Creditor Flow The Creditor decision process The migration Contacts Annex & References Page 10

11 From the Debtor to the Creditor Flow "AS-IS" National mandate flow of DOM2009 using the DMF (Debtor Flow) Creditor sends a mandate to be completed by the debtor a PSUs Buyer (Debtor) b Seller (Creditor) Debtor completes, signs and sends the mandate back Debtor asks his a bank for a Debtor bank sends the b mandate, mandate to the creditor completes, signs and sends it back c Creditor sends the original mandate to the debtor's PSP PSPs Debtor bank Creditor bank ORIGINAL Debtor's PSP keeps the original paper mandate d DMF Page 11

12 From the Debtor to the Creditor Flow "AS-IS" National collection and R-transaction flows of DOM2009 using the DMF PSUs Buyer (Debtor) Seller (Creditor) Refund (Contestation du prélèvement)* (Instruction de Prélèvement)* DOM-2000/ DOM-Allégé Bilateral DOM2009 or PSPs Debtor bank CETREL DOM2009 Creditor bank Refund MT207 Page 12 Message format DOM-2000/ DOM-Allégé *Nomenclature Documentation Technique Créancier CETREL Initiation of collection Refund Reporting

13 From the Debtor to the Creditor Flow TO-BE/NEW mandate flow of using the CMF (Creditor Flow) Creditor sends a mandate to be completed by the debtor PSUs Buyer (Debtor) b a Seller (Creditor) C Only for mandate, Debtor sends information to his bank. Debtor completes, signs and sends the mandate back ORIGINAL Creditor keeps the original mandate d PSPs Debtor bank Creditor bank CMF Page 13

14 From the Debtor to the Creditor Flow TO-BE/NEW format & Information required for the mandate in a CMF A) New Format of the message XML ISO format under, The DOM2000/ DOM-Allégé formats will progressively disappear until February B) Information required on the mandate a mandatory clear heading to be completed by the Creditor: : SEPA Direct Debit : SEPA Business to Business Direct Debit Compared to DOM2009, 2 additional Information are required ( & ) mandate attributes Ref* DOM2009 to be completed by Unique reference Creditor Name of the Debtor (line 1) Debtor Address of the Debtor (line 2) Debtor Postal code/city of the Debtor (line 3) Debtor Debtor s country of residence (line 4) Debtor Debtor s account number IBAN (line 5) Debtor The BIC code of the Debtor Bank (line 6) Debtor Creditor company name (line 7) Creditor Creditor s identifier (line 8) Creditor Creditor s address street and number (line 9) Creditor Creditor s postal code and city (line 10) Creditor Country of the Creditor (line 11) Creditor Type of payment (line 12) X Creditor Signature place and time (line 13) X Debtor Signature(s) Debtor The document must contain the field identifiers, followed by the necessary blank space in which to fill the required data items *Content of a similar Ref might differ from DOM2009 to mandate Page 14

15 From the Debtor to the Creditor Flow TO-BE/NEW collection flows of ( & ) PSUs Buyer (Debtor) Seller (Creditor) Collection Reporting pain.008 PSPs Debtor bank pacs.003 Collection Creditor bank Collection Reporting Page 15

16 From the Debtor to the Creditor Flow TO-BE/NEW R-transaction flows of ( & ) PSUs Buyer (Debtor) Seller (Creditor) R Refusal R Refund R R Reversal** Revocation Reporting* PSPs pain.007 pain.007 pain.002 Debtor bank Reversal** pacs.007 R Reject pacs.002 R Return pacs.004 camt.056 Request for cancellation R R Creditor bank * Only if R-transaction occurs ** The reversal can be initiated by the Creditor or the Creditor Bank. The Rulebooks ( & ) do not oblige Creditor Banks to offer the Reversal facility to the Creditors. R R R R-transaction applicable in & R-transaction applicable in only R-transaction part of bilateral agreement Reporting Optional Before due date Page 16 After due date

17 From the Debtor to the Creditor Flow TO-BE/NEW Collection messages required in the CMF Signed One-off OOFF First FRST End of validity Migrated legacy First Migration FRST Recurrent RCUR Last FNAL If no Recurrent is presented, the mandate stops being valid after 36 months. If no Last is presented, the mandate stops being valid after 36 months. Single collection: The One-off collection is a one time direct debit from a mandate agreed under scheme. Regular collections: The First collection is the first direct debit using a mandate. The First Migration is the first direct debit using the scheme of a DOM2009 mandate that migrates to. The Recurrent collection is possible after the First or the First Migration direct debit. The Last is the last direct debit of a collection and automatically induces the end of mandate validity after the debit of the amount on the debtor account. Page 17

18 From the Debtor to the Creditor Flow TO-BE/NEW Comparative Timeline of the different payment instruments D = payment day DOM2009 D-7 Payment pre-advice to CETREL D-2 17:30 Collection R D-1 02:00 Refusal by the debtor or CETREL R D+8W Refund to the debtor D-14 Payment pre-advice D-5 8:00 One-off collection - Initial collection D-2 8:00 Recurrent collection R R D+5 Return by the debtor bank Reversal by the creditor R D+8W Refund to the debtor R Rejects, Refusals, Revocations, Request for cancellation D-14 Payment pre-advice D-1 9:00 One-off collection- First collection Recurrent collection R D+2 9:00 Return by the debtor bank R D+5 Reversal by the creditor No Refund R Rejects, Refusals, Revocations, Request for cancellation Page 18

19 From the Debtor to the Creditor Flow TO-BE/MIGRATION" flow of the migrated DOM2009 mandates to using the CMF (Creditor Flow) Creditor manages the mandate related information (MRI) PSUs Buyer (Debtor) MRI Seller (Creditor) 1 Migration process of existing paper mandates (Original) from DMF to CMF (MRI) 3 4 First Migration Reporting Bilateral 2 Confirmation of legacy mandates pain.008 or PSPs Debtor bank CETREL Creditor bank pacs.003 Debtor's PSP keeps the original paper mandate ORIGINAL Page 19 1 Steps Initiation of Collection Data Confirmation Reporting Migration

20 From the Debtor to the Creditor Flow Controls of the FIRST Migration Payment status status Next file to be sent 3 checks positive Control B OK Control C OK NOK AG01 Collection executed Collection not executed migrated migrated Next file: RCUR Next file: FIRST FIRST MIG Control A (3checks): Control A One attribute wrong And/or Wrong scheme 2 attributes wrong NEW NOK NOK Control C OK NOK MD02 MD02 Collection not executed Collection not executed Collection executed Collection not executed not migrated not migrated No migrated mandate No migrated mandate Next file: FIRST MIG Next file: FIRST MIG Next file: RCUR Next file: FIRST On 2 attributes: 2.31 EndToEndIdentification with the word MIGRATION in capital letters 2.49 DateOfSignature with exactly On the scheme: FIRST MIG presented in the right scheme ( or ) according to the contract signed between parties Control B: Link with Legacy using information mentioned on the FIRST MIG OK = Link established NOK = Link not established Control C: Settlement OK = account debited correctly NOK =account not debited due to a problem (account blocked, insufficient funds...) REMARKS: 1. The word MIGRATION of 2.31 indicates to the Debtor the change of the direct debit scheme 2. The date is not limited to the first collection but is reused in all other collections and gives a clear indication that the collection is made on the basis of a migrated mandate Page 20

21 From the Debtor to the Creditor Flow Contexts to manage during the migration to Payme ent instrument DOM 2009 (bi-lateral) AS-IS National MIGRATION NEW TO-BE SEPA During the migration phase from the national DOM2009 to the European schemes, Creditors have to manage different contexts separately: AS-IS : direct debit of DOM2009 scheme and agreement with CETREL TO-BE scenarios according to the procedures detailed in this document : MIGRATION to scheme of existing legacy mandates. collections based on SEPA mandates. MIGRATION to scheme of existing legacy mandates. collections based on SEPA mandates. Non migrated DOM 2009 Migrated DOM 2009 ( & ) Page 21

22 Agenda Introduction to SEPA From the Debtor to the Creditor Flow The Creditor decision process The migration Contacts Annex & References Page 22

23 The Creditor decision process 2 layers of decisions To help Creditors to carefully combine business characteristics and SEPA requirements Launch of the Creditor project 2 Decision to migrate existing mandates or to open new mandates? 1 Decision on possible scenarios? Page 23

24 1 The Creditor decision process Identify the possible schemes for your business... Type of Clients (PSD) instruments Migration Possible Schemes No Migration A Consumer CORE Decision? Migration B Creditor No Migration A Non-consumer Choice CORE Decision? Migration B Page 24 (optional scheme) No Migration Decision? Migration C D

25 1 The Creditor decision process... and combine them to identify the main scenarios Main scenarios Combinations of schemes 1. I = A The creditor decides to use only scheme, chooses not to migrate existing legacy DOM2009 mandates and to have his debtors sign new mandates 2. II = A + C The creditor decides to use & schemes, chooses not to migrate existing legacy DOM2009 mandates and to have his debtors sign new mandates 3. III = A + B The creditor decides to use only scheme for all direct debits. He chooses to migrate all or part of existing legacy DOM2009 mandates to and have part of his debtors sign new mandates. Page IV = A B C D The creditor decides to use & schemes for all direct debits. He chooses to migrate all or part of existing legacy DOM2009 mandates to or and have part of his debtors sign new mandates.

26 2 The Creditor decision process The decision to migrate mandates or not? The Migration of the legacy mandates is not an obligation! The Creditor decides whether he wants his existing debtors to sign new mandates or whether he wants to migrate his existing DOM2009 mandates. Balance of decisions Elements a creditor has to consider: Sign new mandates is costly and the business risk that a debtor doesn t want to sign a new mandate has to be evaluated. Migration Technical costs of migrating a legacy mandate vs No Migration Operational & Administrative costs of signing a new mandate Costs Migrate legacy mandate is only possible through a precise migration process that has been set-up by the banking community in order to lower the risks linked to the validity of the legacy mandate. Operational risks linked to mandate Migration and first collection vs Business and Operational risks linked to signature of a mandate Risks Creditor decision Page 26

27 The Creditor decision process Scenario n 1: Creditor s Internal Management with only I Seller (Creditor) Trade process Client Management New Display SEPA Amend Cancel CORE Initiation collection Invoice Management SEPA Standards Collection Management One-off First Launch collection R-transaction Recurrent Last CORE R-transactions Bank Account Management Key points Start collecting funds via well before 02/2014 Sign a creditor contract with one or several creditor banks Manage to change from DOM2009 message to message Have existing debtors sign new mandates Send collections directly to the creditor bank(s) instead of to CETREL Display New BIC/ IBAN Cancel Change Page 27

28 The Creditor decision process Scenario n 2: Creditor s Internal Management with & II Client Management New Display SEPA Amend Seller (Creditor) Trade process (optional) Cancel CORE Initiation collection Invoice Management SEPA Standards Collection Management One-off First Launch collection R-transaction Recurrent Bank Account Management (optional) Last CORE R-transactions Key points Start collecting funds via well before 02/2014 Sign a & creditor contract with one or several creditor banks Manage to change from DOM2009 message to & messages according to the Rulebooks Have existing debtors sign new or mandates Send collections directly to the creditor bank(s) instead of to CETREL Display New BIC/ IBAN Cancel Change Page 28

29 The Creditor decision process Scenario n 3: Creditor s Internal Management with & III «New» «Mig» Trade process Client Management New Migration Display SEPA Amend Display Migrated Amend Cancel Cancel Seller (Creditor) CORE Initiation collection Invoice Management SEPA Standards Collection Management One-off Launch collection R-transaction CORE R-transactions Bank Account Management New First Mig First Recurrent Display BIC/ IBAN Change Last Cancel Key points Ask confirmation of existing legacy mandates to debtor banks Start collecting funds via well before 02/2014 Sign a creditor contract with one or several creditor banks Decide whether to keep the existing mandate references and encapsulate the current unique Creditor ID Manage to change from DOM2009 message to message Have part of existing debtors sign new mandates Send collections directly to the creditor bank(s) instead of to CETREL Page 29

30 The Creditor decision process Scenario n 4 : Creditor s Internal Management with New &, & IV «New» «Mig» Client Management New Migration Display SEPA Amend Display Migrated Amend Seller (Creditor) Trade process Initiation collection (optional) Cancel Cancel CORE Invoice Management SEPA Standards Collection Management One-off Launch collection optional) CORE R-transactions Bank Account Management New First Mig First R-transaction Recurrent Display BIC/ IBAN Change Last Cancel Key points Ask confirmation of existing legacy mandates to debtor banks Start collecting funds via well before 02/2014 Sign a & creditor contract with one or several creditor banks Decide whether to keep the existing mandate references and encapsulate the current unique Creditor ID Manage to change from DOM2009 message to & messages according to the Rulebooks Have part of existing debtors sign new or mandates Send collections directly to the creditor bank(s) instead of to CETREL Page 30

31 Agenda Introduction to SEPA From the Debtor to the Creditor Flow The Creditor decision process The migration Contacts Annex & References Page 31

32 The Migration Migration Phases I II III IV Preparation Market information Migration Post-migration 01/09/ /10/ /02/ /01/2018 End of the national DOM2009 direct debit scheme Definition of the standard migration process for banks to move from DOM2009 to Consultation of creditors The banks actively deliver information towards the Luxembourg market about the new products Coexistence of the DOM2009 and the All newly signed mandates have to contain all required information The XML format is mandatory for all collections Creditors start the migration from the national DOM2009 direct debit scheme to the new SEPA schemes ( and ) No creation of DOM2009 collection files with due date after 01/02/2014 Use of a mandate containing all required information All direct debit collections must use schemes No more obligation for the debtor s bank to provide the legacy mandate of a migrated one. Page 32

33 The Migration Steps of the migration process Data preparation D C AT-01 E PSUs Buyer (Debtor) G Seller (Creditor) Request/ Answer D DOM 2009 H New contract(s) A AT-02 B F H PSPs Debtor bank bilateral or Creditor bank Request D D Answer CrId B CETREL DOM2009 ABBL AT-02 Page 33

34 The Migration Tasks of the Creditor during the migration Subject Description Contract/ A C D E G Creditor agrees a new creditor-contract with his bank. The creditor attributes to each mandate a unique mandate reference (AT-01 Unique Reference). This attribute AT-01 can be identical to the reference currently used by the creditor for DOM2009 direct debit Confirmation of existing (legacy) mandate is a requirement. Creditor has to inform the debtor about the migration. Following the rulebooks, the mandates, migrated or new, shall terminate in cases of "inactivity for 36 months without presentation of collection. Communication E F Creditor informs the debtors about the migration of existing DOM2009 direct debits to the new SEPA system. At the first collection of the SEPA direct debit, the creditor communicates via the collection initiation his new creditor identifier, the unique mandate number and the original DOM2009 references. Relations with banks/ CETREL B D H The creditor receives a new identifier (AT-02 Identifier of the Creditor in the European format) via his creditor-bank. If the creditor already possesses such an identifier, he can reuse it after validation by his creditor-bank. The identifier generated by the ABBL is unique. Regardless of the migration period, creditor requests confirmation of existing (legacy) mandate data accuracy from debtor-banks As the migration of the existing (legacy) mandates may be total or partial, a creditor may present either DOM2009 direct debits or European direct debits during the transition phase. Page 34

35 Agenda Introduction to SEPA From the Debtor to the Creditor Flow The Creditor decision process The migration Contacts Annex & References Page 35

36 Contacts List of LUISA banks (May 2012) Andbanc Luxembourg S.A. ABN AMRO Bank (Luxembourg) S.A. Banca Popolare Dell'Emilia Romagna Intl S.A. Banco Itaú Europa Luxembourg S.A. Bank of China (Luxembourg) S.A. Banque BCP S.A. Banque Carnegie Luxembourg S.A. Banque de Luxembourg S.A. Banque Delen Luxembourg Banque et Caisse d'epargne de l'etat Banque Havilland SA Luxembourg Banque Internationale à Luxembourg S.A. Banque LBLux S.A. Banque Privée Edmond de Rothschild Europe S.A. Banque Raiffeisen Banque Transatlantique Luxembourg S.A. BGL BNP Paribas S.A. BSI Luxembourg Citibank International plc, Luxembourg Branch Commerzbank International S.A. Compagnie de Banque Privée S.A. CREDEM International (LUX) SA Credit Suisse (Luxembourg) S.A., Private Banking DekaBank Deutsche Girozentrale Luxembourg S.A. Deutsche Postbank International S.A. DEXIA LDG Banque S.A. DNB Luxembourg S.A. DZ BANK International S.A. East-West United Bank S.A. EFG Bank (Luxembourg) SA Entreprise des Postes et Télécommunications Fortuna Banque S.C. Hauck & Aufhäuser Banquiers Luxembourg S.A. HSBC Private Bank (Luxembourg) S.A. HSBC Trinkaus & Burkhardt (international) S.A. HSH Nordbank Luxembourg Branch HSH Nordbank Securities S.A. Industrial and Commercial Bank of China Luxembourg S.A. ING Luxembourg KBL European Private Bankers S.A. Mediobanca International (Luxembourg) S.A. SMBC Nikko Bank (Luxembourg) S.A. La Française AM Private Bank Norddeutsche Landesbank Luxembourg S.A. Pictet & Cie (Europe) S.A. RBS Global Banking (Luxembourg) S.A. Sal. Oppenheim jr Cie. S.C.A. SEB - Skandinaviska Enskilda Banken S.A. Société Européenne de Banque Société Générale Bank and Trust SA Svenska Handelsbanken S.A. Luxembourg Swedbank S.A. UBI Banca International S.A. UBS (Luxembourg) SA Unicredit International Bank Luxembourg S.A. Van Lanschot Bankiers (Luxembourg) S.A. VP Bank Luxembourg S.A. Contacts Jean-Pierre Borsa Adviser Banking Technologies and Payments borsa@abbl.lu T Serge Wagener Head of Payments, ICT & Standardisation Committee s.wagener@bcee.lu T Jean Petry Vice-Head of Payments, ICT & Standardisation Committee jean.petry@bgl.lu T Jean Diederich Partner - Practice Leader «Payments» jean.diederich@kurtsalmon.com M Romuald Poos Manager romuald.poos@kurtsalmon.com M Pierre Dassonneville Consultant pierre.dassonneville@kurtsalmon.com T Page 36

37 Agenda Introduction to SEPA From the Debtor to the Creditor Flow The Creditor decision process The migration Contacts Annex & References Page 37

38 Annex: countries where SEPA will be implemented? Geographical Scope of SEPA Luxembourg SEPA countries SEPA Migration End-date Regulation provisions applicable to EPC SEPA Scheme Rules applicable to Eurozone in EU27 Non-EUR Member States in EU27 + EEA 3 (Iceland, Liechtenstein and Norway) Switzerland & Monaco euro credit transfers (CT) and direct debits (DD) euro CTs and DDs from 31 st October 2016 Not applicable euro CTs and DDs processed under a SEPA scheme by adhering PSPs (mandatory reachability for PSPs) euro CTs and DDs processed under a SEPA scheme by adhering PSPs (mandatory reachability for PSPs from 31 st Oct 2016) euro CTs & DDs processed under a SEPA scheme by adhering PSPs Luxembourg is fully concerned by the European Regulation 260/2012 for SEPA (no exception) DONE: -The national clearing system for credit transfers (LIPS-Net) was abolished in 2006 and replaced by a new fully SEPA compliant platform (STEP2). TO DO: -Luxembourg has to close down its national direct debit scheme (DOM2009) by and has to exclusively use SEPA Direct Debit scheme(s) after 1 February Creditors who want to migrate their legacy mandates, have to start the migration process as soon as possible. Page 38

39 References European Payment council: website, EPC Rulebooks 2012, Euro Banking association, SEPA & PSD, website, European Parliament Regulation: Regulation (EU) No 260/2012 of 14 March Technical and business requirements for credit transfers and direct debits in euro Regulation (EC) No 924/2009 of 16 September cross-border payments in the Community ABBL: SEPA Migration : from DOM-2009 to SEPA Direct Debit -.UGVKJszZ5cA XML Message for SEPA Direct Debit Initiation CETREL, Creditor technical documentation Page 39