The EMA responds to FCA Consultation on SME access to the Financial Ombudsman Service. EMA expresses concern about the FCA’s proposals to expand the list of eligible complainants to the Financial Ombudsman Service to include SMEs and guarantors. This is a substantial departure from existing practice, and is likely to have a considerable impact, particularly on smaller financial service providers in the payment services sector, where disputes are likely to be complex, and where the financial services provider may themselves be an SME.
A blog with the latest information on regulatory developments in the area of electronic money and innovative payments.
Dr Thaer Sabri, CEO of the EMA joined the regulatory panel at Open Banking: What does it really mean? conference on 11 April 2018 in London.
The Open Banking era has begun
Over the next few months, Britain’s largest banks will be required to make the account data of consenting customers available to approved rivals. As envisaged, the new regime will allow up-and-coming challenger banks and fintech businesses to compete on a more-or-less level playing field with existing financial services giants. It has the potential to alter radically the way that people interact with their finances and with financial services providers.
The purpose of this conference was to ascertain what should be ‘best practice’ in open banking. Sessions will cover:
|· The new regulatory environment
· Relative progress of the UK in open banking
· The bank/fintech interface
· Who controls payments?
· The European experience
· The impact of GDPR on open banking: opportunity or threat?
· The balance between fostering innovation and consumer protection
· Will open banking do enough for the financially vulnerable?
We are delighted that Imran Gulamhuseinwala, Trustee of the new Open Banking Implementation Entity will be giving the opening keynote address.
- Phil Andrew, Chief Executive, StepChange Charity
- Dr Louise Beaumont, Co-Chair, Open Bank Working Group
- Megan Caywood, Chief Platform Officer, Starling Bank
- Laura Coffey, Head of Fintech, TechCity
- Tony Craddock, Director General, Emerging Payments Association
- Mark Davison, Regional Director, Deposit Solutions
- Tom Fisher, Research Officer, Privacy International
- Imran Gulamhuseinwala, Trustee, Open Banking Implementation Entity
- James Kirkup, Director, Social Market Foundation
- Robert Kotlarz, Business Development Director, Significat
- Liz Oakes, Associate Partner, Mckinsey & Co
- Thaer Sabri, Chief Executive, Electronic Money Association
- Cliff Van Tonder, Executive Vice President for Partners and Alliances, EMEA, Avoka
- Michael Vroobel, Vice President Operations, Marketinvoice
- Aidene Walsh, Chief Executive, The Fair Banking Foundation
- James Whittle, Director of International Standards and Services, UK Payments Administration
- Stephen Dury, Head of New Business Models, Santander UK
Who should attend
Management in financial institutions (C Suite, Heads of Digital, Heads of Innovation, Heads of Marketing, Legal and Compliance) and fintech companies; Government and regulators; associations; legal, financial and professional advisers.
Standard fee: £595.00 or £476.00 + VAT (with discount) EMA code: OBANK1EMA
Fintech company fee: £75.00**
**applies to any company registered as an official company for less than 4 years at the date of the event, which is not a subsidiary or part of a group established for longer than this period and which offers a product and/or service usually classified as FinTech
Other booking options, mentioning code in either instance:
T: 01932 340115
FData Open Banking 2020-2030 Summit was held on 5 December 2017 in London.
Thaer Sabri , CEO of the EMA did join the panel on Open Banking – the story so far. This panel session did examine the big issues of open banking’s journey to the mainstream.
The open banking movement is not new. The fintech industry has, for over a decade and in many geographies, been pushing for the acceptance and embracing of third party applications in customer-facing financial services. From 2013, the shifting sands of policy, regulation and commercial requirements has altered the landscape and rate of change. Concerted backing from UK Treasury and policy support in the EU has changed the game.
Find out more about the conference here.
FinTech Connect Live, the EMA’s media partner, will take place between 6 & 7 December 2017 in Excel London
Combining the hustle and bustle of an exhibition featuring over 3000 visitors, and 200 exhibitors and partners from over 50 countries, FinTech Connect Live is the UK’s largest fintech event.
Playing host to 4 strategic conference sessions with inspirational case studies from around the world, a technology buyers theatre with 50 product demos, 12 educational workshops tackling practical fast growth challenges, and two full days of dedicated mentoring clinics for start up leaders, all brought to you from over 300 of the industries finest speakers, FinTech Connect Live is the ‘must have ticket’ for stakeholders from across the full fintech eco-system.
FinTech Connect Live provides a platform for all those attending to collaborate, differentiate, form connections, source solution, conduct and generate business with new, existing and upcoming fintech players in the market.
Get involved and find out more by visiting www.fintechconnectlive.com
FREE conference passes for EMA members
EMA offers 10 free conference passes to the members. Each member quest can use this link https://register.fintechconnectlive.com/srspricing to register for the free pass, using the invite code EMA100. Email firstname.lastname@example.org to confirm your registration.
10% discount after 10 free passes for EMA members are used up
Use this link http://www.fintechconnectlive.com/prices/ to buy the tickets at 10% discount, using the code EMA10.
Free visitor passes
Unlimited free visitor passes are available to the expo and all content on the expo floor.
Thaer Sabri, CEO of the EMA was a panelist at ACAMS Ireland Symposium, 19 October 2017 in Dublin, Ireland
Thaer took part in a panel discussion for the following session:
Eyes on the Forest, not on the Trees: Initiatives by the FinTech sector to identify and mitigate financial crime risks in their sector
· Identify key risk characteristics essential to both assessing Fintechs as customers and by FinTechs of their own business
· Increase working knowledge of CDD and monitoring techniques and technologies used by the FinTech sector
· Raise awareness around financial crime typologies specific to FinTechs and measures taken to mitigate these risks
For more information about the Symposium, click here.
EMA partners up with GLC Europe for 7th Annual Risk Management Forum
14-15 September, 2017 – Vienna, Austria
Risk management in banking had to overcome many changes in past years mainly in response to regulations that emerged from the global financial crisis. And there are still new challenges ahead, risk management will experience even more extensive change in the next decade.
The 7th Annual Risk Management Forum will provide opportunities for attendees to listen insights, guidelines, practices from regulatory bodies, leading industry associations and banks/central banks.
During the event participants will hear about the latest regulations, impacts of IFRS 9, Stress testing practices, developments in risk measurement and there are many more topic on board.
Discount code: ema_risk2017, which provides EMA members/ readers 20% discount
EMA partners up with Global Leading Conferences Europe for the 4th Annual European Payments Forum on 14-15 September 2017
Since last years’ European Payments Forum, many has changed within the industry, so it is time to organize our 4th Annual European Payments Forum, which will discuss both the changes and the future forecast of the topic. The FinTech war has just began, which will change the entire business and effect all stakeholders as well. Learn more about Blockchain from well-known topic experts and debate if banks are ready for the adoption.
Hear more about PSD 2 and its improvement on the payment experience from different point of view. What is the long and short term impact of this regulation and forest the regulatory landscape?
Join our Round Table Discussion to debate on banking (r)evolution and the technological innovations within the industry; do they disrupt or improve different processes?
Our aim is to bring together representatives from all different companies that are part of the payment industry in order to hear the most emerging issues they face and the solution to cope with these challenges.
EMA discount code: ema_payment2017, which provides EMA members/ readers 20% discount
Reflections on the UK Open Banking initiative
The UK Open Banking initiative is gathering pace, and is looking to deliver a first version of its read/write API specifications for testing early July 2017. This is welcome, and is a significant milestone in creating a single set of APIs that UK banks can adopt to enable the delivery of payment initiation (“PIS”) as well as account information services (“AIS) by authorised providers.
The benefits the initiative delivers are tempered however by the limited scope of the work, addressing consumer and SME bank current accounts, being restricted to UK Sterling currency, and being subject to a number of limitations to the technical design work, driven by the January 2018 Competition and Markets Authority (“CMA”) deployment deadline. Notably the solution only caters for single immediate payment transaction initiation – so a user is required to separately authorise each payment transaction with their PIS provider, and cannot for example authorise multiple transactions in a single step.This means that it continues to be easier to authorise a service provider to access funds through a credit or debit card than to initiate PIS payments. Secondly, the specifications require customer authentication to be undertaken directly with the ASPSP (Bank or PI or EMI), and does not provide for authentication to be undertaken through the PIS provider.
This means that a separate parallel communication channel has to be created and the user redirected to their ASPSP before returning to PIS platform to complete the transaction. This results in a poor customer experience, and one which restricts business models, limits the roles played by different parties in the value chain and can inhibit the deployment of innovative technical solutions.
The initiative does not cater for the AIS obligations relating to cards, to the needs of ‘decoupled’ card issuers (PSD2 Article 65) or to electronic money products.
The Open Banking Implementation Entity (IE) employs a steering group to advise the Trustee on decision making, but does not have decision making power. The objectives of the IE were set by the UK CMA and are directed at the 9 banks that were subjects of its competition review. The banks are also required to fund the work of the IE as part of the CMA remedy.
This has created a limitation that the Open Banking initiative is struggling to overcome. This would be merely a shortcoming had this not been the only significant ongoing UK based standardisation effort in this space. It is funded and run by the CMA 9 banks and required to deliver a CMA remedy, rather than a PSP wide (bank, PI and EMI) solution, taking into account the needs of the wider constituency. It furthermore falls far short of the requirements of PSD2, and would not therefore deliver PSD2 compliance for participating PSPs.
In creating the IE, the CMA has galvanised the UK payments community to work together to create a common standard. In setting out the terms of the remedy and the deliverables it may have inadvertently laid the ground for the next wave of anti-competitive behaviour. This could not have been contemplated by the CMA, but now that the impact is clearer, I believe that an adjustment is necessary.
The design of the specification is being driven by the CMA 9 banks, and other parties have little or no influence on the direction, decision making or priorities of the initiative. This is formalised in the terms of reference of the IE steering group which excludes a decision-making role for the body. Similarly, the Project Management Group and Technical Design Office, the two bodies with meaningful decision-making roles have only CMA 9 representation and do not provide for non-CMA 9 payments industry participation.In the context of the delivery of a CMA remedy for the 9 banks, this is entirely reasonable; it is run by them, funded by them and is operated for their benefit.
In the context of delivering a meaningful Open Banking initiative however, a PSD2 compliant industry solution that can benefit all PSPs, FinTech providers and the wider payment user community, this is entirely inappropriate.
There needs to be a change; and the change needs to happen while the different parties remain engaged within the current process. Quite soon alternative standardisation initiatives, driven by EU institutions that aim to deliver a more inclusive outcome, will start to deliver draft PIS API specifications and the restrictions of Open Banking will be set in stark contrast.
I believe the CMA needs to urgently review the initiative and consider whether it delivers the outcomes it had intended in the new world of AIS and PIS services, and not just for competition in ‘current bank accounts’. This is a world driven by use cases and technologies that mostly reside with non-bank participants, it promises significant user benefits and enhanced competition, but only if the entire value chain is able cooperate in its delivery.
In the immediate term, a binding commitment by Open Banking to broaden the scope of the work to include the interests of other payment industry participants is needed, accompanied by a change to corporate governance to give all participants a say in decision making. This is so, even if outcomes cannot be delivered until after January 2018.
Article written by Dr Thaer Sabri, CEO of the EMA published on LinkedIn Pulse
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E.N.G.’s Automotive Finance summit, 31 May – 1 June 2017, Crowne Plaza City Centre Hotel, Berlin
Thaer Sabri, CEO of the EMA was a speaker at Automotive Finance Summit 2017. The goal of the 9th annual event was to share insights and experience on driving profitability with modern, flexible financing solutions and adapting to today’s customer needs.
Find out more here.