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Bank of England publishes discussion paper on innovations in money and payments

On 30 July 2024, the Bank of England (BoE) published a discussion paper setting out its approach to innovations in money and payments (Discussion Paper). In the Discussion Paper, the BoE sets out its current view on...more

APP fraud: UK PSR compliance / monitoring requirements and consumer comms guidance for October 2024

The Payment Systems Regulator (PSR) has published a policy statement (PS24/3) on compliance and monitoring under the Faster Payments System (FPS) APP fraud mandatory reimbursement requirement. The PSR has rowed back on some...more

Big Tech and digital wallets: UK PSR and FCA publish call for information

The Payment Systems Regulator (PSR) and the Financial Conduct Authority (FCA) have launched a joint call for information on the opportunities and risks of digital wallets for people and businesses. This comes as recent data...more

UK retail conduct requirements: FCA launches Call for Input following introduction of Consumer Duty

Coinciding with the publication of its first report on how it has taken forward its new secondary UK competitiveness and economic growth objective, the FCA has published a Call for Input (CfI) on how far it may be appropriate...more

UK FCA publishes key findings on tackling money mule activities

The FCA has published the key findings from its multi-firm review of payment account providers’ systems and controls against money mule activity (ie where someone is recruited by criminals to move illegally obtained money)....more

UK “de-banking”: Latest UK government and FCA developments

Following the publication in July 2023 of a policy statement on payment service contract termination rules and freedom of expression, HM Treasury (HMT) has now published a further statement on implementation, timings and next...more

Evolution not revolution: European Commission publishes financial data access and payments package

As part of the European Commission’s 2020 Retail Payments Strategy and following its 2022 review of PSD2 and related consultations, it has published legislative proposals to improve the functioning of PSD2. The first is for a...more

UK FCA consults on changes to create stronger framework to support borrowers in financial difficulty

As previously referred to by the FCA (for example in its 2023/24 Business Plan) and following its Borrowers in Financial Difficulty (BiFD) project findings, it has launched a consultation setting out how it plans to...more

EU Payment Accounts Directive: Commission review mainly positive but improved data collection needed

The European Commission has published its long-delayed report to the European Parliament and Council of the EU on the application of the Payment Accounts Directive (PAD). The findings are generally positive and no legislative...more

UK Consumer Duty: FCA outlines expectations on fair value assessments as July deadline looms

In a speech marking less than three months until the first Consumer Duty implementation deadline, the FCA has warned that firms can expect swift action if they ignore the Duty or pose the most harm to consumers. As part of...more

Global Payments Newsletter, April 2023

Key developments of interest over the last month include: the UK FCA’s publication of a portfolio letter to payments and e-money firms; the U.S. Federal Reserve announcing the July 2023 launch of its FedNow Service; and...more

UK FCA overdrafts remedies: Positive findings tempered by cost of living and upcoming Consumer Duty

The FCA’s evaluation of its 2019 personal current account (PCA) overdraft rule changes - introduced as part of its High-Cost Credit Review - paints a largely positive picture in terms of good consumer outcomes. However, the...more

Open Banking: JROC recommendations on next phase aim to keep UK ahead of the pack

The Joint Regulatory Oversight Committee (JROC), co-chaired by the FCA and the Payment Systems Regulator (PSR) and with HM Treasury (HMT) and the Competition and Markets Authority (CMA) as the other members, has published its...more

Cost of living crisis and financial services: what’s the impact in the UK and Ireland?

As part of the Hogan Lovells FinTech Fundamentals webinar series, on 22 March 2023 Financial Services Regulatory senior associate Jen Staniforth hosted a thought provoking panel discussion on the impact of the cost of living...more

UK FCA portfolio letter to payments firms: compliance with safeguarding is ‘top priority’

The FCA has published a Portfolio letter setting out its priorities for payments and e-money firms amidst tightening economic conditions and the cost-of-living crisis. Among the three outcomes that it has set for firms in...more

Global Payments Newsletter, February/March 2023

Key developments of interest over the last two months include: the Central Bank of Ireland publishing a Dear CEO letter to the payments industry; the Bank of England and HM Treasury launching a consultation on a model for a...more

UK Consumer Duty: FCA publishes third set of portfolio letters to help firms with implementation

On 3 March 2023, the FCA published its third batch of portfolio letters setting out its expectations for firms implementing the Consumer Duty. We covered the previous two sets of letters in our Engage articles of 9 and 28...more

UK Financial Services Regulatory Initiatives Forum publishes sixth edition of Grid

The eagerly awaited sixth edition of the Financial Services Regulatory Initiatives Grid has been published by the Financial Services Regulatory Initiatives Forum. The delay to its publication (originally expected in November...more

Consumer Duty: navigating the Consumer Understanding Outcome

Under the new Consumer Understanding Outcome, firms in scope of the Consumer Duty must support retail customer understanding so that all communications meet the information needs of retail customers; are likely to be...more

Financial Institutions Horizons 2023

The outlook for 2023 looks uncertain, following another tumultuous year. The collapse of a number of large cryptocurrency exchanges has shone another spotlight on the digital asset market. The financial system’s resilience...more

Buy-Now Pay-Later: UK government consults on draft legislation

The government is consulting on proposed draft legislation that will bring BNPL within the FCA’s regulatory perimeter. Whilst a proportionate approach may be evident in the tailoring of pre-contractual information...more

Implementing UK Consumer Duty: Prioritisation, delivering real change, and teamwork are key

The FCA has published its findings from its review of the Consumer Duty implementation plans of around 60 of the largest retail financial services firms who have fixed FCA supervisory teams. It highlights effective...more

Global Payments Newsletter, January 2023

Key developments of interest over the last month include: the UK Treasury publishing a review and call for evidence on the Payment Services Regulations 2017 and a post-implementation review of the Payment Card Interchange Fee...more

UK government reviews Payment Services Regulations and Payment Card Interchange Fee Regulations

HM Treasury has published a review and call for evidence on the Payment Services Regulations 2017, as well as the outcome of a post-implementation review of the Payment Card Interchange Fee Regulations 2015. Both...more

Global Payments Newsletter, December 2022

Key developments of interest over the last month include: the UK government announcing a package of financial services regulatory reforms (the “Edinburgh Reforms”) to drive growth and competitiveness in the sector; continued...more

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