On May 29, 2015 the Payment Systems Regulator initiated the information gathering phase of its review to develop final terms of reference on indirect access to payment systems and whether competition is working well for service-users. The key questions that the review seeks to address are set out in the Terms of Reference, and include exploring the gap between the services that indirect payment service providers want and what they receive, the factors which have led to a limited number of indirect access providers in the market and the options available to improve indirect access to interbank payment systems. The review covers the main interbank payment systems (Bacs, CHAPS, Cheque and Credit, Faster Payments Service and LINK). The Payment Systems Regulator expects to publish an interim report by January 2016 and a final report by May 2016.
What this means for you
Firms are advised to:
- consider how to influence the direction, focus and outcome of the review. Where firms are not required to participate, consider whether there is benefit to them in proactively engaging with the PSR.
- think strategically about what outcomes would be most advantageous for the firm and how to influence to best achieve those outcomes.
- think about whether it is appropriate to challenge requests for information, for example if the scope is too wide, or to rephrase questions to ensure the focus of any data-gathering is useful.
- be careful to mark selectively any sensitive written submissions to the PSR as confidential - the PSR will assume anything not marked confidential can be published and will not accept ‘blanket’ confidentiality claims.
- be aware that while confidential information is generally likely to be protected from disclosure, the PSR is empowered to share firms’ confidential information where it would assist it in performing its functions.