HM Treasury consultation on 'A Streamlined Approach to Payment Systems Regulation' - Which? response

We make the following observations to inform HM Treasury’s activity as it takes forward plans to consolidate the PSR's functions in the FCA:

• The focus on consumer interests must be retained as a core objective of payments regulation. 
• The integration of the PSR into the FCA must deliver consumer benefits.
• The PSR has expertise and a dedicated focus on payment regulation. This must be maintained / replicated within the FCA. 
• To ensure adequate oversight of payments regulation, there is a need to establish clear lines of accountability to Parliament. 
• Application of the competitiveness and growth duty to payments must be only a secondary duty. 
• HM Treasury should revisit the core arguments which led to the creation of the PSR to ensure that its proposed approach does not inadvertently reintroduce the problems that the PSR was designed to solve.