Policy submission

HM Treasury Payments Regulation and the Systemic Perimeter Consultation and Call for Evidence - Which? response

Which? response to the Government's consultation supporting the need to broaden the threshold for systemic actors to include entities throughout the payment journey and asking the Government to carry out a review of consumer protections for different payment methods, including considering whether the list of designated payment systems should be extended
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Summary

  • Which? supports the broadening of the threshold for systemic actors to include entities throughout the payment journey.
  • We support use of the model set out as part of the Financial Services & Markets Act 2000 (FSMA approach) to enable regulators to be more agile and responsive.
  • The Senior Managers & Certification Regime (SM&CR) should be extended to include payments and e-money.
  • We support the proposals for the Payment Systems Regulator (PSR), particularly the removal of the “primary purpose” requirement for designated payment systems.
  • We want the Government to carry out a review of consumer protections for different payment methods, including considering whether the list of designated payment systems should be extended.