Lack of preparedness for the European Payment Services Directive

A recent IAMTN survey of money service businesses shows a serious lack of preparedness for the implementation of the European Payment Services Directive which comes into force in November 2009 - just 16 months away. Despite the fact that the Payment Services Directive which will impact on all those financial services providing money transfer facilities, IAMTN survey shows that companies have not got to grips with the changes which will impact on their business. The IAMTN response is similar to a survey put out by PSE Consulting exclusively to banks.

Addressing a conference organized by Sidley Austin on the European Payments Services Directive, Lady Olga Maitland, CEO, IAMTN said "Our findings are worrying for the money service sector. Most companies we found have chosen to ignore the changes or make any preparation at all - despite being only 16 months away from the deadline. Bearing in mind that the PSD will have a beneficial effect on the money service sector; giving them a level playing field with banks in Europe - and a great opportunity for both themselves and their customers, it is interesting to note how little attention has been paid to changes which will undoubtedly change the way they operate. "Indeed we found, as indeed did PSE in their survey, that the vast majority of businesses and banks are light years away from preparedness. This will cause massive last minute problems for them."

The Payment Services Directive was approved by the European Parliament in December 2007. Charlie McCreevy, the European Commissioner for Internal Markets and Services, described its objectives as 'generating more competition' providing a simple, harmonized set of rule and ensuring a high level of consumer protection." The PSD will have a revolutionary effect on the legal framework between banks and their customers setting stringent rules for information disclosure, conduct of business rules and service provision. It addition it introduces a new lightly regulated licensed entity called a 'Payments Institution' which may allow non-banks ie. Money service businesses etc to join the bankers' payment schemes and associations across the European Union. It could be said that the money service sector and banks are into new territory. They are unused to implementing prescriptive legislation from the EU. As a consequence smaller institutions appear to be unaware of the potential impact of the PSD on their customers and operations.

While the major international institutions expect to be ready by November 1st, 2009, substantial concerns have appeared for the lack of readiness by smaller banks - let alone the money service businesses. "What was interesting in our survey were those who did NOT respond when it was in their interests for their businesses to take advantage of the new opportunities. Lack of awareness of the changes ahead, like it or not, have not hit them. Among those who did respond, they had a moderate understanding of the changes. Most felt that the impact would be modest. Interestingly it was the small and medium sized businesses who felt that the PSD would be implemented on time. The major institutions did not."

The Majority of respondents to our questionnaire who are more aware than most, admitted they have not yet made any effort to prepare for the changes. Others are keeping their heads down and waiting for the implementation by national governments. Only 11% had made an impact assessment and of that only 7% had agreed a budget for implementation. The others had not got started. As a result they had not consulted with third party providers who would also be involved, ie. The software companies, agency banks, agents and so on. For those who had given some thought, they felt that the greatest effort will fall on adjusting the IT, and updating the terms and conditions. Interestingly we should recall the Capgemini World Payments Report 2007 who also lamented lack of preparedness. But in addition they pointed out that the greatest beneficiaries would be the card sector. They anticipated that by 2012 44% of all non-cash transactions in Europe will be via cards - to the point that Europe needs a 'any card at any terminal solution. Costs. Most believe it will not be that bad.

Banks though are fearful. According to PSE Consulting over 40% of banks surveyed believe that implementation will cost them more than 10m Euros and almost 25% believe it will cost over 50mEuros. Significantly nearly 60% of the banks surveyed do not believe there will be any benefits. Broadly though there is a positive feel about the opportunities. Indeed 61% in the IAMTN survey said there would be a revenue benefit. If there is a wind of change, it will affect the banks the most, who face highly competitive, agile and innovative money service business competition."

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