Reply form for the Consultation on possible end-date(s) for SEPA migration

Transcription

1 detailed answer 1 Do you think that under current circumstances re is a need to support SEPA migration by setting (a) deadline(s) for migration to SCT and SDD? Do you consider certain preconditions should be met for setting such (a) deadline(s)? a) yes, re is a need to set (a) deadline(s) to SEPA migration b) yes, but under certain conditions c) no b) The National Forum on Payment System recognizes need for setting a deadline for phasing out existing national credit transfer and direct debit products in Europe. The right timing and process to set end-date depends on European developments. 2 How much time would be needed to budget and implement technically SEPA migration? What is anticipated impact of SEPA migration on your organisation/business (eg. on your IT systems, organisation, human resources, communication, or any or area)? 3-5 years Please provide quantitative and financial analysis if available. End-users will need at least 3-5 years after launch of SDD. For large corporates, especially large billers, technical and budgetary consequences are considerable. Many have started preparations, but may need anor 3-5 year. For smaller firms, re is a dependency on specialized software providers that are not ready yet. The impact will be on IT systems mainly. 3 What deadline(s) would you see as feasible for replacement of legacy euro credit transfers and direct debits by SCT and SDD? 2013 at earliest The National Forum on Payment System considers timelines in current Nerlands SEPA Migration plan as realistic, based on current insights. This would imply a deadline end of 2013 at earliest. 1

2 4 Do you think (a) migration end-date(s) should cover only standards (ie. account identifiers and payment format to be used) or schemes' rules as well? a) only standards b) also schemes rules c) or (please specify) detailed answer Scheme rules are an essential part of payment products and services banks (will) offer. 5 Do you think (a) migration end-date(s) should cover only interbank space (ie. bank/bank and bank/infrastructure communication) or complete end-toend payment chain (including customer/bank communication)? a) interbank space b) complete end-toend payment chain c) or (please specify) c) Please The migration end-date should cover phasing out of existing national credit transfer and direct debit products, i.e. ir replacement by products based on SCT and SDD rulebooks. The changes in products will impact customer/bank communication. But customer/bank space will remain partly bank and customer(group) specific, so word 'complete' in answer b) is an overstatement and refore c) is chosen. 6 Do you consider that setting (a) migration end-date(s) should imply that all legacy payments migrate to SEPA payments or could some products be maintained or developed on market besides SEPA products? a) all payments should migrate to SEPA products b) 'niche' products could remain - or be developed - on market c) or and specify conditions which would have to be met by such products. Due to differences in national markets 'niche products' may exist. Such products may play an important part in stimulating efficiency and innovations. Banks can offer additional optional services (AOS) based on core SEPA payment schemes, too. 2

3 7 8 Do you think re should be a single enddate for SCT and SDD migration or two separate migration end-dates? What do you think best approach would be regarding territorial scope of (a) migration end-date(s)? a) a single end-date for SCT and SDD migration b) two separate enddates for SCT and SDD migration a) different national end-dates b) a single EU enddate c) a single EU end-date but with flexibility to set an earlier end-date at national level d) a phased approach e) or a) Please c) Please and specify your answer for d), and e). detailed answer Most enterprises and firms prefer to change-over to SCT and SDD at same time for reasons of efficieny. For consumers, having a single end-date will minimize inconvenience and confusion. However given that SDD migration will be complicated and time consuming, two seperate migration end-dates may be an option. The Dutch Consumer's Association favours separate migration enddates. A single EU end-date gives maximum clarity for all. But, if for some reason some national markets want to migrate somewhat earlier, that should be possible. 9 Do you think that migration end-date(s) should be same for euro payments in euro area countries and in non-euro area countries or that re should be different migration end-dates? a) same end-date(s) for euro area and noneuro area countries b) different end-date(s) for euro area and noneuro area countries a) Please From perspective of Dutch market parties it would be practical to have a common end-date for both groups of countries. However, if non-euro countries need more time for ir preparations, different deadlines would not be a big problem. In that case it will be b). 3

4 10 11 If (a) migration end-date(s) was (were) to a) pure self-regulation be established, should this be done by selfregulation or by regulation? c) intermediate solution b) regulation (self-regulation with political endorsement) Do you think that some criteria (such as critical mass) should first be followed before setting any migration end-date(s)? and elaborate on modalities for each answer (eg. if b) who should be regulating body). yes If yes, please and elaborate on se criteria. detailed answer Essential is a commonly agreed end-date, supported by stakeholders. If needed for migration, a regulation could be build upon this commonly agreed end-date. In that case b) and c) hardly differ. The regulating body would be EU, i.e. European Council and European Parliament Regarding criteria no unanimity among stakeholders involved. Some are of opinion that an end-date is necessary to start migration (no criteria). Ors are of opinion that an end-date should be set after product launch of all SCT and SDD variations. And some only want to set an end-date to enforce migration of a remaining minority of users of legacy payment instrumens (after reaching a critical mass). 4

5 detailed answer Name of respondent The Consultative Platform SEPA in Nerlands (Afstemgroep SEPA Nederland, ASN) of National Forum on Payment System. Geographical scope of action The Nerlands Type of stakeholder Volume of payments that you handle or represent a) payment service provider b) technical provider c) public authority d) corporate e) merchant f) SME g) consumer h) national SEPA coordination committee i) or (please specify) h) Answers above are joint answers of following participants of Consultative Platform SEPA in Nerlands: - Dutch Senior Citizens Association (ANBO voor 50-plussers) - Dutch Council of Chronically ill and Disabled (Chronisch zieken en Gehandicapten Raad Nederland) - Dutch Consumers Association (Consumentenbond) - Federation for Visually Impaired (Viziris) - User Platform for Payment System (Gebruikers Platform Betalingsverkeer) - Dutch Home Shopping Organisation (Nederlandse Thuiswinkel Organisatie) - National Employers Organisation (VNO-NCW) - Dutch Association of Insurers (Verbond van Verzekeraars) - Association of Dutch Water Companies (Vewin) - Association of Energy Producers, Traders and Retailers in Nerlands (Energiened) - Currence - Above-mentioned participants represent vast majority of end-users of credit transfers and direct debits in Nerlands 5