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March 24, 2009


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Harri Rantanen



Addenda to your article on SEPA ....
Talk to end-users ,in addition to banks ....otherwise you miss half the story.
The organizations representing end users who sit in the EPC Consumer Stakeholder Forum ( CSF ) hav created a Coordination Committee with Olivier Brissaud of EACT as spokesman
Major weakness of SEPA is "governance", who cannot be left entirely to the EPC . End users participation ,so far, has been largely "ornamental" .The "finished SEPA products" delivered by the EPC,especially SDD , have met with widespread criticism ,lack of committment and lack of end user adoption.
End users proposals for changes in the Rulebooks have not been discussed . Early thie year,the Committee endorsed EACT Press Release ( and undelying technical paper ) listing 7+2 open issues to be solved before end users acceptan end-date on Credit Transfer.A similar list with open issues re. SDD and e-mandate is besing readied. There is no way , under the current governance, that these changes can be seriously discussed with the EPC. And without this , no serious end-date can be fixed . Unless the EC and ECB plan to impose one regardless...Fixed this way, is tantamount to declaring SEPA's market flop.
End-users Committee primary request is there fore a changee of governance .
Comment on MIF --- Present domestic MIF is not impacted by the EC decision to establish a 8.8 euro cents on crossborder SDD ( French banks will continue to use 12.0 euro cents on domestic SDD .This decision, not agreed with stakeholders,is clearly intended as a "subsidy" or "incentive" to banks for them to accept SEPA SDD . It creates "asymmetries" for banks and possibilities of "arbitrage" for corporates. The final fee structure , after the three years' moratorium , should be discussed with all stakeholders ( not just banks) and be taken considering its impact on each country ( MIF and no-MIF countries )

End of last year ,the EC+ECB consulted stakholders' representatives on a new SEPA Governance Scheme and Action Plan. Nothing has come of it yet, due to "political" pressure and more pressing priorities( economic and financial crisis ) . End-users are eagerly awaiting an official proposal and , based on it , will decide whether to continue cooperation on SEPA .

Gianfranco Tabasso , Chairman EACT Payments Commission

neil burton

Chris, SEPA (the EPC response to the regulators) may be having a slow start, but it is premature to paint the PSD with the same brush. The PSD provides a regulatory regime for and hence legitimises non-bank providers - some of which are providers to banks, so are not automatically bank competitors as sometimes assumed. Some non-bank providers are extremely well positioned to deliver to the PSD. Whether the banking sector will adopt the alternative approaches, which could therefore fast-track SEPA, is an open question.

Such payments and collections services are fully live today, hence are very low cost to adopt, and have very fast time to value. And, incidentally, have reach well beyond the EEA. Some of them are designed to benefit banks, not to disintermediate them.

I'm sure there is a long list but to start it off - Western Union & Earthport have clearly signalled their intent regarding PSD compliance, and various industry pundits have commented on Paypal.

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