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Revised FCA Approach Document

July 11, 2018

What has happened?

The FCA has published version 2 of its Approach Document on payment services and electronic money, which can be found here. The Document acts as a navigation tool for the Payment Services Regulations 2017 (PSR), and the Electronic Money Regulations 2011 (EMR).
The Document is relevant to all payment service providers, but is aimed at businesses that are or are seeking to become:

  • Authorised payment institutions or small payment institutions
  • Authorised e-money institutions or small e-money institutions
  • Registered account information service providers
  • Credit institutions, (which must comply with parts of the PSR 2017 and EMR 2011 when carrying on payment services and e-money business)

The previous September 2017 Approach Document has been amended to reflect changes brought about by the revised Payment Services Directive, market changes which have since had an impact on previous guidance and feedback from consultation papers.

Notable new guidance covers ‘Reporting and notifications’ and ‘Operational and security risks’ in light of the PSR and EMR. The Document also provides numerous minor alterations to several chapters of the earlier document in light of these changes. In correspondence with the Document, the FCA has further published the revised operational security risk reporting form (REP018), which is available here.

How Thistle can help you?

Thistle will continue to keep this area under review and will issue further updates where necessary. Please contact Thistle if you need assistance in relation to any of these issues.