How proactive policy pays off

by Ricardo Tordera
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The Payments Association’s head of policy and government relations Ricardo Tordera takes a look back at the trade body’s key achievements in 2022.

Last year was an exciting year for policy and regulatory developments in the payments industry. The Payments Association (TPA) vocalised our frustration for the FCA’s delays with authorisations, licensing and change of control requests and actively supported the regulator’s efforts to hire more and better qualified staff.

We believe things are slowly moving in the right direction. We remained keen to collaborate with all our regulators, to highlight our industry’s top priorities and to remind them that good regulation and a good regulator are both required for the UK to remain competitive.

On authorised push payments (APP) scams, we have had to be critical of some of the PSR’s proposed solutions. We appreciate the PSR is committed to doing more to protect consumers from this growing fraud problem, but we do not believe that measures such as requiring mandatory reimbursement will effectively prevent fraudsters from acting. Rather, this could create the opposite effect, and encourage fraud on an industrial scale as last seen with PPI fraud scams (payment protection insurance).

While the implementation of the PSR’s proposed solutions will provide additional protection for consumers, we highlighted four main areas of concern: friction; education of payment users; increase in first party fraud; and reduced competition.

Q1 2023 watch list

  • Publication of the second paper from Bank of England on CBDCs
  • Parliamentary approval of the Financial Services and Markets Bill
  • Provision of a regulatory regime for stablecoins from HMT
  • Publication of BoE proposals for the next roadmap for RTGS services beyond 2024

Digital currencies spotlight

Digital currencies were the real highlight of 2022 – in both good and bad respects. But despite the bare market in the crypto arena and too many serious fraud and money laundering scandals, regulation and safety are finally on their way, and the payments industry is taking note.

We can proudly claim to have brought to the table the most interesting work on central bank digital currencies (CBDC) in the UK, by publishing the Green Paper, A New Era for Money, supported by our member Boston Consulting Group.

While the debate in the UK has been lacking real world initiatives for the past two years, and theoretical discussions are blocking the progress of the HMT/BoE taskforce, The Payment Association’s Green Paper has been the platform for the launch of a UK pilot by a consortium of companies, led by technology providers. It will be interesting to see how things evolve in this constantly and rapidly changing environment.

Furthermore, we are proud to have been a founding member of the new UK Forum for Digital Currencies(UK FDC) along with the City of London, TheCityUK, UK Finance and the Digital Pound Foundation.

The UK FDC is a forum for discussion and collaboration around the industry’s response to digital currency developments in the country, and a resource to help educate those in Parliament about this exciting new approach to moving money. This includes the potential for a CBDC, as well as stablecoins and other variable value cryptoassets.

In December 2022, the UK FDC produced a joint commentary on MiCA (the EU’s Market in Crypto Assets) to suggest to UK regulators and government how to improve the EU’s proposals and thereby create a better regulatory framework in the UK, allowing us to make the most of regulatory arbitrage. The work will be presented to HMT, the Economic Secretary’s Team, FCA and BoE in early 2023.

In January 2023 we published a joint policy statement from the UK FDC on digital assets. This is a very powerful move because, for the first time ever, it brings the entire industry together to ask the government and the regulators to adopt these innovative new solutions to age old problems facing everyone who pays and gets paid.

2022 Highlights

WATCH: The Payments Association’s Riccardo Tordera talks to Brunello Rosa, CEO of Rosa & Roubini, about what stablecoins can do for the British economy.

The pair discuss the similarities between the success of e-money and what could become of stablecoins in the UK. Rosa believes that if commercial banks begin to distribute their own stablecoin, it could go in two directions: either ‘narrow banking’ when stablecoins are backed by short-term assets; or a route where banks will be able to introduce stablecoin lending on a much larger scale.


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