This paper sets out the Emerging Payment Association’s response to the FCA’s Consultation Paper, “A New Consumer Duty”. We welcome the FCA’s focus on consumer protection and the broad objectives behind the CP. However, we have comments on the application of certain aspects of the proposed framework to firms that provide payment services and/or issue e-money. We fear that, despite the good intention of protecting consumers, this proposition will create extra burdens on firms, providing extra costs and another layer of administration which will inevitably exclude smaller players and will create an extra barrier to market entry, resulting in the consolidation of bigger players alone and harming broader competition. We urge the FCA to consider excluding all payment that are not retail consumer-facing.
The Payments Association
St Clement’s House
27 Clements Lane
London EC4N 7AE
© Copyright 2024 The Payments Association. All Rights Reserved. The Payments Association is the trading name of Emerging Payments Ventures Limited.
Emerging Ventures Limited t/a The Payments Association; Registered in England and Wales, Company Number 06672728; VAT no. 938829859; Registered office address St. Clement’s House, 27 Clements Lane, London, England, EC4N 7AE.
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