The Payments Innovation Forum (PIF) has highlighted the need for future UK payments policy to strike the right balance to ensure that one or more of the government's objectives for UK payments is not met at the expense of another.
In its response to HM Treasury's Call for Evidence on the Payments Services Regulations, PIF explains that while consumer protection is a fundamental objective for government, regulators and firms to pursue, "over-zealous rules such as the Payment Systems Regulator's mandatory reimbursement proposals will make it very difficult for firms to compete in the interests of consumers".
PIF also describes the contribution that electronic money and payment institutions made to the UK payments market and that this "should not be underestimated"; enabling the introduction of innovative new products and services to the existing financial services market, providing solutions where none existed, or were too costly or complex to use, and providing payment facilities for many businesses and individuals who have hitherto been unable to access (or were priced out of) using financial services.
Responding to the government's questions concerning the regulatory treatment of payment services and e-money, PIF sets out its concerns about the management of authorisations by the Financial Conduct Authority and proposes the implementation of a number of steps to address these concerns.
Read PIF's response in full: