Rules on scheme access and scheme management must be synonymous in all three Rulebooks
As described in the article "Think ahead: the Scheme Change Management Process" in this Newsletter, the Scheme Management Internal Rules annexed to all three Rulebooks prescribe a formal change management process which allows the to modify the Rulebooks. As of launch in January 2008, changes to the Credit Transfer Scheme Rulebook are subject to this formal change management process. In accordance with the timelines stipulated by the change management process, the Plenary will decide in September 2009 on changes to be introduced into the Scheme Rulebook. Among others, it is suggested to introduce changes to chapter 5 and to the Internal Rules in the Rulebook.
Chapter 5 defines the criteria for participation in the schemes. Changes to chapter 5 are envisaged in light of the fact that the schemes will be open for participation of payment institutions duly licensed under the Payment Services Directive (PSD) from 1 November 2009 onwards. The Internal Rules define the administration and compliance functions performed by the Scheme Management Committee (SMC) and - as mentioned above - the rules to be followed when modifying the schemes themselves.
Chapter 5 and the Internal Rules, respectively, must be synonymous in all three Rulebooks. As such, if any changes are introduced to chapter 5 and the Internal Rules in the Scheme Rulebook, the Direct Debit Scheme Rulebooks have to be aligned accordingly.
If you already read the article "Think ahead: the Scheme Change Management Process", you will argue that any changes with regard to the Scheme Rulebook approved in September 2009 may only take effect in November 2010. In principle, you are right. However, as is described below, an exception to this rule may be introduced.
Suggestion: expedite change management process with regard to section 2 of the Scheme Management Internal Rules
A suggestion has been submitted into the change management process to expedite implementation of changes pertaining to section 2 of the Internal Rules which covers the administration and compliance functions performed by the SMC.
There are extremely good reasons for a one year freeze-period prior to changing provisions of the Rulebooks that require scheme participants to amend their own internal processes. The SMC, however, believes that such a freeze-period is unnecessary for changes to section 2 of the Internal Rules when such changes do not have a direct impact on scheme participants. The SMC therefore proposes to implement changes to section 2 of the Internal Rules thirty days after Plenary approval.
At the same time, specific changes regarding administrative procedures of the SMC defined in the Internal Rules were introduced into the change management process.
Alignment of chapter 5 and Internal Rules in all three Rulebooks in November 2009
If the suggestion of the SMC to expedite implementation of changes to section 2 of the Internal Rules should be approved by the Plenary in September 2009, actual modifications of the Internal Rules would become effective already in November 2009. Moreover, possible clarifications of the scheme access criteria laid down in chapter 5 of the Rulebooks would have to be implemented by November 2009 as well.
In the - very likely - case that changes to chapter 5 and to the Internal Rules take effect under the Credit Transfer Rulebook in November 2009, it would be necessary to align the Direct Debit Scheme Rulebooks accordingly. As such, updated versions of the Credit Transfer Rulebook, of the Core Direct Debit Rulebook and of the Business to Business Direct Debit Rulebook will become effective in November 2009.
It is important to note, however, that no operational changes will be introduced into any of the Rulebook versions to be approved in September 2009.
Credit Transfer Scheme Rulebook Release 2009
The current Credit Transfer Scheme Rulebook version 3.2 will be updated to reflect changes to chapter 5 and to the Internal Rules in September 2009. The Credit Transfer Scheme Rulebook version 3.3 will take effect on 2 November 2009.
Any operational changes with regard to the Credit Transfer Scheme approved by the Plenary in September 2009 will only take effect with release of a further updated version of the Scheme Rulebook in November 2010.
Core Direct Debit Scheme Rulebook Release 2009
The current Core Direct Debit Scheme Rulebook version 3.3 will be updated to reflect changes to chapter 5 and to the Internal Rules in September 2009. The Core Direct Debit Scheme Rulebook version 3.4 will take effect on 2 November 2009, the launch date of the scheme.
Business to Business Direct Debit Scheme Rulebook Releases 2009
The Plenary will approve the B2B Direct Debit Scheme Rulebook version 1.2 in June 2009. This version will be updated to reflect changes to chapter 5 and to the Internal Rules in September 2009. The B2B Direct Debit Scheme Rulebook version 1.3 will take effect on 2 November 2009, the launch date of the scheme.
Christian Westerhaus is the Chair of the Payments Scheme Working Group (SPS WG).
Related articles in this Newsletter:
Think ahead: the SEPA Scheme Change Management Process. Public consultation on 2010 Rulebook release starts in May 2009
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