354 is the total number of change suggestions the European Payments Council ( ) received on the proposed Instant Credit Transfer ( ) scheme during the public consultation, which ended in July.
This high level of participation certainly reflects the improvements that the scheme will bring to euro payments. The optional scheme will be the first in the world to enable interoperable instant credit transfers in a region as large as . It will also contribute to further enhancing payments integration in the area. This is tremendously important to avoid fragmentation (as some countries have already launched their national instant payment solutions), and to help making payments easier and faster in Europe.
The suggestions received come from the complete range of payment stakeholders, and from all across Europe. Payment Service Providers ( ) and Clearing and Settlement Mechanisms (CSM) organisations represent, unsurprisingly, the majority of respondents. A sizeable number of contributors proposed alternative business and operational rules for handling positive confirmation messages of transactions coming from the beneficiary bank. These contributors see a more pivotal role for the interbank players in the transmission of positive confirmation messages, before the funds are made available to the beneficiary. Another category of comments relates to the regulatory controls (sanctions, counter-terrorist financing, and anti-money laundering for example) performed during the processing of the transaction.
These comments are food for thought for the , which is currently in the process of analysing them, and assessing their relevance and feasibility in the tight scheme publication calendar. The finalised rulebook is scheduled to be published at the end of November 2016, and will take effect one year later, in November 2017. In line with its commitment to stakeholder involvement and transparency, the will review the change suggestions not only internally but also via its stakeholder forums (Scheme End-User Forum and Scheme Technical Forum) representing a broad spectrum of stakeholders. All change suggestions, as well as the comments to these suggestions will be made publicly available once the finalised rulebook is published.
The thanks all contributors for their participation in the public consultation. Undoubtedly, the great interest demonstrated by the payment community is a sign of the widespread wish to make the scheme a success! Moreover, the valuable input received from the payment stakeholders will ensure the scheme is fit for purpose for and users.
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