My organisation is a savings/co-operative PSP forming part of a “de-centralised group”. Can one PSP sign on for all of the PSPs in this co-operative structure?

One PSP or an association may sign on behalf of all or some of the PSPs in the group. In so doing it is signing only as Agent and all liabilities are assumed by the adhering PSP as if it had itself signed.

Is it necessary for every legal entity processing SEPA payment transactions in my organisation's group structure to adhere to the Scheme, even if its SEPA Scheme payments are “routed” through another legal entity in the group?

If no, will my organisation be legally responsible if its subsidiaries participating in the Scheme do not correctly perform their obligations under the Rulebook?

No, these subsidiaries are responsible for their own acts and omissions. 

If my organisation signs the Adherence Agreement, will all the subsidiary entities of my organisation also joining the Scheme be covered by this application?

No, such subsidiaries or affiliated institutions (i.e., any entity with a separate and distinct legal personality within your organisation) will need to execute a separate Adherence Agreement.

If my organisation has branches that are located outside of SEPA, will they also have to comply with the Rulebook?

No. Such branches are not eligible to participate in the Scheme.

If yes, does this mean that all of my organisation's branches must be able to comply with the Rulebook from the time that my organisation states that it is ready to adhere to the Scheme?

They should be able to comply with the Rulebook from such time as branches intend to make or receive Scheme payments. 

If my organisation signs the Adherence Agreement, will all the branches of my organisation be covered and so subject to obligations in the Rulebook?

Yes, branches of an adhering institution located in a SEPA country will be covered by the Adherence Agreement and be subject to Scheme rules in relation to Scheme payments made or received.

If two authorised people sign the Adherence Agreement on a different day, which date is the date of signature?

The date of signature is always the latest date.

Can my organisation use information in the Register of Participants as a basis for routing payment transactions?

No. The Register is not a routing table and does not hold operational routing information.