Advice note from the Pay.UK End User Advisory Council to the Pay.UK Board
The EUAC discussed the outcome of the Pay.UK consultation on the proposed CRM Fee Change Request in late November 2019 and agreed to write formally to the board to make our views clear. We hope that in doing so we can strengthen Pay.UK’s position as it seeks to facilitate discussions to find a solution to this issue. We want to make the following points:
First we should say that the EUAC is very supportive of the CRM and we are therefore keen to see a solution to long-term funding as soon as possible. We recognise that this is an issue for the industry and regulators, but we are also keen to see Pay.UK help where it can in its guardianship role.
We are very supportive of the fact that Pay.UK has taken the initiative to seek alternative arrangements by working with the industry. However, we recognise that Pay.UK cannot enforce any arrangement and is stepping outside its core remit in trying to broker a solution.
We were very disappointed to find that the original proposal made by industry had several flaws and was not supported by the whole of the sector. This meant that valuable time has been wasted consulting on something that Pay.UK could not have implemented. We are therefore concerned that no more time should be lost and are therefore keen to see industry, or regulators, set a tight timetable with clear criteria for establishing wide support for this voluntary scheme. We encourage Pay.UK to do all that they can in this respect.
We warmly welcome the initiative taken by one bank to fund their own implementation of the CRM and would hope others will follow suit. But ultimately, we wonder whether this will need a regulatory initiative to ensure comprehensive cover and are pleased therefore to know that Pay.UK are pursuing that possibility with the PSR, alongside the work UK Finance is doing on the voluntary arrangement.
We would be very happy for Pay.UK to make the views of the EUAC known, should it be helpful to have such support publicly.