19 April 2012
• The Financial Institutions Act
• The Payment Services Directive (2007/64/EC)
• The Electronic Money Directive (2009/110/EC)
• The way forward
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Malta Financial Services Authority
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(Chapter 376 of the Laws of Malta)
• A legislative innovation enacted in 1994;
• Regulates the activities of non-bank ‘financial institutions’;
• Sets out statutory requirements and obligations of financial institutions
and the competent authority – but less onerous when compared to the
Banking Act (Cap 370);
• Allows financial institutions enough ‘elbow-room’ to operate whilst
ensuring constant supervision and regulation;
Web-links:
Financial Institutions Act - http://www.justiceservices.gov.mt/DownloadDocument.aspx?app=lom&itemid=8843
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• Financial Institution:
“any person who regularly or habitually acquires holdings or undertakes the
carrying out of any activity listed in the First Schedule for the account and at the
risk of the person carrying out the activity”;
• Financial Institutions shall not be funded through the taking of deposits or any
other repayable funds from the public;
• Subtle but important differences in the definition of “Financial Institution” under
the Financial Institutions Act and the Capital Requirements Directive
(2006/48/EC);
• CRD definition:
“financial institution means an undertaking other than a credit institution, the
principal activity of which is to acquire holdings or to carry on one or more of the
activities listed in points 2 to 12 of Annex I”.
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A Financial Institution may undertake the following activities listed in the
First Schedule to Article 2 of the Financial Institutions Act:
1. Lending;
2. Financial leasing;
3. Venture or risk capital;
4. Payment services as defined in the Second Schedule;
5. Issuing and administering other means of payment (travellers cheques, bankers’ drafts and
similar instruments) in so far as this activity is not covered by point 4 above;
6. Guarantees and commitments;
7. Trading for own account or for account of customers in:
(a) money market instruments (cheques, bills, Certificates of deposits and similar instruments);
(b) foreign exchange;
(c) financial futures and options;
(d) exchange and interest rate instruments;
(e) transferable instruments;
8. Underwriting share issues and the participation in such issues;
9. Money broking;
10. Issuing of Electronic Money as defined in the Third Schedule.
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Article 3 – Licensing
• No business of a financial institution may be carried out without a licence under the
Act granted by the competent authority;
• If not expressly exempted by the Act, the competent authority shall conclusively
determine whether the business of a financial institution is being transacted;
• A licensed financial institution may not take deposits or other repayable funds from
the public within the meaning of the Banking Act.
Article 5 – Conditions for a licence
• Specific conditions for the granting of a licence:
Minimum initial capital/own funds as determined by the competent authority;
‘Four eyes’ principle;
Fit and proper qualifying shareholders, controllers and senior managers;
Sound and prudent management structures, governance and internal controls;
Any Close links between the applicant and another person(s) do not effect supervision.
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Article 8A – Agency Arrangements
•
•
No financial institution shall enter into agency arrangements, with third parties, unless it has
notified the competent authority and provided the applicable information to the competent
authority;
Limitations on the operations of agents include:
Undertake activities which the principal is licensed to undertake;
Not act as agents for more than one licensed financial institution;
May commence activities subsequent to the competent authority's verification of information
submitted on its behalf by the financial institution;
May be subject to the same obligations as its principal.
Article 9 - Notification of new or variation in participation or control
•
•
•
•
Any changes in shareholding involving a qualifying shareholding (in tranches of 20%, 33%,
50% or subsidiary) requires authorisation;
Includes mergers or restructuring;
Unless prior authorisation is obtained, the competent authority has the right to restrain or cancel
the transaction;
Approval and authorisation of controllers of the financial institution.
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Article 13 – Powers and duties of the Competent Authority
• It shall be the duty of the competent authority to carry out the functions assigned
to it by this Act;
• Authority is to ensure that financial institutions carrying on business in Malta
comply with applicable regulatory and legislative requirements;
• Authority empowered to undertake on-site inspections and create Financial
Institutions Rules;
• Authority may suspend or withdraw a financial institution’s licence.
Article 20 – Co-operation and sharing of information
• Enables the competent authority to share its supervisory duties (including sharing
information) with other overseas regulatory authorities, national central banks
(when acting in their capacity as monetary and oversight authorities) and other
relevant authorities.
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First Schedule – Activities
A list of activities that can be carried out by a financial institution.
Second Schedule – Financial Institutions Carrying Out Payment
Services
• Sets out the regulatory framework under which payment services may be carried
out;
• Definitions transposed from PSD;
• List of activities relating to payment services.
Third Schedule – Financial Institutions Issuing Electronic Money
• Set out the activities that may be undertaken by financial institutions that issue
electronic money.
• Definitions transposed from EMD;
• List of additional activities that electronic money institutions may undertake.
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• Financial Institutions Rules are binding on licence holders;
• May lay down additional requirements and conditions in relation to:
activities of licence holders;
the conduct of their business;
their relations with customers, the public and other parties;
their responsibilities to the competent authority;
reporting requirements;
any other matters as the competent authority may consider
appropriate.
• Financial Institutions Rules are published on the Authority’s website.
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FIR/01 – Application Procedures & Requirements for Authorisation
• Provides applicants with the procedures and requirements for the processing of
applications;
• Applies to all companies desirous of carrying out any of the activities listed in the
Schedules to the Act in or from Malta;
FIR/02 – Supervisory & Regulatory Requirements
• Requires a prudential supervisory approach proportionate to the nature, scale and extent
of the institution's activities;
• Financial institutions undertaking activities similar to those undertaken by credit institutions
(excluding the acceptance of deposits) are considered as quasi-banking institutions and
consequently requires a level of regulation similar to that applied to credit institutions.
FIR/03 – Electronic Money Institutions Rule
• Lays down all the regulatory and supervisory procedures the authority will adopt in
respect of financial institutions issuing electronic money;
• Modelled on the requisites of EU Directive 2009/110/EC (EMD).
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• Licensed Financial Institutions: 15
• Financial Institutions ‘traditional’ activities only: 6
• Financial Institutions undertaking solely Payment Services: 2
• Financial Institutions undertaking ‘traditional’ activities and Payment
Services: 8
• Financial Institutions issuing electronic money: 1
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2007/64/EC
Purpose of the PSD:
• Providing the legal foundation for the creation of a single payment market in the EU;
• Establishing a comprehensive regulatory framework applicable to all payment
services in the EU;
• Creating a level playing field and enhancing competition;
• Ensuring consistent consumer protection and improving transparency by establishing
the same set of rules on information requirements;
• Creating the potential for more efficiency of EU payment systems.
• Main ambition of EU Commission - make cross-border payments as easy, efficient and
secure as 'national' payments within a Member State.
• PSD establishes a single licence for payment service providers – ‘payment institutions’.
Web-links:
EU Commission: http://ec.europa.eu/internal_market/payments/framework/index_en.htm
PSD Text: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:319:0001:0036:EN:PDF
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Key Dates:
• December 2003 – EU Commission issues a Consultative Document regarding a
New Legal Framework for Payments in the Internal Market;
• December 2005 – EU Commission publishes first draft of the new Directive;
• November 2007 – Adoption of PSD (official publication);
• November 2009 – Deadline for Member State Transposition and Adoption;
• November 2012 – Deadline for review of PSD.
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Key Definitions:
Payment Institution – a legal person that
has been granted authorisation in terms
of the PSD to provide & execute payment
services throughout the Community;
Payment Account – an account held in the
name of one or more payment service
users which is used for the execution of
payment transactions;
Payment Instrument – any personalised
device(s) (e.g. payment card) &/or set of
procedures (e.g. virtual card/online) used
by the payment service user in order to
initiate a payment order.
Payment Service Providers:
•
•
•
•
•
•
Credit institutions
E-money institutions
Post office giro institutions
Payment institutions
The ECB & National Central Banks when not
acting in their capacity as monetary
authority or other public authorities
Member States or their regional or local
authorities when not acting in their capacity
as public authorities
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Article 3: Negative Scope
• Lists payment transactions/services which are exempt from the requirements
of the Directive.
• Aimed at providing guidance to the industry and regulatory authorities …
but some exemptions are rather subjective.
Article 5: Applications for Authorisation
• Requires the submission of an application together with additional
information;
Article 6: Initial Capital
• States initial capital requirements:
Not less than €20K for Activity 6 – Money Remittance;
Not less than €50K for Activity 7 – Payment Services through IT devices;
Not less than €125K for remaining Activities 1 to 5.
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Articles 7 & 8: Own Funds
• Own funds held by a payment institution may not fall below the initial capital
requirement or that required by the applicable Own Funds’ calculation.
• Three Methods for the Calculation of Own Funds:
Method A: At least 10% of fixed overheads of the previous year;
Method B: Based on Payment Volumes;
Method C: Based on Profit & Loss indicators – interest income, interest
expense, commissions and fees received, and other operating income.
• Competent Authorities are empowered to increase or decrease minimum
Own Funds requirement by 20%
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Article 9: Safeguarding Requirements
• Payment Institution required to safeguard funds received from payment service users:
Funds to be deposited in a separate account in a credit institution or invested in secure,
liquid low-risk assets; and
Insulated in accordance with national law against claims of other creditors;
Or
Covered by an insurance policy
Article 16: Other Activities
• Additional activities that payment institutions are entitle to undertake:
Provision of operational and closely related ancillary services;
Operations of payment systems;
Other business activities.
• May also grant credit (with conditions) in relation to a number of payment services;
• Any funds received from payment service users shall not constitute a deposit or other
repayable funds within the meaning of Article 5 of the CRD.
• Payment Institutions shall not conduct the business of taking deposits or other
repayable funds within the meaning of Article 5 of the CRD.
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Article 17: Use of Agents, branches and outsourcing
• Requirement to communicate information on agent to competent authority in home member
state;
• Competent authority may refuse to list agent;
• Sub-article 17(5) allows the engagement of agents in another member state through
passporting – opinion on agent of the host member state to be taken into account;
• Sub-article 17(6) – suspicion of host member state relating to the use of agent for money
laundering purposes – inform home member state.
Article 25: Passporting
• Lays down procedure for passporting by payment institutions;
• Requires co-operation between home and host member states by sharing essential and/or
relevant information.
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1. Services enabling cash to be placed on a payment account as well as all the operations required for operating a
payment account;
2. Services enabling cash withdrawals from a payment account as well as all the operations required for operating a
payment account;
3. Execution of payment transactions, including transfers of funds on a payment account with the user's payment service
provider or with another payment service provider:
(i) execution of direct debits, including one-off direct debits;
(ii) execution of payment transactions through a payment card or a similar device;
(iii) execution of credit transfers, including standing orders;
4. Execution of payment transactions where the funds are covered by a credit line for a payment service user:
(i) execution of direct debits, including one-off direct debits;
(ii) execution of payment transactions through a payment card or a similar device;
(iii) execution of credit transfers, including standing orders;
5. Issuing and/or acquiring of payment instruments;
6. Money remittance;
7. Execution of payment transactions where the consent of the payer to a payment transaction is transmitted by means of
any telecommunication, digital or IT device and the payment is made to the telecommunication, IT system or network
operator, acting solely as an intermediary on behalf of the payment service user and the supplier of the goods and
services;
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Payment Service
Examples
Services enabling cash to be placed on a payment
account and all the operations required for
operating a payment account
Cash deposits on a payment account over the
counter or through an ATM
Services enabling cash withdrawals from a payment
account and all of the operations required for
operating a payment account
ATM cash withdrawals or over the counter
withdrawals
Execution of:
- Direct debits, including one-off direct debits;
- Payment transactions through a payment card or
similar device;
- Credit transfers, including standing orders.
-
Direct debits (including one-off direct debits);
Payment transactions involving e-money;
Credit Transfers such as standing orders
Transfer of funds with the user’s PSP or with
another PSP.
Execution of payment transactions covered by a
credit line:
- Direct debits, including one-off direct debits;
- Payment transactions through a payment card or
similar device;
- Credit transfers, including standing orders.
-
Direct debits using overdraft facilities;
Credit Card payments;
Credit transfers using overdraft facilities.
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Payment Service
Examples
Issuing payment instruments or acquiring payment
transactions
Card issuing and card merchant acquiring services
Money Remittance
Money transfer/remittances that do not involve
payment accounts
Execution of payment transactions where the consent
of the payer to execute a payment transaction is
given by means of any telecommunication, digital or
IT device and the payment is made to the
telecommunication, IT system or network operator,
acting only as an intermediary between the
payment service user and the supplier of goods and
services.
-
Mobile or fixed phone payments;
Payments made from handheld devices (e.g.
Blackberry)
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• Joint exercise between the MFSA and Central Bank of Malta;
• MFSA – Titles I & II – Regulatory and Supervisory provisions;
• CBM – Titles III & IV – Provision and Use of Payment Services.
• Transposition exercise involved amendments to the Financial
Institutions Act and Rules, creation of Safeguarding of Funds
Regulations and Passporting Regulations.
• Central Bank of Malta issued Directive No 1 on the “Provision and use
of Payment Services” on 30 October 2009.
Web-links:
CBM Directive No 1: http://www.centralbankmalta.org/updates/Downloads/pdfs/directive1.pdf
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Financial Institutions Act:
• Streamlining of FIA provisions with PSD;
• Creation of the Second Schedule to the FIA which:
Sets out the regulatory framework under which payment services may be carried out;
Applies definitions transposed from PSD;
Lists activities relating to payment services.
Financial Institutions Rule FIR/01:
• Insertion of the provision of payment services in the definition of the business of a
financial institution;
• ‘Verbatim’ transposition of PSD Negative Scope;
• Aligning of minimum criteria for authorisation, application documentation & initial capital
requirements with PSD;
• Amendments to the passporting procedures;
• Insertion of procedures for Safeguarding of funds.
Financial Institutions Rule FIR/02:
• Insertion of Own Funds requirements for payment institutions (Methods A, B & C)
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2009/110/EC
•
In its review of Directive 2000/46/EC the Commission highlighted the need to revise the first
EMD since some of its provisions were considered to have hindered the emergence of a true
single market for electronic money services and the development of such user-friendly services.
Main problems with Directive 2000/46/EC:
•
•
Unclear definition of electronic money and scope of the Directive;
Inadequate and excessive legal framework.
Purpose of the new E-Money Directive (2009/110/EC):
•
•
•
•
Enable new, innovative and secure electronic money services to be designed;
Remove barriers to market entry;
Facilitating the taking up and pursuit of the business of electronic money issuance;
Foster real and effective competition between all market participants.
•
The directive focuses on modernising EU rules on electronic money, especially bringing the
prudential regime for electronic money institutions, into line with the requirements for payment
institutions in the Payment Services Directive.
•
EMD repealed Directive 2000/46/EC and came into force on 20th October 2009.
Web-links:
EU Commission: http://ec.europa.eu/internal_market/payments/emoney/index_en.htm
EMD Text: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:267:0007:0017:EN:PDF
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Key Dates:
• July 1998 – EU Commission proposes a clear regulatory framework for e-money;
• September 2000 – Directive 2000/46/EC is issued;
• February 2006 – Publication of final report on evaluation of Directive 2000/46/EC;
• October 2008 – Commission adopts proposal for new Directive;
• September 2009 – Directive 2009/110/EC is issued;
• April 2011 – Deadline for Member State Transposition;
• November 2012 – Deadline for review of EMD.
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Definition of ‘electronic money’ :
• Legal definition of e-money updated to enhance legal certainty, and to bring in line
with the definition of payment transactions as set out in the PSD;
• Intended to achieve technical neutrality between different forms of e-money.
Authorisation:
• Procedures for authorisation brought in line with PSD;
Prudential Requirements:
• Under Directive 2000/46/EC Prudential Requirements were closely linked to CRD –
considered excessive;
• Alignment of Prudential Requirements with PSD is considered a very important
development in increasing the attractiveness of the e-money business.
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New Activities:
• Scope of activities expanded and may include payment services;
• Other business activities – hybrid institutions (e.g. Mobile Phone companies).
Safeguarding of Funds:
• Repeal strict limitations on investments that e-money issuers could undertake;
• Alignment with PSD safeguarding requirements.
Waived entities (Small e-money institutions):
• Aligned with PSD.
Redeemability:
• Fine-tuned concept of redeemability – redemption at all times during or after
termination of contract.
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Electronic Money means electronically, including magnetically, stored monetary value
as represented by a claim on the issuer which is issued on receipt of funds for the
purpose of making payment transactions as defined in the PSD, and which is accepted
by a natural or legal person other than the issuer;
Key Elements of E-money Definition:
• Electronically, including magnetically, stored monetary value –
technologically neutral;
• Claim on the issuer;
• Purpose of making payment transactions only;
• Accepted by a natural or legal person other than the issuer – universally
acceptable.
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Categories of E-Money Issuers:
• Credit Institutions;
• Electronic Money Institutions;
• Post office giro institutions which are entitled under national law to provide
payment services;
• The ECB & national central banks when not acting in their capacity as
monetary authority or other public authorities;
• Member States or their regional or local authorities when not acting in their
capacity as public authorities.
• Title II of the EMD is only applicable to E-money Institutions.
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Title I: Scope and Definitions
• Negative Scope – Cross-reference to PSD negative scope but limited to just two
instances:
Limited network or limited range of goods and services;
Mobile payments
• Aimed at providing guidance to the industry and regulatory authorities … but
subjective.
Title II: General Prudential Requirements
• Substantial cross references to PSD prudential rules;
• Agents
E-money Institutions may distribute or redeem e-money through third parties – but not issue
e-money;
May passport distribution of e-money through third parties in another Member State;
May provide payment services through third parties.
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• Initial Capital
Reduced initial capital requirement from €1m to €350K;
• Own Funds
Own funds may not fall below the initial capital requirement or that required by
the Own Funds calculation;
Method ‘D’ for the Calculation of Own Funds - At least 2% of the average
outstanding e-money;
Where an e-money institution undertakes payment services, the Own Funds
Requirement for these services are to be calculated using Methods A, B or C;
Total Own Funds must be equal to the sum of both Own Funds calculations;
Competent Authorities are empowered to increase or decrease minimum Own
Funds requirement by 20%.
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• Waived entities – Small e-money Issuers
Waiver of certain prudential requirements for ‘small e-money issuers’ where:
Total business activities generate an average outstanding e-money that does
not exceed €5m (or a lower threshold set by Member State);
Suitability of persons responsible for the management or operations of the
business.
• Member State may set storage limit on payment instrument or payment account
where e-money is stored;
• ‘Waived’ entities may not passport but are to be included in Register.
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Title III: Issuance & Redeemability of E-money
• Prohibition for issuing e-money
Persons who are not e-money issuers may not issue e-money;
• Issuance and Redeemability
E-money issuers to issue e-money at par value of receipt of funds;
At request of e-money holder, e-money issuers redeem, at any moment and at par
value, the monetary value of the e-money held;
Contract to state conditions of redemption (including any fees);
Redemption subject to a fee only in 3 cases;
• Prohibition of Interest
Prohibition on granting of interest or other benefit related to the length of time during which
an e-money holder holds the e-money.
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Title IV: Final Provisions & Implementing Measures
• Amendments to Directive 2005/60/EC (3rd AML Directive)
Increase in the ceilings for exemptions for due diligence;
Non-rechargeable device – maximum amount €250;
Rechargeable device – maximum amount €2,500 per calendar year except when an
amount of €1,000 or more is redeemed in the same calendar year;
Member State Option – to increase €250 threshold to €500 for national payment
transactions.
• Amendments to CRD
Removal of e-money institution from definition of credit institution;
Insertion of e-money institution in definition of financial institution;
Added Point 15 – Issuing e-money to Annex 1 of CRD (List of activities).
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• Transposition exercise involved:
Amendments to the Banking Act;
Amendments to the Financial Institutions Act;
Amendments to existing Financial Institutions Rules;
Creation of a new Financial Institutions Rule FIR/03;
Repealing of the Electronic Money Directive EMD/01.
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Financial Institutions Act:
•
Streamlining of FIA provisions with EMD:
Article 2 – New definitions from EMD;
Article 3 – Provisions relating to ‘small e-money issuers’;
Article 8A – Amendments reflecting agents of e-money institutions;
Article 8F – Issuance and redeemability;
Article 10A – Prohibition of granting interest;
Article 26 – Consumer complaints – inclusion of holders of e-money;
Other minor amendments.
Sub-Article 3(7): ‘Small e-money Issuers’
•
The competent authority may waive the application of all or part of the provisions relating to
general prudential requirements, initial capital, own funds and safeguarding requirements, as
set out in this Act and in any Financial Institutions Rules applying to financial institutions
authorised to issue electronic money, in cases where:
(a) the total business activities of the company generate an average outstanding electronic
money that does not exceed the amount of €2 million; and
(b) none of the natural persons responsible for the management or operation of the company’s
business has been convicted of offences relating to money laundering or terrorist financing or
other financial crimes.
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Further amendments to FIA:
• Creation of the Third Schedule to the FIA which:
Set out the activities that may be undertaken by financial institutions that issue
electronic money.
Definitions transposed from EMD;
List of additional activities that electronic money institutions may undertake.
Financial Institutions Rule FIR/01:
• Minor amendments to reflect EMD provisions;
Financial Institutions Rule FIR/02:
• Insertion of Own Funds requirement for e-money institutions (Method D)
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Financial Institutions Rule FIR/03:
• Objective is to lay down all regulatory and supervisory procedures the MFSA
will adopt in respect of e-money institutions;
• Summarises the provisions of the FIA most relevant to e-money institutions and
provides technical guidance;
• Key Features:
General Prudential and Compliance Requirements;
Own Funds Calculation (Method D);
Small E-money Issuers;
Passporting;
Agents and Distribution Network.
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Positives:
•
•
•
•
•
Increased interest and take-up of e-money business;
Better understanding of e-money;
Alignment with PSD prudential regime;
Enable financial services industry to embrace fast pace of technological advancement;
Allows customers, including the un-banked, to have a payment instrument other than cash.
Negatives:
•
•
•
•
Negative Scope – highly subjective;
Variety of e-money propositions – varied risk profiles;
Passporting – Different transposition and interpretation across Member States;
Overlapping with PSD – Difficulty in establishing whether a product may be classified as emoney or as a payment account (PSD)
•
AML Issues:
Lower due diligence requirements (following changes to 3rd AML Directive);
AML set-up of EMIs considered weaker than credit institutions;
Anonymity of certain products – various fraud typologies developed by FATF;
Difficult balance between AML concerns and social concerns (e.g. provision of e-money services to
unbanked customers)
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• Study on the implementation of PSD already finalised;
• Study on impact of PSD on-going;
• Study on the implementation of EMD II to be launched in June 2012;
• Study on the impact of EMD II to be carried out in early 2013;
Way Forward:
• Possibility that PSD and EMD II will be merged into ONE Directive;
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Credit Institutions
E-Money
Institutions
Payment
Institutions
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Pierre-Paul Gauci
Analyst
Banking Supervision Unit
Tel: 00356 25485179
E-mail: ppgauci@mfsa.com.mt
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