GRTU calls for Commission proposals relates to electronic payments to go further

GRTU Deputy
President Philip Fenech has attended a consultation session organized by MEUSAC
on the ‘Proposal on interchange fees for card-based payment transactions'
and  the ‘Proposal on the comparability
of fees related to payment accounts, payment account switching and access to
payment accounts with basic features'.

The
continued development of the single market in the area of financial services is
of primary importance for Europe's growth and competitiveness. However
obstacles to a fully integrated internal market for financial services remain.
In the field of retail financial services, The Single Market Act I (SMA I)
stated that particular regard should be given, "to the transparency of
bank fees and better protection of borrowers in the mortgage market1". The
Commission also announced, "an initiative concerning access to a basic
payment account for all citizens at a reasonable cost, wherever they live in the
EU" in order to enable all citizens to participate actively in the single
market.

Previous
initiatives in the field of retail banking have not only improved the ability
of payment service providers to operate cross-border, but have brought
substantial benefits to many European consumers, in particular through cheaper
transactions, faster payments and more transparent conditions and prices. The
Payment Services Directive (2007/64/EC) provides certain transparency
obligations with respect to the fees charged by payment service providers. This
initiative has contributed to substantially shorten the time required to
execute transactions and increase the consistency of the information provided
to consumers in relation to their payment services.

While
measures to complete the single market for financial services should generate
growth and enhance business opportunities for providers of financial services,
their impact on consumers is also of vital importance. At present, the opacity
of payment account fees makes it difficult for consumers to make informed
choices. Even where fees are comparable, the process for switching from one
payment account to another is often lengthy and complex. As a result, consumers
still show a very high degree of inertia with respect to payment accounts.

The
proposals aim to: improve the transparency and comparability of fee information
relating to payment accounts; facilitate switching between payment accounts;
eliminate discrimination based on residency with respect to payment accounts;
and provide access to a payment account with basic features within the EU. They
will contribute to easier market entry, increased economies of scale and
therefore increased competition in the banking and payment industries, both
within and across Member States. Taking steps to simplify the comparison of
services and fees offered by payment services providers and facilitate the
process of switching between payment accounts will, in turn, improve prices and
services for consumers. This proposal will also guarantee access to basic
payment services to all EU consumers and prohibit discrimination based on
residency against consumers who intend to open a payment account abroad, to the
benefit of both payment service providers and consumers.

GRTU, in
line with the position taken by EuroCommerce, has long been calling for more
transparency and competition in the payments market. We welcome the package of
proposed payments legislation announced on 24 July 2013 but we feel that
current proposals do not go far enough.

In
Europe, millions of businesses accept millions of payment transactions each
day. For these companies, large and small, payments are an essential part of
their business, and the fees charged (multilateral interchange fees – MIFs) can
contribute significantly to their operating costs. On their behalf, we call for
the full potential of the Single European Payments Area (SEPA) to provide
low-cost payments across Europe to be realised. A reduction in the cost of
payments will allow European payment users to adopt innovative payment
solutions and realise cost savings that will benefit consumers.

Philip
Fenech put foreword a joint statement by EU level representatives of payment
users, amongst which EuroCommerce and UEAPME, that suggest the below
amendments:

1.   Debit: Provide an interchange-free electronic debit service for all
citizens by mandating the removal of the interchange fee on consumer debit
cards. As an alternative, any fee should be set as a maximum fixed cap in line
with current best practice at national level.

2.   Credit: Lower the proposed caps for electronic credit
cards/applications. This cap should be lowered proportionately in line with
lowered debit caps.

3. Commercial cards: Include
commercial payment cards/applications within the scope of the proposed fee caps.
The current proposal to exempt commercial cards from caps is unjustified
economically and risks creating loopholes. Distinguishing commercial cards from
consumer cards will also give rise to significant technical and practical
problems.

4.   Three-party schemes: Mandate a mechanism to include consumer and
commercial cards issued by three-party schemes within the fee caps.

5.   Implement the Regulation immediately. Cross-border caps should
begin within 2 months of adoption of the Regulation and national caps within 6
months, with a year as absolute maximum. The proposed two year deadline for
national implementation is not technically necessary and would adversely affect
mainly SMEs and consumers since the greatest burden of interchange fees is felt
at national level.