Treasury Tinkers With Payment Account Transparency

When the UK government finally acted to improve transparency in retail banking fees and charges, it sparked a similar effort in Brussels that the UK negotiated to align with its own initiatives. This resulted in the Payment Accounts Directive which the UK implemented via the Payment Accounts Regulations 2015 (PARs). Unfortunately (as the FCA later pointed out) the Treasury 'gold-plated' the implementation, by simply cutting and pasting the Directive. The EU was due to review the Directive in 2019, though that is yet to complete. Meanwhile, the Treasury completed its own review in 2021. Struggling to find any 'Brexit benefits', the Treasury has come up with the wheeze of timing its consultation on how payment account fees are presented to consumers with the political gestures announced by the Chancellor today as some kind of post-Brexit renaissance for Britain's financial services industry, now starved of access to its biggest market. You have until 23 February to have your say on these particular changes [yawns].

Among other things required by the PARs, payment service providers must: 

• provide customers with a fee information document that sets out the fees associated with the payment account in a specific form (FID);
• provide each customer with a statements of fees incurred on the payment account in a given period (SoFs) in a specific form; 
• inform customers of whether it is possible to purchase a payment account separately, where it's offered as part of a package, and provide the consumer with separate information regarding the costs and fees associated with each of the other products in the package.

The Money and Pensions Service (MaPS) is also required to provide consumers with access to a website comparing fees charged by payment service providers (I challenge you to find this!).

The Treasury now wants to know your thoughts on the following questions:

Question 1 Do you consider the requirement for payment service providers to provide consumers with FIDs to have any positive impacts (e.g. supporting transparency and comparability of fee information related to payment accounts)?  

Question 2 Do you consider the requirement for payment service providers to provide consumers with FIDs to have any negative impacts (e.g. admin costs or duplication of information already provided)?  

Question 3 Do you consider the requirement for payment service providers to provide consumers with SoFs to have any positive impacts (e.g. supporting transparency and comparability of fee information)? 

Question 4 Do you consider the requirement for payment service providers to provide consumers with SOFs to have any negative impacts (e.g. administration costs or duplication of information already provided)?  

Question 5 Do you consider the presentational requirements (under Schedules 1 and 2 of the PARs) to be necessary? Could consumers be provided with the same or equivalent information by simpler or alternative means?  

Question 6 Do you consider the requirements for the FCA to maintain a linked services list, and for payment service providers to provide customers with a glossary of related definitions, to have any positive impacts (towards supporting transparency and comparability of fee information)? 

Question 7 Do you consider the requirement for the FCA to maintain a linked services list, and for payment service providers to provide customers with a glossary of related definitions, to have any negative impacts?  

Question 8 Do you consider the requirements for the Money and Pensions Service (MaPS) to provide consumers with access to a website comparing fees charges by payment service providers to have any positive impacts towards supporting transparency and comparability of fee information beyond private sector providers? Or could the same objectives be fulfilled without these specific requirements? 

Question 9 Where relevant, what are the costs to your organisation of adhering to Part 2 and Schedules 1 and 2 of the PARs?  

Question 10 Can you foresee any potential unintended consequences or negative impacts of removing any requirements under Part 2 and Schedules 1 and 2 of the PARs? 

Question 11 Do you have any other views on Part 2 and Schedules 1 and 2 of the PARs that you wish to share?