Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation
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5. Do you agree that, in light of the aims of the underlying regulation, there is a need for template S 04.00 to collect data on the number of rejected transactions on the side of the payer’s and payee’s PSP prior to the application of the IPR amendments to SEPA Regulation, and rejected transactions on the side of the payer’s PSP, and frozen funds on the side of the payee’s PSP, after the application of the IPR amendments to SEPA Regulation?
If a client is on the list of sanctioned entities, its account is frozen, so its ability to receive (and initiate) any payment will be blocked per se.
How are banks supposed to collect the number of instances when incoming funds have been frozen? They can only be rejected, because the payee's account is blocked.
So banks can only collect data on rejected transactions, both incoming and outgoing.