Response to consultation on draft implementing technical standards for uniform reporting under the Single Euro Payments Area Regulation

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6. Are the instructions and templates in Annex I and II clear to you or do any of the terms therein require to be defined further?

  1. PSPS in cope

PSPs located in Monaco have reporting obligations under PSD2.  Is a PSP located in Monaco (branch of an European Bank) subject to this SEPA reporting ?

 

2. Type of transactions in scope

Are internal transfers between 2 accounts of a same client  or different clients in a same PSP in scope ? if yes should we report only  the debited amount (credit transfer) and not the credited amount ? . Should we report the debited amount only if it is in EUR ? if the payment account is in another currency should we ignore the transfer (situation where the PSP is located in a member State with EUR currency). Same question might apply to spot forex transactions ; should we report the debit leg if it is in EUR ? Those Sport Forex transactions are reported under PSD2 as Credit and Debit transfers.

Referred to : table 1 210 Total number of cross-border credit transfers:  "Total number of credit transfers initiated by a payer or by a payee where the payer’s PSP and the payee’s PSP are located in different Member States. Cross-border transactions are counted in the Member States in which the transaction originates." ; It is not clear  for  Direct Debit  which PSP should report? the Payee PSP as he is the originator of the transaction ? or the Payer PSP as it is a credit transfer.

 

3. Exchange conversion rates     

If fees are taken in a different currency than EUR  which rate should be used to convert the amount in EUR, Rate at the date when the fees where debited or a unique rate as of end of the reporting year,

 

4. fees

For client to whom we apply “all in fees”  and no specific maintenance payment account fees, should we report the all in fees ?

What is the difference between  Payment account maintenance charge (FID) and Payment account all charges (SOF). Please provide examples.

Name of the organization

Banque Pictet & Cie SA