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?

No. Please define the following further:
Questions to S 01.00

  1. 0010: Are transactions between customers’ own accounts considered as credit transfers?
  2. 0030: For non-Euro countries should we convert credit transfers in other currencies than national currency to national currency? In that case which exchange currency rate should be used?
  3. 0150: Should MFI be considered as PSU other than consumer?
  4. 0170: Could you provide definition of ‘credit transfers that can be initiated by the payee’? Is that a direct debit? According to PSD2 article 4(24) a credit transfer is only initiated by a payer. 
  5. 0210: Are third territories e.g. Vatican state, Monaco, Martinique, Andorra, etc. considered as countries within EU? 

 

 

Questions to S 02.00

  1. 0010: Should we exclude the credit transfers that are a part of pre-paid package since they are included in S 01.00 field 0050? 
  2. 0070 and 0090: Since it is not allowed to have different charges for domestic and cross-border payments, should we have the breakdown? 

 

Questions to S 03.00

  1. 0020: Please elaborate on maintenance fee and provide a definition. 
  2. 0030: If the customer pays an annual fee for a package that includes both services and accounts, what should we report in 0030?
  3. 0030: Does this field apply only to the consumers? 

Name of the organization

SEB