The Association of Foreign Exchange and Payment Companies
We agree with the reasoning.
Article 8(1)(b) states that the exemption applies where the payer initiates a contactless electronic payment transaction at a point of sale and the cumulative amount of previous non-remote electronic payment transactions initiated via the payment instrument offering a contactless functionality without application of strong customer authentication does not exceed €150. We think that this €150 limit should be for a set period of time, for example one day or one week. If there is no limit of time then the exemption will become meaningless quickly for a lot of payers.
Article 8(2)(d)(ii) states that the exemption applies where the payer initiates a remote electronic payment transaction where ...the individual amount does not exceed €10 and the cumulative amount of previous electronic payments transactions initialed by the payer without the application of strong customer authentication does not exceed €100. We think that the €100 limit should be reset after a certain period of time. If the €100 limit was cumulative and applied forever the exemption would become meaningless quickly for a lot of payers.
It would be useful to have a definition of electronic payment transaction. Does this definition include the PSP making the payment transaction when the instruction comes through an email or telephone. If so, what constitutes a non-electronic payment transaction.
Same as question 4.
Association of authorised payment institutions and electronic money institutions
Each of our member conducts foreign exchange and money remittance on behalf of their customers.