The Association of Foreign Exchange and Payment Companies

Yes.
Yes.
No.
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.
Yes.
Yes.
No comment.
No comment.
No comment.
[Other "]"
Association of authorised payment institutions and electronic money institutions
[Other"]"
Each of our member conducts foreign exchange and money remittance on behalf of their customers.
Richard Creed