Payment Systems Regulator’s (PSR) consultation CP24/3: The FPS APP scams reimbursement requirement: compliance and monitoring - Which? response

Which? welcomes the opportunity to respond to the PSR consultation on the FPS APP scams reimbursement requirement: compliance and monitoring (CP 24/3). While much of the consultation is directed at PSPs in-scope of the reimbursement requirement policy, Which? has a strong interest in ensuring that the mandatory reimbursement system delivers a step-change in the level of protection offered to consumers, and we recognise the important role that compliance and monitoring requirements have to play in delivering this. 

We do not respond to the specific questions set out in the consultation document but make a number of key points for the PSR to take account of:

• Clear record-keeping and reporting requirements are essential to determine whether the mandatory reimbursement scheme is operating as intended, and to identify problems or shortcomings.
• It is essential the roles of PSR and Pay.UK are clearly delineated. The PSR must not hesitate to intervene to address non-compliance where Pay.UK is unable to do so.
• The phased approach will expedite implementation but must not compromise the ability of Pay.UK or PSR to assess firms’ compliance or take action where necessary.
• We have concerns that proposals for the data firms must collect and report to Pay.UK about vulnerability will make it difficult to assess how firms are performing.
•  PSR should strengthen its requirements on firms in relation to record-keeping.
•  Complex cases may be more prevalent than the PSR expects. It should include contingency plans to deal with larger numbers.