aimm continually strive to work with regulatory bodies and industry leaders to ensure positive change that benefits our members’ businesses. See below for some of our achievements.
Payment Services Directive PSD2
September 2017 aimm posed significant questions and challenges to the FCA on their interpretation of the PSD2 Electronic Communications Networks (ECN) exclusion. aimm achieved a number of successes:
- Gaining a cascade of the ECN exclusion to encompass intermediaries processing the same payment. This prevents intermediaries from being caught in financial regulation as “Payment Acquirers”.
- aimm questioned the scope of a payment service, particularly with the PSD wording being changed by the UK government that potentially expanded scope. FCA guidance is that where the ECN is acting as “principle” in the supply of services to its consumer, then the transaction is not in scope of Payment Services Regulations.
- aimm also challenged FCA view that the “bill payer” was the individual subscriber referenced by the ECN exclusion, which meant any limits could apply to all phones on a single account. aimm have succeeded in establishing clarity on this point in that it is a single number (fixed line) or SIM (mobile). (This still presents difficulties for fixed line providers who may however be able to review how the clarity on scope can benefit them).
Took over the Charity Text Action Group from MDA
AIME took over the running of the CTAG working group from the Mobile Data Association, ensuring that the group, who's member include those from charities and social lotteries, as well as L1's could continue their work on Mobile Text Donations as well as other issues, allowing the improvement of regulation and charity processes.
Created Rapid Response Team
This small team of Industry professionals were put together to deal with urgent emerging market issues, ensuring that these are dealt with in a timely manner
AIME Early Warning System (EWS)
The AIME Early Warning System for advertisers enables them to warn each other of bad practices that they have encountered when conducting their own monitoring. The Early Warning System is a Digital Marketing Community blogging system designed to alert advertisers of malware and malpractices that have been spotted by other advertisers, anti-virus companies, PhonepayPlus, security specialists and other UK businesses. EWS goes hand in hand with the AIME Digital Marketing Guide. EWS is for use by both AIME Members and non members. Only Members have access to Member contributed content, but everyone has access to basic level information. All information is behind password control, and on first access you will be required to set up a new account to be able to login. All Digital Marketing advertisers and monitoring companies are encouraged to contribute information for sharing. Receive Twitter alerts from EWS by following @AIMEWarnings https://twitter.com/AIMEWarnings If you have any queries, or you want to get your new EWS account set up, email us on: email@example.com
Digital Marketing Guidance and Code of Practice
Best Practice Guidelines for Participation TV services using Mobile shortcode text and voice services introduced. Signed up to by main UK broadcasters.
Successfully re-introduced SMS services for PTV
Proposal for Higher Rate Premium Rate Services trial submitted to Ofcom
AIME submits White Paper to UK Treasury detailing the damage to all Members commercial interests that could be caused through changes to the European Payment Services Directive