Consultations

HM Treasury are seeking views on legislative changes proposed to meet the requirements of the revised Payments Services Directive II (2015/2366/EU) (PSDII). The area that AIME is concentrating on is the "telecom exclusion" detailed in Article 3(l) of PSD, which assumes that a telecom provider, taking a payment for a third party service and adding that payment to the consumer telecoms bill is acting as a Payment Service Provider (PSP). PSP's have to register and be authorised by the FCA. The exclusion from registration covers a limited range of products and services that can be purchased with a maximum value and a maximum monthly spend. The other area of concern for AIME is that Networks Intermediaries, all the way to the merchant are potentially captured as "Payment Acquirers" requiring FCA registration. AIMEs response to Treasury answered the questions being posed and covered in detail, the operational environment of telecoms based payments to ensure Treasury could brief ministers correctly if required.

The Phone-paid Services Authority today publishes for consultation its Business Plan and Budget 2017/18. The consultation sets out how we seek to meet our strategic priorities and ensure consumer protection in the phone-paid services market.

aimm's response to this consultation is attached.

aimm welcomes the opportunity to respond to Phone-paid Services Authority Consultation on its proposals for developing the regulatory framework to ensure that the regulation of premium rate services and premium rate charging mechanics is fit for purpose as consumers and their surrounding technologies evolve. To assist aimm in providing a comprehensive input to Phone-paid Services Authority, aimm researched its Members in the following manner;

• Written input from Members
• One-to-one discussions
• Discussions inside aimm's Board and Member Working Groups

PRS development through outcomes-focussed regulation: A Review of Phone-paid Services Authoritys’ regulatory framework Phone-paid Services Authority have asked aimm and its members to contribute to a review of their regulatory framework consultation. aimm welcomes the opportunity to respond to Phone-paid Services Authority Consultation on its proposals for developing the regulatory framework to ensure that the regulation of premium rate services and premium rate charging mechanics is fit for purpose as consumers and their surrounding technologies evolve.

The UK Government announced at Autumn Statement 2013 that it would give intermediaries, operating within the charity sector, a greater role in administering Gift Aid. Since then, the Government has published provisions in Finance Bill 2015 and 2016 to support this aim. The Government has also produced draft secondary legislation which sets out, in detail, the way in which this greater role will work. This consultation sets out those draft Regulations and asks for comments to ensure they achieve the desired outcome. aimm believes that the outcome will be achieved for intermediaries, but not for a universal Gift Aid Declaration made for text based donations to multiple charities. The unintended outcome of this legislation is to incorrectly define an intermediary so that text Aggregators are affected, to require a citizen to renew their declaration annually and to force intermediaries to send statements to donors where a text message linking to an online statement would be adequate.