There is more to FTR 2015 than meets the eye, however. Concerns are mounting that FTR’s obligations are, in places, open to interpretation. Writing for Global Banking and Finance Review, Deutsche Bank’s Stefan Fruschki, Head of Regulatory Management, Institutional Cash Management, believes that if this lack of clarity goes unchallenged, there could be numerous repercussions for the payments sphere. These include inadvertent regulatory breaches and disciplinary action against senior managers (who are personally liable for the regulation’s observance).
“By evaluating FTR 2015’s implications, what becomes apparent is that financial institutions must not underestimate the scale of the incoming procedural change,” says Fruschki. “The danger, of course, is that PSPs are underprepared – deeming the changes more a minor evolution, rather than revolution. And given that the consequences of non-compliance are severe – above all for society – this is even more crucial.”
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