Published on 8th December 2023

We have sent Joe Garner c/o HM Treasury a 5-page letter with our response to the report from the Future of Payments Review.

You can download the letter here

As Lyddon Consulting was cited as one of ‘the more than 100 organisations who contributed to this report’, I felt entitled to submit a response, especially as what I actually did was to submit a response to the Call for Input, but I was not involved in the processing of the inputs or the creation of the report.

The report’s outcome is a triumph of the PR machine for Open Banking. All roads seem to lead there – the Natalie Ceeney Access to Cash exercise and the Payment Systems Regulator’s Digital Payments Inititaive, to name but two others.

Now it had better deliver, but not before we see several other preparatory streams of work carried out:

• Card fees – legal examination of the validity of the charging of fees with different names than ‘interchange fee’ when the wording of the preamble to the EU Interchange Fee Regulation uses that term as a catch-all for any and all deductions-from-face-value, meaning that the interchange fee is the only cost that can fall on a merchant other than the remuneration paid to the acquirer under the contract between the merchant and their acquirer
• APPF – operational/legal review of the interplay between the Faster Payments process and technical message specifications, the 2017 Payment Services Regulations, existing case law, and the upshot that payers must state the beneficiary name but payment service providers do not have to check or process it
• Open Banking – rigorous verification of Open Banking’s statistics on its supposed success. We wouldn’t want so much of the responsibility for garnering the future benefits from payments to be invested in an initiative that had so far been a failure