The BSA response to FCA CP17/11 Implementation of the revised Payment Services Directive (PSD2): draft Approach Document and draft Handbook changes is available here.

Summary of our response:

• There is a need for further guidance on what elements of the PSR 2017 apply to non-Payment Accounts.
• We are concerned over the proposals to provide or make available a monthly statement. We wish to see the current arrangements continue, but if that is not an option, we would support the move to monthly statements over the requirement to send out notifications immediately after every transaction on a Payment Account.
• We are concerned that the proposed changes to complaint handling times will create a two-tier process, which will be confusing for customers and a significant burden for firms.
• We call for more clarity around the fraud reporting requirements.
• We are broadly supportive of the remaining proposals.