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SEPA Direct Debit Scheme Rulebook Bundesverband

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					                                                                                     EPC140-12
                                                                                     Version 1.0
                                                                                   16 May 2012
                                                                                             EPC


                   SEPA B2B DIRECT DEBIT SCHEME RULEBOOK
                               CHANGE REQUEST
                          CONSULTATION DOCUMENT
The Single Euro Payments Area (SEPA) payment schemes, as set out in the SEPA Credit Transfer
(SCT), the SEPA Direct Debit (SDD) Core Rulebook and the SDD Business to Business (B2B)
Rulebook, evolve based on a transparent change management process adhered to by the European
Payments Council (EPC). For details on the principles governing the annual EPC scheme change
management process, refer to chapters 5and 6 in this document and the sources listed at the end of
this page.
This SDD B2B Change Request 2012 (document EPC140-12) details suggestions for possible
modifications to be introduced into the next version of the SDD B2B Rulebook. This consultation
document builds on suggestions for changes submitted by customer representatives, banking
communities and by EPC Working and Support Groups. The SDD B2B Change Request 2012 offers
the recommendations of the EPC SEPA Payment Schemes Working Group (SPS WG) on the way
forward with regard to individual suggestions. An overview of the suggestions for changes and
related recommendations by the SPS WG is provided on pages 4 and 5 of this Change Request.
The EPC submits the SDD B2B Change Request 2012 for public consultation. The 2012 public
consultation takes place between 16 May and 13 August 2012. All stakeholders are encouraged
to provide feedback on the possible changes to be introduced into the next version of the SDD
B2B Rulebook.
   •   To share your feedback on this Change Request, please complete the online questionnaire
       posted at http://www.smart-survey.co.uk/v.asp?i=52471iyxtm.Please send your response by
       13 August 2012.
   •   Should you encounter any technical difficulties in accessing or completing this
       questionnaire, please contact the EPC Secretariat at secretariat@epc-cep.eu.
Proposed changes detailed in this SDD B2B Change Request 2012, which are broadly accepted by
all stakeholders, are taken forward. The updated version of the SDD B2B Rulebook will be
published in November 2012. In accordance with industry best practice, payment service providers
and their suppliers have a one-year lead time to address rulebook updates prior to such updates
taking effect.
 The following general background information is made available for further information:
   •   Extract SEPA Scheme Management Internal Rules (section 3: development and evolution).
   •   EPC Newsletter: ‘EPC Scheme Change Management: Annual Public Consultation Starts in
       May 2012’ (Issue 14, April 2012).
 It should be noted that the EPC’s analysis of the SEPA Regulation and its impact on the
 EPC Rulebooks is continuing. The EPC therefore reserves the right to make the necessary
 changes to the schemes (in addition to those described in chapter 3) in order to ensure
 compliance with this Regulation.
    Please refer to Annex I for the original detailed suggestions for changes. This document
                     contains only a summary of each individual suggestion.



               Conseil Européen des Paiements AISBL– Av. de Tervueren 12 – B 1040 Brussels
                          Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                   Enterprise N° 0873.268.927 www.epc-cep.eu secretariat@epc-cep.eu
                                                  TABLE OF CONTENTS


 1    Executive Summary: Suggestions for Major Changes to the SEPA direct debit B2B Rulebook 4
  1.1    Summary of suggestions for changes and proposed way forward for consideration by
  respondents to this public consultation ............................................................................................ 5
 2 Detailed Analysis of Suggestions for Major Changes to the SDD B2B Rulebook ................... 10
  2.1   Clarification on sequence verification .............................................................................. 10
  2.2   Inclusion of new reject codes............................................................................................ 11
  2.3   Extension of return period ................................................................................................ 12
  2.4   Mandate digitization ......................................................................................................... 13
  2.5   Inclusion of new reason code in AT-R3 ........................................................................... 14
  2.6   Deletion of the usage rule of AT-10 ................................................................................. 15
  2.7   Allowing electronic mandate / signature .......................................................................... 16
  2.8   Notification to Creditor in case of change in debtor’s details........................................... 17
  2.9   Notification to Creditor in case of change of debtor banking details ............................... 18
  2.10  The use of International Bank Account Number (IBAN) only procedure on mandates... 19
  2.11  The use of Basic Bank Account Number (BBAN) and national sorting code instead of
  IBAN on the mandate .................................................................................................................... 20
  2.12  Clarification on mandate guidelines ................................................................................. 21
  2.13  Allowing longer remittance information .......................................................................... 22
  2.14  Waiving of the obligation to issue a pre-notification Description .................................... 24
  2.15  Unique Mandate Reference to be space insensitive.......................................................... 25
  2.16  Clarification on the use of AT-21 ‘transaction type’ ........................................................ 26
  2.17  Clarification on one-off collections .................................................................................. 27
  2.18  Inclusion of the possibility of a shorter notice period for the termination of participation
        28
  2.19  Notices given under the Rulebook .................................................................................... 29
  2.20  Refund right ...................................................................................................................... 31
 3 Changes pertaining to the impact of the ‘SEPA Regulation’ (Regulation (EU) No 260/2012) 32
  3.1  Common legal framework ................................................................................................ 32
  3.2  Definition of a payment scheme ....................................................................................... 32
  3.3  “IBAN only” ..................................................................................................................... 32
  3.4  Validity of legacy mandates ............................................................................................. 32
  3.5  Interchange Fees ............................................................................................................... 32
 4 Changes to the Rulebook for clarification, updating and correction of errors .......................... 33
  4.1   Introduction....................................................................................................................... 33
  4.2   Proposed changes.............................................................................................................. 33
 5 principles governing the Change Request Process .................................................................... 39
  5.1  Change Request ................................................................................................................ 39
  5.2  Structure of the Change Request ...................................................................................... 39
 6 Change management process in respect of Major Changes ...................................................... 40


EPC140-12 SDD B2B Change Request 2012                                                                                                     2
  6.1  Consideration of Suggestions ........................................................................................... 40
  6.2  Change Request ................................................................................................................ 40
  6.3  Cost-benefit analysis and business case for the Change Request ..................................... 40
  6.4  Consultation on the Change Request ................................................................................ 41
  6.5  Feedback from consultation .............................................................................................. 41
  6.6  Next steps.......................................................................................................................... 41
  6.7  SPS WG recommendation ................................................................................................ 41
  6.8  Further information........................................................................................................... 41
 7 Change management process in respect of Minor Changes ...................................................... 42
  7.1    Publication of list of minor changes ................................................................................. 42
  7.2    Comments on the minor changes ...................................................................................... 42
  7.3    Submission of the list of minor changes to the EPC Plenary ........................................... 42
  7.4    Publication of changes ...................................................................................................... 42
 Annex 1 - Original Change Requests............................................................................................... 43




EPC140-12 SDD B2B Change Request 2012                                                                                                     3
1      EXECUTIVE SUMMARY: SUGGESTIONS FOR MAJOR CHANGES TO THE
       SEPA DIRECT DEBIT B2B RULEBOOK

 The principles governing the evolution of the Single Euro Payments Area (SEPA) payment
 schemes as set out in the SEPA Credit Transfer (SCT) and SEPA Direct Debit (SDD) Rulebooks
 are detailed in the ‘SEPA Scheme Management Internal Rules’ (the Internal Rules). These Internal
 Rules are available for download on the European Payments Council (EPC) Website. Chapters 5, 6
 and 7 in this SDD B2B Change Request 2012 document detail the application of the Internal Rules
 in the annual EPC scheme change management process.

    The Internal Rules differentiate between so called major and minor changes to the scheme
    rulebooks. A major change is a change that affects or proposes to alter the substance of the
    rulebooks and the schemes. Any change to chapters 5 and 6 of the rulebooks are always considered
    a major change. A minor change is a change of an uncontroversial and usually technical nature that
    facilitates the comprehension and use of the rulebooks.

    This executive summary of the SDD B2B Change Request 2012 highlights suggestions for major
    changes to the SDD B2B Rulebook received in the 2012 scheme change management cycle.
    Suggestions for minor changes to the SDD B2B Rulebook are set out in chapter 4 of this Change
    Request. All suggestions for changes to the SDD B2B Rulebook are submitted for public
    consultation between 16 May and 13 August 2012. Information on how to share feedback with the
    EPC is included on the cover page of this Change Request.

 The EPC received 22 suggestions for major changes to be introduced into the SDD B2B Rulebook.
 Five additional suggestions for changes reflect the need to align the SDD B2B Rulebook with the
 ‘Regulation (EU) No 260/2012 establishing technical and business requirements for credit transfers
 and direct debits in euro and amending Regulation (EC) No 924/2009' (the SEPA Regulation),
 which was adopted by the European Union legislator in February 2012. The suggestions for
 changes submitted to the EPC are included in Annex 1 to this document. It should be noted that the
 EPC’s analysis of the SEPA Regulation and its impact on the EPC Rulebooks is continuing. The
 EPC therefore reserves the right to make the necessary changes to the schemes (in addition to those
 described in chapter 3) in order to ensure compliance with this Regulation.

 All suggestions for changes to the SDD B2B Rulebook received were reviewed by the EPC SEPA
 Payment Schemes Working Group (SPS WG). This Change Request includes the recommendation
 of the SPS WG with regard to each of these suggestions. Each recommendation reflects one of the
 options detailed in items a) through f) below:

 a) The suggestion for change is already provided for in the scheme.
              •   No action is necessary for the EPC.
 b) The suggestion for change should be incorporated into the scheme.
              •   The suggestion for change becomes part of the scheme and the rulebook is amended
                  accordingly.
    c) The suggestion for change should be included in the scheme as an optional feature.
              •   The new feature is optional and the rulebook will be amended accordingly.
              •   Each scheme participant 1 may decide to offer the feature to its customers, or not.


 1
     A scheme participant is a payment service provider which has formally adhered to a SEPA Scheme.

EPC140-12 SDD B2B Change Request 2012                                                                   4
 d) The suggestion for change is not considered fit for SEPA wide use and could be handled as
 an additional optional service (AOS) by interested communities.
           •   The proposed new feature is not included in the rulebook or in the implementation
               guidelines released by the EPC with regard to the rulebooks.
           •   The development of AOS is out of scope of the EPC. The EPC does however
               publish declared AOS arrangements on its website for information.
           •   The EPC may consider the inclusion of AOS arrangements, if supported by a
               sufficient number of communities, in a future version of the rulebook.
 e) The suggestion for change cannot be part of the existing scheme.
           •   It is technically impossible.
           •   It is not feasible (explained on a case by case basis).
           •   It is out of scope of the EPC.
 f) The suggestion for change may be considered for the development of a new scheme.
           •   The suggestion reflects major changes which cannot be integrated into an existing
               scheme.
           •   To develop the suggestion for change further, i.e. to develop a new scheme, the
               following requirements should be met:
                        The benefits of the new scheme for bank customers are demonstrated prior
                         to the launch of the development phase.
                        It is demonstrated that a sufficient number of stakeholders will make use of
                         the new scheme.
                        A cost-benefit analysis is provided.

1.1    Summary of suggestions for changes and proposed way forward for
       consideration by respondents to this public consultation

The below table lists all the received suggestions for change which are submitted for public
consultation. The SPS WG has issued a recommendation on the way forward with regard to each
suggestion; the reasons underlying each recommendation are detailed in chapter 2. The final
decision whether a suggested change will be incorporated into the rulebook is however subject to the
outcome of the public consultation.

The contributors to this public consultation are requested to indicate whether they agree with
the recommendation of the SPS WG on the way forward. In case the contributors do not agree
with the SPS WG recommendation, they are requested to indicate their preferred way
forward.

Ref.                    Topic                     Contributor             Recommendation of the
                                                                         SPS WG on the proposed
                                                                          way forward. The final
                                                                         decision is subject to the
                                                                           outcome of the public
                                                                               consultation.




EPC140-12 SDD B2B Change Request 2012                                                             5
Ref.                Topic                   Contributor         Recommendation of the
                                                               SPS WG on the proposed
                                                                way forward. The final
                                                               decision is subject to the
                                                                 outcome of the public
                                                                     consultation.
2.1    Clarification on sequence          Cedacri Spa          Not a change request but a
       verification                                            question for clarification –
                                                               will be clarified in FAQ
                                                               document
2.2    Inclusion of new reject codes      French banking       Should be incorporated into
                                          community            the scheme – option b
2.3    Extension of return period         BVR, VÖB,            The suggestion cannot be
                                          DSGV                 part of the existing scheme –
                                                               option e
2.4    Mandate digitization               Dutch banking        Already provided for in the
                                          community,           scheme – option a
                                          Bitkom
2.5    Inclusion of new reason code       Dutch banking        Already provided for in the
       in AT-R3                           community            scheme – option a
2.6    Deletion of usage rule of AT-      Spanish banking      The suggestion cannot be
       10                                 community            part of the existing scheme –
                                                               option e
2.7    Allowing electronic mandate /      Bitkom, InterCard,   Already provided for in the
       signature                          Handelsverband       scheme – option a
                                          Deutschland,
                                          easycash, TeleCash
                                          & BP Europa

2.8    Notification to creditor in case   Bitkom               The suggestion cannot be
       of change in debtor’s details                           part of the existing scheme
                                                               as it is out of scope of the
                                                               EPC – option e
2.9    Notification to creditor in case   Bitkom               The suggestion cannot be
       of change of debtor banking                             part of the existing scheme
       details                                                 as it is out of scope of the
                                                               EPC – option e
2.10   The use of International Bank      Bitkom               Should be incorporated into
       Account Number (IBAN) only                              the scheme – option b
       procedure on mandates




EPC140-12 SDD B2B Change Request 2012                                                     6
Ref.                 Topic                   Contributor         Recommendation of the
                                                                SPS WG on the proposed
                                                                 way forward. The final
                                                                decision is subject to the
                                                                  outcome of the public
                                                                      consultation.
2.11   The use of Basic Bank               Bitkom               The suggestion cannot be
       Account Number (BBAN) and                                part of the existing scheme
       national sorting code instead of                         as it is out of scope of the
       IBAN on the mandate                                      EPC – option e
2.12   Clarification on mandate            Bitkom               The suggestion cannot be
       guidelines                                               part of the existing scheme –
                                                                option e
2.13   Allowing longer remittance          Bitkom, InterCard,   The suggestion cannot be
       information                         Handelsverband       part of the existing scheme –
                                           Deutschland,         option e
                                           easycash, TeleCash
                                           & BP Europa

2.14   Waiving of the obligation to        Bitkom               The suggestion cannot be
       issue a pre-notification                                 part of the existing scheme –
                                                                option e
2.15   Unique mandate reference            Bitkom               The suggestion cannot be
       (UMR) to be space insensitive                            part of the existing scheme –
                                                                option e
2.16   Clarification on the use of AT-     Bitkom               Not a change request but a
       21 ‘transaction type’                                    question for clarification –
                                                                will be clarified in FAQ
                                                                document
2.17   Clarification on one-off            Bitkom               Not a change request but a
       collections                                              question for clarification –
                                                                will be clarified in FAQ
                                                                document
2.18   Inclusion of the possibility of a   EPC Legal Support    Should be incorporated into
       shorter notice period for the       Group (LSG)          the scheme – option b
       termination of participation

2.19   Notices given under the             LSG                  The suggestion cannot be
       rulebook                                                 part of the existing scheme –
                                                                option e
2.20   Wording correction of 5.9.1         LSG                  Should be incorporated into
                                                                the scheme – option b



EPC140-12 SDD B2B Change Request 2012                                                      7
Ref.                   Topic                    Contributor      Recommendation of the
                                                                SPS WG on the proposed
                                                                 way forward. The final
                                                                decision is subject to the
                                                                  outcome of the public
                                                                      consultation.
2.21    Refund right                          LSG               The suggestion cannot be
                                                                part of the existing scheme –
                                                                option e



 Summary of changes which will be included in the next version of the SDD Core
 Rulebook to align the rulebook with Regulation 260/2012. The contributors to this
 public consultation are welcome to comment on these changes.

3.1     Common legal framework: in line       SPS WG & LSG      Should be incorporated into
        with Article 1(1) of the SEPA                           the scheme – option b
        Regulation, it is proposed to add a
        new section to all rulebooks to
        make reference to the common
        legal framework for the SCT and
        SDD Schemes.

3.2     Definition of a payment scheme:       SPS WG & LSG      Should be incorporated into
        in line with Article 2(7) of the                        the scheme – option b
        SEPA Regulation, it is proposed
        that wording be added to section
        1.1 of all rulebooks to state that
        the SCT and SDD Schemes are
        schemes in the sense of this
        Article.

3.3     Alignment of the rulebooks and        SPS WG & LSG      Should be incorporated into
        implementation guidelines with                          the scheme – option b
        provisions in the SEPA
        Regulation concerning the use of
        the International Bank Account
        Number (IBAN) and the Business
        Identifier Code (BIC) in line with
        Articles 5(1), 5(2), 5(4) and 5(7)
        of the SEPA Regulation (‘IBAN
        only’ rule)

3.4     Alignment of the rulebooks with       SPS WG & LSG      Should be incorporated into
        the provisions of the SEPA                              the scheme – option b
        Regulation concerning the
        validity of legacy mandates in
        line with Article 7




EPC140-12 SDD B2B Change Request 2012                                                     8
3.5    Alignment of the rulebooks with   SPS WG & LSG   Should be incorporated into
       the provisions of the SEPA                       the scheme – option b
       Regulation concerning
       interchange fees in line with
       Article 8




EPC140-12 SDD B2B Change Request 2012                                            9
2      DETAILED ANALYSIS OF SUGGESTIONS FOR MAJOR CHANGES TO THE
       SDD B2B RULEBOOK

2.1      Clarification on sequence verification

2.1.1      Description

 This suggestion was made by Cedacri Spa, Italy. It is suggested to clarify if the sequence of
    the collection must be verified in accordance with collections previously received under the same
    mandate and if the abnormal sequence of a collection must be understood as a reason for rejecting
    or returning the collection.

2.1.2      SPS WG analysis and recommendation

    It is up to the debtor bank to decide on the checking of the sequence and on whether the incorrect
    sequence type should be treated as a reason for rejection or returning.

    The SPS WG considers this as a request for clarification rather than a change suggestion and it is
    included in this document for the sake of completeness. It is proposed to add this clarification in a
    Frequently Asked Questions (FAQ) document which will be published on the EPC website.




EPC140-12 SDD B2B Change Request 2012                                                                 10
2.2     Inclusion of new reject codes

2.2.1    Description

 This suggestion was made by the French banking community. They propose making
 rejects possible because either the destination bank or the originator bank is not registered
 within the clearing and settlement (CSM) reference data. The French banks propose to add
 two new reasons (“Beneficiary Bank not registered under this BIC in the CSM” and
 “Originator Bank not registered under this BIC in the CSM”).

2.2.2    SPS WG analysis and recommendation

 The SPS WG recommends that the suggestion be incorporated into the scheme and the
 reason codes added to the rulebook and implementation guidelines (IGs) (option b).

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a        Yes.
 case for wide SEPA market
 acceptance?

 Is the change underpinned        No.
 by a cost-benefit analysis?

 Is the change feasible to        Yes; only a minor impact on rulebook and IGs.
 implement?

2.2.3    Rulebook Impact

 This change will impact both the rulebook and the IGs as new reason codes must be added.




EPC140-12 SDD B2B Change Request 2012                                                      11
2.3     Extension of return period

2.3.1    Description

 This suggestion was made by Bundesverband der Deutschen Volksbanken und
 Raiffeisenbanken (BVR), Bundesverband Öffentlicher Banken Deutschlands (VÖB) and
 Deutscher Sparkassen- und Giroverband (DSGV). The suggestion is to extend the return period
 to 3 TARGET business days, i.e. until D+3 instead of D+2.

2.3.2    SPS WG analysis and recommendation

 The SPS WG recommends not taking forward this suggestion for change as it is not
 feasible to incorporate this change into the scheme (option e).. The fundamental principle –
 and main benefit – of the SDD B2B is to guarantee finality of the transaction after the two days
 allowed for refunds by the debtor bank. Extending this short time cycle would therefore undermine
 this fundamental principle and eliminate the main benefit of the B2B Scheme.

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a         No.
 case for wide SEPA market
 acceptance?

 Is the change underpinned         No.
 by a cost-benefit analysis?

 Is the change feasible to         It would be technically feasible to implement this
 implement?                        suggestion for change. Incorporating this change
                                   would however undermine one of the fundamental
                                   principles of the SDD B2B and eliminate its main
                                   benefit.

2.3.3    Rulebook Impact

 If this suggestion for change were supported by the broad majority of all SEPA
 stakeholders, this would have a significant impact on the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                         12
2.4     Mandate digitization

2.4.1    Description

Two similar suggestions concerning mandate digitalization were presented both by the
Dutch banking community and by Bitkom, Germany.

The Dutch banking community proposed to add a clarification in the rulebooks to state that
if a correct SEPA-mandate is digitized according to the legal requirements and conditions, a
copy must be considered “valid” by the debtor banks e.g. for investigation of unauthorised
transactions.

The proposal of Bitkom requested that the obligation to store the original mandate and its
changes (in paper format) should be avoided and that an audit-proofed archiving of the
digitalized mandates and the digitalized mandate changes should be enough.

2.4.2    SPS WG analysis and recommendation

The SPS WG considers that this issue is already covered in the rulebooks (section 4.1) where it is
stated that mandates must be stored according to the requirements of national legislation (option a).
It cannot be stated in the rulebooks that digitalised mandates must always be accepted by debtor
banks as national legislations differ in this regard within SEPA countries.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a           N/A – already provided for in the Scheme..
 case for wide SEPA market
 acceptance?

 Is the change underpinned           N/A – already provided for in the Scheme..
 by a cost-benefit analysis?

 Is the change feasible to           N/A – already provided for in the Scheme..
 implement?

2.4.3    Rulebook Impact
N/A as suggestion is already covered in the rulebook to the extent possible.




EPC140-12 SDD B2B Change Request 2012                                                             13
2.5     Inclusion of new reason code in AT-R3

2.5.1    Description
This suggestion was made by the Dutch banking community. It is proposed to add new reason code:
‘transaction type incorrect’ in AT-R3.

2.5.2    SPS WG analysis and recommendation
The SPS WG considers that this suggestion is already provided for in the scheme as there is already
a reason code for this in the Rulebooks as AT-R3 includes the reason code “Operation/transaction
code incorrect, invalid File format”(option a). It is however proposed to enhance the AT-R3 reason
code description “Operation/transaction code incorrect, invalid File format” to
“Operation/transaction/sequence type code incorrect, invalid File format” in order to cover in the
wording the issue of a wrong sequence type (this applies also for suggestion described in section
2.17).
In order to make a differentiation between incorrect transaction or sequence type code and invalid
file format, a change to the ISO external code list is required.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a          N/A – already included in the Rulebook.
 case for wide SEPA market
 acceptance?

 Is the change underpinned          N/A – already included in the Rulebook.
 by a cost-benefit analysis?

 Is the change feasible to          N/A – already included in the Rulebook.
 implement?

2.5.3    Rulebook Impact

 Only a minor wording addition in the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                            14
2.6     Deletion of the usage rule of AT-10

2.6.1    Description

This suggestion was made by the Spanish banking community. The suggestion is to delete the usage
rule of AT-10 (the creditor’s reference of the direct debit collection”) in the interbank IGs.

2.6.2    SPS WG analysis and recommendation

The SPS WG considers that this suggestion cannot be part of the existing scheme as the field is
mandatory in the ISO20022 standard developed by the International Organization for
Standardization (ISO) (option e). For more information, refer to the ISO 20022 website
(www.iso20022.org). Therefore, the creditor bank has to provide this field in the inter-bank
message even if no reference was received from the creditor.

Banks offering an SDD initiation service in a non-ISO environment should mandate the creditor to
provide this reference.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a          No.
 case for wide SEPA market
 acceptance?

 Is the change underpinned          No.
 by a cost-benefit analysis?

 Is the change feasible to          No. The EPC IGs are a subset of the global ISO 20022
 implement?                         message standards. The EPC is not in a position to
                                    unilaterally change fields which are mandatory in the ISO
                                    20022 standard.

2.6.3    Rulebook Impact
N/A.




EPC140-12 SDD B2B Change Request 2012                                                             15
2.7       Allowing electronic mandate / signature

           2.7.1 Description

 This suggestion was made by Bitkom, Germany. It is proposed that in future electronic
 mandates with electronic signatures should be permitted based on:
      •    the qualified electronic signature
      •    the authentication via the new identity card without qualified electronic signature
      •    the signature with the help of a signature pad
      •    via the Double-Opt-In-Procedure
 A similar request was made jointly by InterCard, Handelsverband Deutschland, easycash,
 TeleCash & BP Europa (Germany).

           2.7.2 SPS WG analysis and recommendation

The SPS WG considers that this suggestion is already provided for in the scheme as the rulebook
already allows the use of electronic signatures (option a).

It is proposed however to add “electronic signature” in the glossary to clarify that electronic
signatures must be legally valid (a qualified electronic signature).

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a              N/A – already included in the Rulebook.
 case for wide SEPA market
 acceptance?

 Is the change underpinned              N/A – already included in the Rulebook.
 by a cost-benefit analysis?

 Is the change feasible to              N/A – already included in the Rulebook.
 implement?

           2.7.3 Rulebook Impact
N/A as this is already allowed in the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                             16
2.8        Notification to Creditor in case of change in debtor’s details

            2.8.1 Description

 This suggestion was made by Bitkom, Germany. The suggestion is that changes of mandate
 by the debtor should be communicated by the debtor via:
      a)    mail
      b)    fax
      c)    internet
      d)    telephone

            2.8.2 SPS WG analysis and recommendation

The SPS WG considers that this suggestion cannot be part of the existing scheme as this issue is out
of scope of the rulebook and the EPC (option e). Any communication between the debtor and the
creditor can be done in a manner agreed between the parties bilaterally according to the rules stated
in the SDD Core Rulebook section 4.1; the EPC is not authorised to mandate the form which this
communication takes place.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a           N/A – out of scope of the rulebook.
 case for wide SEPA market
 acceptance?

 Is the change underpinned           No.
 by a cost-benefit analysis?

 Is the change feasible to           N/A – out of scope of the rulebook.
 implement?

            2.8.3 Rulebook Impact
N/A as the suggestion is out of scope of the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                            17
2.9        Notification to Creditor in case of change of debtor banking details

            2.9.1 Description

 This suggestion was made by Bitkom, Germany. It is suggested that changes of the banking details
 by the debtor should be communicated via
      a)    mail
      b)    fax
      c)    internet
      d)    telephone
 In the case of “d” sending a written acknowledgement by the creditor should be enough as
 evidence.

            2.9.2 SPS WG analysis and recommendation

The SPS WG considers that this suggestion cannot be part of the existing scheme as this issue is out
of scope of the rulebook and the EPC (option e). Any communication between the debtor and the
creditor can be done in a manner agreed between the parties bilaterally according to the rules stated
in the SDD Core Rulebook section 4.1; the EPC is not authorised to mandate the form in which this
communication takes place.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a           N/A – out of scope of the rulebook.
 case for wide SEPA market
 acceptance?

 Is the change underpinned           No.
 by a cost-benefit analysis?

 Is the change feasible to           N/A – out of scope of the rulebook.
 implement?

            2.9.3 Rulebook Impact
N/A as the suggestion is out of scope of the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                            18
2.10 The use of International Bank Account Number (IBAN) only procedure on
     mandates

       2.10.1 Description

This suggestion was made by Bitkom, Germany. It is proposed that the requirements for the
mandate should consider the IBAN-only procedure. For national accounts it should not be necessary
to provide the BIC on the mandate.

       2.10.2 SPS WG analysis and recommendation

The SPS WG proposes to incorporate this suggestion into the scheme (option b) as according to the
SEPA Regulation, after 1 February 2014, the BIC will become in principle optional in the customer-
to-bank IGs for national payments, therefore it will become optional on the mandate as well. The
BIC will be necessary until 1 February 2016 for cross-border transactions. However, it is expected
that the debtor always has its BIC at the time of the signature of the mandate.

Possible national transitional rules according to the SEPA Regulation regarding the requirement of
the BIC for national payments have to be respected.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a          Yes.
 case for wide SEPA market
 acceptance?

 Is the change underpinned          This is a change required by regulation.
 by a cost-benefit analysis?

 Is the change feasible to          Yes.
 implement?

       2.10.3 Rulebook Impact
The impact on the rulebook is limited as this change will require the change of an element from
mandatory to optional.




EPC140-12 SDD B2B Change Request 2012                                                             19
2.11 The use of Basic Bank Account Number (BBAN) and national sorting code
     instead of IBAN on the mandate

        2.11.1 Description

 This suggestion was submitted by Bitkom, Germany. It is proposed that if it is allowed by
 national legislation to provide the account number and national sorting code instead of the IBAN
 for national payments until 1st February 2016, it should also be allowed to use the account number
 and the national sorting code instead of the IBAN to issue a mandate.


        2.11.2 SPS WG analysis and recommendation

The SPS WG considers that this suggestion cannot be part of the existing scheme as it is out of
scope of the EPC (option e). According to the SEPA Regulation, the initiation of direct debits with a
BBAN is only allowed for consumers.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a          Subject to the number of EU Member States which
 case for wide SEPA market          will opt to make use of the derogation permissible
 acceptance?                        under Article 16 (1) of the SEPA Regulation. The
                                    market will have more clarity by 1 February 2013, by
                                    which time EU Member States must notify the
                                    European Commission of the derogations that they
                                    intend to use (see Article 16 (7).

 Is the change underpinned          No.
 by a cost-benefit analysis?

 Is the change feasible to          Implementing such a significant change at this stage
 implement?                         would have a substantial impact on a majority of
                                    SEPA stakeholders who to date indicated a preference
                                    for the current scheme rules.

        2.11.3 Rulebook Impact

 Subject to outcome of the public consultation: if a broad majority of all SEPA stakeholders
 would support this suggestion for change, this would have a significant impact on the
 rulebook.




EPC140-12 SDD B2B Change Request 2012                                                            20
2.12 Clarification on mandate guidelines

        2.12.1 Description

 This suggestion was submitted by Bitkom, Germany. According to Bitkom, the DK (Deutsche
 Kreditwirtschaft) mandate samples are not in accordance to formal regulations of the EPC
 rulebook:
    •   The compliance with the order of the mandate information.
    •   The obligation to indicate the specified identifier (field names).
    •   The obligation to specify a statement to the payee for the mandate return.
    •   The clear separation of the mandate from any other text.
 The request is to no longer consider the above as mandatory guidelines for a mandate. They should
 be considered more as non-binding recommendations for the issue of a mandate.

        2.12.2 SPS WG analysis and recommendation

The SPS WG considers that this suggestion is already covered by the scheme as the sample of a
physical mandate in the rulebooks is only an illustration (option a). More detailed information can
be found in document EPC392-08 “Guidelines for the Appearance of Mandates” available on the
EPC website. The recommendation is to incorporate a clarification in the rulebook.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:

 Does the change present a           N/A – already provided for in the scheme.
 case for wide SEPA market
 acceptance?

 Is the change underpinned           N/A – already provided for in the scheme
 by a cost-benefit analysis?

 Is the change feasible to           N/A – already provided for in the scheme.
 implement?

        2.12.3 Rulebook Impact
The impact on the rulebook is minor as only a wording clarification needs to be done.




EPC140-12 SDD B2B Change Request 2012                                                            21
2.13 Allowing longer remittance information

       2.13.1 Description

 Suggestions for allowing longer remittance information were submitted by Bitkom and
 jointly by InterCard, Handelsverband Deutschland, easycash, TeleCash & BP Europa (Germany).

       2.13.2 SPS WG analysis and recommendation

 The SPS WG recommends not taking forward this suggestion for change at this point as it is not
 feasible to incorporate this change into the scheme at this stage in the migration process (option e).
 It should be kept in mind that all market participants in the euro area are required to meet the 1
 February 2014 deadline for compliance with the SEPA Regulation; i.e. systems and operations
 have already been aligned or are being aligned with, among other things, the current standard 140
 character remittance information. Introducing such a significant change at this stage would require
 all market participants (i.e. payers, payees, PSPs, payment service users and CSMs) to make
 further significant investments into their IT systems, rendering previous developments obsolete

 Experience shows that over 95 percent of credit transfers can be validly reconciled with less than
 140 characters of remittance information. It is standard practice throughout Europe and in many
 other parts of the world for all processing chains to allow for 140 characters in the remittance data
 field. Allowing for 1000 characters in SEPA would force European PSPs and corporates to
 maintain different processing applications and IT systems for SEPA and non-SEPA transactions.

 The remittance information should be kept at 140 characters, in order to ensure full remittance
 information end-to-end through the different account information channels for mass payments.

 The EPC would welcome to discuss with all stakeholders any other need going further based on an
 impact and cost-benefit analysis.

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a           Based on feedback received from a broad majority of
 case for wide SEPA market           all SEPA stakeholders in previous public
 acceptance?                         consultations, this change does not present a case for
                                     wide SEPA market acceptance at this stage.

 Is the change underpinned           No.
 by a cost-benefit analysis?

 Is the change feasible to           Implementing such a significant change at this stage
 implement?                          would have a substantial impact on a majority of
                                     SEPA stakeholders who to date indicated a preference
                                     for the current scheme rules. It would also require
                                     SEPA stakeholders which already migrated to SDD
                                     Core to reinvest into further adaptation of systems and
                                     operations.



EPC140-12 SDD B2B Change Request 2012                                                             22
       2.13.3 Rulebook Impact

 Subject to outcome of the public consultation: if a broad majority of all SEPA stakeholders
 would support this suggestion for change, this would have a significant impact on the
 rulebook.




EPC140-12 SDD B2B Change Request 2012                                                   23
2.14 Waiving of the obligation to issue a pre-notification Description

 This suggestion was made by Bitkom, Germany. It is proposed to waive the pre-notification in the
 scope of an AOS or eliminating the specification of an exact amount in the pre-notification
 concerning certain transactions.

        2.14.1 SPS WG analysis and recommendation
The SPS WG considers that this suggestion cannot be part of the existing scheme (option e). The
EPC defines the pre-notification as an instrument for debtor protection and for enabling the debtor to
provide the exact amount of cover on the defined due date. It is the interest of the creditor that the
direct debit can be successfully collected on due date and therefore the debtor must know the date
and the amount of the collection in advance. The pre-notification does not need to be an additional
document as invoices and contracts already showing the amounts and due dates can be considered as
pre-notifications.
The SPS WG however proposes to add a clarification on the use of the pre-notification in the
rulebook.

According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:
 Does the change present a           No.
 case for wide SEPA market
 acceptance?

 Is the change underpinned           No.
 by a cost-benefit analysis?

 Is the change feasible to           Implementing such a significant change at this stage
 implement?                          would have a substantial impact on a majority of
                                     SEPA stakeholders who to date indicated a preference
                                     for the current scheme rules. It would also require
                                     SEPA stakeholders which already migrated to SDD
                                     Core to reinvest into further adaptation of systems and
                                     operations.

        2.14.2 Rulebook Impact

 Subject to outcome of the public consultation: if a broad majority of all SEPA stakeholders
 would support this suggestion for change, this would have a significant impact on the
 rulebook.




EPC140-12 SDD B2B Change Request 2012                                                             24
2.15 Unique Mandate Reference to be space insensitive

        2.15.1 Description

 This suggestion was made by Bitkom, Germany. They propose that spaces in the unique
 mandate reference (UMR) (AT-01) should not be considered.

        2.15.2 SPS WG analysis and recommendation

The SPS WG recommends that this suggestion cannot be part of the existing scheme as it is
not feasible (option e). Spaces are permitted in the UMR and are considered as meaningful
characters. Therefore not taking the blanks into account would mean creating a different UMR than
the original one.
According to section 3.1.6 of the Internal Rules, the following criteria have been evaluated:
 Does the change present a           No.
 case for wide SEPA market
 acceptance?

 Is the change underpinned           No.
 by a cost-benefit analysis?

 Is the change feasible to           No, implementing such a change would have a
 implement?                          significant impact as this would not be in line with the
                                     way UMRs are currently handled.

        2.15.3 Rulebook Impact

 Subject to outcome of the public consultation: if a broad majority of all SEPA stakeholders
 would support this suggestion for change, this would have a significant impact on the
 rulebook.




EPC140-12 SDD B2B Change Request 2012                                                           25
2.16 Clarification on the use of AT-21 ‘transaction type’

       2.16.1 Description

 Bitkom submitted several processing-related questions concerning the use of AT-21
 ‘transaction type’ (see original change suggestion EPC243-11-23 in the Annex for more
 details).

       2.16.2 SPS WG analysis and recommendation.

  The SPS WG considers that this request is not a change request but rather a clarification issue. It is
 included in this document for sake of completeness. Answer to it will be included in the FAQ
 document.

 The SPS WG however recommends that AT-21 should be called ‘transaction or sequence type’.




EPC140-12 SDD B2B Change Request 2012                                                               26
2.17 Clarification on one-off collections

       2.17.1 Description

 Bitkom submitted several operational questions linked to one-off collections (please see
 document EPC243-11-24 for further details).

       2.17.2 SPS WG analysis and recommendation.

 The SPS WG considers that this request is not a change request but rather a clarification issue. It is
 included in this document for sake of completeness. Answer to it will be included in the FAQ
 document.




EPC140-12 SDD B2B Change Request 2012                                                              27
2.18 Inclusion of the possibility of a shorter notice period for the termination of
     participation

 This suggestion was made by the EPC Secretariat concerning section 5.11 of the rulebooks which
 currently allows a participant to terminate its status as a participant by giving no less than six
 months' prior written notice to the Scheme Management Committee (SMC) of the EPC, such
 notice to take effect on a designated day (for which purpose such a day will be designated at least
 one day for each month).

 However, section 5.11 of the rulebook does not contain any provisions allowing the SMC to agree
 on a shorter notice period with the relevant participant.

 The EPC Secretariat therefore proposes to add a new second paragraph to section 5.11 as follows:

 “Notwithstanding the previous paragraph, upon receipt of the Participant’s notice of termination by
 the SMC, the Participant and the SMC may mutually agree for the termination to take effect on any
 day prior to the relevant designated day.”

       2.18.1 SPS WG analysis and recommendation

 The SPS WG recommends incorporating this suggestion into the scheme and making the
 necessary changes to the rulebooks in order to increase flexibility in the termination process
 (option b).

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a          Yes.
 case for wide SEPA market
 acceptance?

 Is the change underpinned          No.
 by a cost-benefit analysis?

 Is the change feasible to          Yes.
 implement?

       2.18.2 Rulebook Impact

Minor impact on the rulebook as this is only a wording change.




EPC140-12 SDD B2B Change Request 2012                                                            28
2.19 Notices given under the Rulebook

       2.19.1 Description

 This suggestion was made by the EPC LSG. It is proposed to add wording to section 5.15 (on
 contractual provisions governing the rulebook) to state that notices that are given in accordance
 with the rulebook should only be translated into English if the party receiving the document so
 requests.

       2.19.2 SPS WG analysis and recommendation

 The SPS WG considers that this suggestion cannot be part of the existing scheme (option
 e) as this obligation is already included in the RB 5.14 and 5.15 as follows: “Every document that
 is required to be provided under the Rulebook shall be provided in the English language.”

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a          No.
 case for wide SEPA market
 acceptance?

 Is the change underpinned          No.
 by a cost-benefit analysis?

 Is the change feasible to          No.
 implement?

       2.19.3 Rulebook Impact

 Subject to outcome of the public consultation: if a broad majority of all SEPA stakeholders
 would support this suggestion for change, this would have an impact on the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                                29
2.20 Wording correction of section 5.9.1

2.20.1 Description

 This suggestion was made by the LSG concerning section 5.9.1 of the e-Mandate rules in
 Annex VII of the rulebook which currently mirrors the equivalent section in Annex VII of the SDD
 B2B Rulebook regarding e-Mandates and contemplates that the debtor has refund rights. This is
 not correct under the SDD B2B Scheme with regard to authorised transactions.

 The LSG proposes to correct this discrepancy, by deleting the e-Mandate version of section 5.9.1
 and removing the reference to "e-Mandates" at the beginning of section 5.9 of the paper-based
 mandate rules

2.20.2 SPS WG analysis and recommendation

 The SPS WG recommends that the suggestion for change should be incorporated into the
 scheme partially and that the reference to refunds be deleted from the rulebook (option b),
 however it is not recommended to delete section 5.9.1 completely.

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a         Yes.
 case for wide SEPA market
 acceptance?

 Is the change underpinned         No.
 by a cost-benefit analysis?

 Is the change aligned with        Yes.
 the strategic objectives of
 the EPC?

 Is the change feasible to         Yes.
 implement?




EPC140-12 SDD B2B Change Request 2012                                                          30
2.21 Refund right

2.21.1 Description

 This suggestion was made by the LSG which proposes that the following paragraph be inserted
 into section 2.7 of the rulebook after the second paragraph: "in the event that a Debtor Bank is
 required under the Scheme to which the Mandate relates to pay a Refund to the Debtor, the
 Creditor Bank must reimburse the Debtor Bank in respect of the amount of the Refund and any
 related Refund compensation in accordance with the rules in process steps PT-04.16 and PT-04.24
 of section 4.6.4 of the Core Scheme Rulebook".

2.21.2 SPS WG analysis and recommendation

 The SPS WG recommends not taking forward this suggestion for change as it is not
 feasible to incorporate this change into the scheme (option e). The fundamental principle of
 the SDD B2B is to guarantee finality of the transaction after the two days allowed for returns by
 the debtor bank. Any refund request made by the debtor after due date is due to a non respect of the
 checking obligations of the debtor bank.

 Such refund request can be settled outside the scheme. The rulebook provides an inquiry procedure
 (as described in detail in Annex VI of the rulebook) to assist the debtor bank and the creditor bank
 to establish whether the transaction was erroneous.

 According to section 3.1.6 of the Internal Rules, the following criteria have been
 evaluated:

 Does the change present a          No.
 case for wide SEPA market
 acceptance?

 Is the change underpinned          No.
 by a cost-benefit analysis?

 Is the change feasible to          No.
 implement?

2.21.3 Rulebook Impact

 Incorporating this change would undermine one of the fundamental principles of the SDD
 B2B; i.e. the change would have a significant impact on the rulebook.




EPC140-12 SDD B2B Change Request 2012                                                            31
3      CHANGES PERTAINING TO THE IMPACT OF THE ‘SEPA REGULATION’
       (REGULATION (EU) NO 260/2012)

On 30 March 2012, the ‘Regulation (EU) No 260/2012 establishing technical and business
requirements for credit transfers and direct debits in euro and amending Regulation (EC) No
924/2009' (the SEPA Regulation) was published in the Official Journal of the European
Union (EU). The EPC SPS WG and LSG have analysed the impact of this Regulation on
the rulebooks and jointly propose that the changes listed below be made to the SDD B2B
Scheme.

As the EPC is under the legal obligation to ensure compliance of the rulebooks with the SEPA
Regulation, these proposed changes to the rulebooks are not subject to public consultation and are
included in this document for information but the contributors to this public consultation are
welcome to comment on these changes.

3.1     Common legal framework

    In line with Article 1(1) of the SEPA Regulation, it is proposed to add a new section to all
    rulebooks in order to make reference to the common legal framework for the schemes. In
    section 5.16, a reference to the SEPA Regulation will also be added.

3.2     Definition of a payment scheme

 In line with Article 2(7), it is proposed that wording be added to section 1.1 of all
 rulebooks to state that the EPC payment schemes are schemes in the sense of this Article.

3.3      “IBAN only”

 In line with Articles 5(1), 5(2), 5(4) and 5(7), it is proposed that the following changes be
 made to the SDD rulebooks and IGs:

       • Customer-to-bank IGs to be amended : BIC optional in all cases

       • DS-01 of SDD rulebooks to be amended: BIC to be optional and footnote to be
          added in the rulebook to state that as from Feb 2014 the BIC is optional for
          national mandates and as from Feb 2016 for cross border mandates.

       • Interbank area: BIC to be kept as mandatory element in DS-02, DS-03, DS-04, DS-
          08 and add the wording: if not agreed otherwise by the PSPs involved in the
          payment transaction

3.4     Validity of legacy mandates

    In line with Article 7(1), the rulebook section 5.17 needs to be updated.

3.5     Interchange Fees

 In line with Article 8, the rulebook section 5.14 and the definition of AT-R8 need to be
 updated.



EPC140-12 SDD B2B Change Request 2012                                                         32
4     CHANGES TO THE RULEBOOK FOR CLARIFICATION, UPDATING AND
      CORRECTION OF ERRORS

4.1     Introduction

 This section sets out proposed changes which, although they are uncontroversial in nature,
 constitute either Major Changes (since they propose changes to Section 5 of the Rulebook
 and are therefore deemed to be 'major' changes under section 3.1.6 of the Internal Rules) or
 Minor Changes to the Rulebook.

 The SPS WG recommends acceptance of these proposed changes since they are for the
 following purposes:
            •    Improved wording which is for explanation or for clarification
            •    Other updating amendments (for example amendment of statements referring to
                 documents which have been superseded).

 The proposed minor changes are summarised in the table below. The SPS WG
 recommends accepting these minor changes:

4.2     Proposed changes

    Section of
                     Description of the                                           Type of
       the                                           Reason for change
                         Change                                                   Change
    Rulebook




EPC140-12 SDD B2B Change Request 2012                                                          33
 Section of
                  Description of the                                      Type of
    the                                             Reason for change
                      Change                                              Change
 Rulebook

PT-04.09      The "description section" of     Clarification            Minor
              PT-04.09 under section
              4.6.4 of the rulebook
              currently provides that "the
              Debtor Bank has no refund
              right under the Scheme in
              case a consumer account is
              debited in error" (emphasis
              added).

              In determining whether the
              debtor bank is entitled to get
              reimbursed from the creditor
              bank, it is irrelevant whether
              the debtor is a consumer or
              not; for example, a business
              customer may use the SDD
              Core Scheme and therefore
              be entitled to a refund. The
              LSG is of the view that the
              above-mentioned wording
              should be amended so as to
              warn debtor banks that no
              refund reimbursement will
              be available if any account
              that is not authorised for
              B2B is credited, irrespective
              of the status of the debtor.

              Accordingly, the LSG
              proposes that the phrase "a
              consumer account" is
              replaced by "an account not
              authorised for B2B".




EPC140-12 SDD B2B Change Request 2012                                               34
 Section of
                  Description of the                                    Type of
    the                                           Reason for change
                      Change                                            Change
 Rulebook

4.4           Amendment of current           Clarification            Minor
              wording of AT-31 should be
              amended so as it is
              consistent with the
              definition of reversal at
              section 4.4, which allows
              reversals to be initiated by
              either creditors or creditor
              banks. The LSG proposes
              that the sentence "It is
              defined by the Creditor who
              initiates the Reversal"
              should be replaced by "It is
              defined by the actor who
              initiates the reversal, i.e.
              either the Creditor or the
              Creditor Bank"..

4.4           The LSG proposes change        Clarification            Minor
              to clarify that the creditor
              bank is not obliged to offer a
              reversals service. The
              definition of reversals in
              section 4.4 should be
              amended by to read: "a
              Reversal initiated by a
              Creditor must (if the
              Creditor Bank offers a
              Reversals service) be
              handled by the Creditor
              Bank and the Debtor Bank".




EPC140-12 SDD B2B Change Request 2012                                             35
 Section of
                  Description of the                                      Type of
    the                                             Reason for change
                      Change                                              Change
 Rulebook

4.2            In 4.2, in the list of          Correction               Minor
               possible R-transactions,
               refund is listed. A refund
               cannot exist in the SDD
               B2B Scheme, therefore
               the word refund should be
               deleted from the list.

               …If a Creditor does not
               present a Collection under
               a Mandate for a period of
               36 months (starting from
               the date of the latest
               Collection presented, even
               if rejected, returned or
               refunded), the Creditor
               must cancel the Mandate
               and is no longer allowed to
               initiate Collections based
               on this cancelled Mandate.
               If there is a further
               requirement for a direct
               debit, a new Mandate must
               be established. The
               Rulebook does not oblige
               the Debtor Bank to check
               the correct application of
               this rule. The Rulebook
               does not oblige the
               Creditor Bank to check the
               correct application of this
               rule. It is an obligation for
               the Creditor.

PT-02.02      It is proposed to add            Clarification            Minor
              wording in the rulebook to
              state that debtor banks who
              have changed their BIC (but
              remain the same entity)
              should not reject collections
              due sequence type ‘first’.




EPC140-12 SDD B2B Change Request 2012                                               36
 Section of
                    Description of the                                    Type of
    the                                             Reason for change
                        Change                                            Change
 Rulebook
eMandate        Currently      there    is    a
Unique          discrepancy between DS-12
                                                Correction              Minor
Mandate         and PT- 07.04 / PT-08.04.
Reference       DS-12 makes the UMR
(UMR) PT-       Mandatory for the request
07.04/ PT-      from Creditor to the Debtor
08.04     and   Bank via the validation
DS-12           services.
                PT07.04 & PT-08.04 states
                “The      Unique      Mandate
                Reference (if provided)”
                 The wording (if provided)
                should be deleted in the 2
                PTs and make the UMR
                mandatory at this stage for
                the eMandate procedure.
                When the debtor is in his
                Online banking application
                and the Debtor Bank
                receives the data for the
                eMandate initiation, the
                UMR should already be
                sent with all the data. This
                allows the Debtor Bank to
                open a record in the
                Mandate Database based on
                the CID and the UMR being
                the keys for the record
p.58            The paragraph “…outside
                the content of lines 1 to 16
                                                Correction              Minor
                as indicated on the
                illustration in Figure 11 (see
                ‘Creditor’s use only’
                below). The reverse side of
                a Mandate must not set out
                any information that might
                be misunderstood by the
                Debtor to be part of the
                Mandate“ has a wrong line
                numbers: it must be line 1 to
                20
                The SDD Core Rulebook is
                correct.




EPC140-12 SDD B2B Change Request 2012                                               37
 Section of
                  Description of the                                   Type of
    the                                          Reason for change
                      Change                                           Change
 Rulebook
Description   Add the sentence ‘If no
of AT-10      reference is provided by the
                                            Clarification            Minor
              creditor, this attribute has
              default      value      “Not
              Provided”’ to the AT-10
              (The Creditor’s Reference
              of    the    Direct     Debit
              Transaction) description.
#0.1, 0.4,    It is suggested to make
Annex I
                                         Alignment with EPC          Minor
              the necessary changes to   plenary decision
              the all rulebooks in order
              to ensure alignment with
              the EPC Plenary
              resolution dated 22 March
              2012 to retrieve the SEPA
              eligibility criteria.




EPC140-12 SDD B2B Change Request 2012                                            38
5      PRINCIPLES GOVERNING THE CHANGE REQUEST PROCESS

5.1     Change Request

    This Change Request is submitted by the SPS WG in accordance with the procedures set
    out in the Internal Rules in respect of changes to the rulebook.

5.2     Structure of the Change Request

 Sections 2, 3 and 4 describe the changes to the rulebook which are proposed in this Change
 Request.

 These changes fall into three categories:
             •   Section 2 – covers innovative suggestions for change to technical operations in
                 sections 3 and 4 of the rulebook and other significant non-technical changes which
                 fall within the definition of major changes
             •   Section 3 covers suggestions to align the scheme rulebook with the SEPA
                 Regulation
             •   Section 4 - proposes changes to correct typing errors and provide additional
                 clarification to the rulebook. These changes consist of minor changes to the
                 rulebook or major changes which are uncontroversial in nature and do not affect
                 technical operations. These changes are identified as such in the table of changes set
                 out in section 6

 Annex 1 – contains the original change requests relating to section 2.




EPC140-12 SDD B2B Change Request 2012                                                              39
6     CHANGE MANAGEMENT PROCESS IN RESPECT OF MAJOR CHANGES

6.1   Consideration of Suggestions

 In accordance with chapter 3.1.4 of the Internal Rules, a number of suggestions in respect
 of changes to the SDD B2B Rulebook have been submitted for consideration to the SPS
 WG. 31of these are applicable to the SDD B2B Scheme.

 Following consideration of these suggestions as required under chapter 3.1.6 of the
 Internal Rules, the SPS WG has determined: (a) that the changes set out in section 2 and 3
 meet the criteria for acceptance into the change management process; and (b) that the
 changes set out in section 4 constitute minor changes invoking the procedures set out in
 Chapter 3.3 of the Internal Rules or uncontroversial major changes.

6.2   Change Request

 The SPS WG is responsible for preparation and development of a Change Request in
 respect of the major changes referred to in section 2.1 above, and guiding the changes
 through the change management process.

 The SPS WG has therefore formulated this Change Request under chapter 3.2 of the
 Internal Rules. In accordance with chapter 3.2, this Change Request analyses the major
 changes which have been proposed, and attaches at Annex 1 the original suggestions.

6.3   Cost-benefit analysis and business case for the Change Request

 The SPS WG is required under chapter 3.2.1 of the Internal Rules to conduct research and
 carry out a cost-benefit analysis on the suggestions accepted, including developing a
 business case for making a Change Request.

 The SPS WG has examined the costs and benefits arising from the suggestions raised in
 this Change Request. In carrying out its examination of costs and benefits of the proposed
 changes, the SPS WG has concluded that a formal monetary cost-benefit analysis in
 accordance with Appendix 1 to the Internal Rules is not appropriate since each of the
 proposed changes meets at least one of the following criteria:
          •   the change has been mandated by a change in law;
          •   the change implements policies decided by prior approved EPC Resolutions;
          •   the change meets a demand from Participants and Scheme users for improvement to
              technical aspects of the Rulebook; or
          •   the change is to add clarification or explanation or to amend typing errors in the
              Rulebook.

 The SPS WG has accordingly concluded that the requirements of chapter 4.1.2 of Annex 1
 of the Internal Rules have been met.




EPC140-12 SDD B2B Change Request 2012                                                              40
6.4   Consultation on the Change Request

 The EPC encourages all SEPA stakeholders to provide feedback during the public
 consultation. Banking communities are asked to consult all of their members who are
 involved in the SDD B2B Scheme to ensure that the views of the payment services
 constituency are considered in the consultation process. The SPS WG encourages the
 banking communities to consult as wide a range of stakeholders as possible, including
 Participants, end users and service suppliers. All stakeholders should provide feedback to
 the EPC on the change request by 13 August 2012.

6.5   Feedback from consultation

 The EPC shall collect and analyse the comments from all stakeholders and prepare a
 feedback report on the consultation. The report will be published on the EPC website.

6.6   Next steps

 Taking into account comments received during the consultation, the SPS WG will
 complete a change proposal per rulebook for approval by the EPC Plenary in September
 2012.

 Approved changes will be incorporated into version 5.0 of the Rulebook with the intention
 that they become effective in November 2013.

6.7   SPS WG recommendation

The SPS WG has issued a recommendation on the way forward with regard to each suggestion; the
reasons underlying each recommendation are detailed in chapter 2. The final decision whether a
suggested change will be incorporated into the rulebook is however subject to the outcome of the
public consultation.

The contributors to this public consultation are requested to indicate whether they agree with the
recommendation of the SPS WG on the way forward. In case the contributors do not agree with the
SPS WG recommendation, they are requested to indicate their preferred way forward.

6.8   Further information

 The above is a summary of the change management process. If you would like further
 information please refer to the Internal Rules or contact the EPC Secretariat.




EPC140-12 SDD B2B Change Request 2012                                                         41
7     CHANGE MANAGEMENT PROCESS IN RESPECT OF MINOR CHANGES

7.1   Publication of list of minor changes

 The SPS WG has identified certain minor changes which they consider necessary for the
 rulebook. The SPS WG is required under the Internal Rules to publish a list of minor
 changes on the EPC website and to ensure that the list may be viewed by all stakeholders.
 This obligation shall be met by the publication of this Change Request, and in particular
 the provisions of section 4 of this Change Request noting certain changes as 'minor'.

7.2   Comments on the minor changes

 All stakeholders may submit comments on the list of minor changes with feedback to this
 Change Request.

7.3   Submission of the list of minor changes to the EPC Plenary

 The list of minor changes shall be submitted to the EPC Plenary for determination. The
 EPC Plenary shall determine whether or not to accept the changes proposed in the list of
 minor changes by resolution.

7.4   Publication of changes

 A list of minor changes that has been considered at the EPC Plenary shall be published on
 the EPC website together with the decision of the Plenary on those proposals. It is
 intended that such minor changes take effect in November 2013 alongside any major
 changes approved in accordance with the procedure explained in section 6 of this Change
 Request.




EPC140-12 SDD B2B Change Request 2012                                                   42
                  ANNEX 1 - ORIGINAL CHANGE REQUESTS




EPC140-12 SDD B2B Change Request 2012                  43
Doc:EPC243-11-01                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Mr. Matteo Fontanesi
contributor:

Organisation: Cedacri Spa

Address:          Via del Conventino 1, 43040 Collecchio (Parma) - Italy

Contact           Crebm09@cedacri.it
details:

Your              Sepa Direct Debit Debtor Bank side Technical developer
reference:

Scheme and        SDD CORE and B2B scheme, all version
document
and version
number:

Date:             2011-11-07




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion: Clarify if the sequence of the collection must be verified in
accordance to requests of payment previously received on the same Mandate and if the abnormal
sequence in presentation/collection must be treat as a reject/return motivation. Actually, about 50%
of the repetitive collection starts with ‘RCUR’ value in the AT-21 Transaction type. This check is
over the accordance between the type of mandate and the transaction type on the collection,
because also on a repetitive mandate the sequence could be mistaken.


Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)




EPC243-11-01 Cedacri Spa                                                               4 August 2010
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No
analysis?
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       No
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?




EPC243-11-01 Cedacri Spa                                                           4 August 2010
                             2013 Change request proposal

                       Submitter: French banking community
                               On: 29 February 2012
                            Scheme(s): SCT and SDD


   1. Request

Make possible that a payment is rejected because either the destination bank or the originator
bank is not registered within the CSM reference data..

   2. Description

In the SCT/SDDs Rulebooks, in the current description of “AT-R3 The reason code for non-
acceptance of the credit transfer / [direct debit] collection”, which is used in the customer-to-
bank reject as well as in the interbank reject, French banks are missing the reason “Bank not
registered” is not listed.

Indeed, the experience proves that:
   • in the customer-to-bank relation a number of rejects occur because the destination
       bank is not listed in the EPC register for the relevant scheme (Currently, originator
       banks quite often stop the process and ask the customer to correct the destination bank.
       This is not STP and not adapted to large direct debit files),
   • when the systems of the bank did not detect the problem for any reason, the CSM
       should reject the payment.
   • Destination banks receive transactions from originating banks which are not registered
       in the relevant scheme (and the CSM did not make the control)

 The French banks propose to add the reasons
   - “Beneficiary Bank not registered” (SCT) / ”Debtor Bank not registered” (SDDs)
   - “Originator Bank not registered” (SCT) / “Creditor Bank not registered” (SDDs)
to AT-R3 in the respective Rulebooks and as a consequence to add a relevant reason code in
the IGs.

   3. Analysis

According to section 3.1.6 of the SMIRs, the following criteria have been evaluated by French
banks, as well for a) as for b):
 Does the change present a case for wide         Yes, we think that not only French banks
 SEPA market acceptance?                         would welcome this change in the RBs
                                                 which is meant to improve STP processing
                                                 and to allow a better understanding of the
                                                 reject.
 Is the change underpinned by a cost-benefit     Not directly, the goal of the change is to
 analysis?                                       clarify the reject reason in the C2B
                                                 relationship, the relationship between the
                                                 CSM and its participant banks and
                                                 between the banks.
 Is the change aligned with the strategic        Yes, as the objectives of EPC are inter alia
 objectives of the EPC?                          to facilitate the acceptance of the schemes
                                                 and their related transactions.
 Is the change feasible to implement?            Yes, for the banks it is a question of
                                                 parameter settings.

   4. Decision and Rationale

It is asked to make this change in the Rulebooks and the Implementation Guidelines.

   5. Rulebook Impact

Add the reject reasons to AT-R3.

 French banks would also advise to improve the CSM framework by making the control of
the registration of the originating bank as well as the destination bank.
Doc:EPC243-11-06                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Roland Flommer
contributor:      on behalf of the following German banking associations:
                  1. Bundesverband der Deutschen Volksbanken und Raiffeisenbanken e.V. (BVR)
                  2. Bundesverband Öffentlicher Banken Deutschlands, VÖB, e.V.
                  3. Deutscher Sparkassen- und Giroverband e.V.

Organisation: Deutscher Sparkassen- und Giroverband e.V.

Address:          Charlottenstrasse 47
                  DE-10117 Berlin, Germany

Contact           Tel. +49-30-20225 5548
details:          mailto:roland.flommer@dsgv.de

Your              B2B SDD Return Period
reference:

Scheme and        SEPA Business to Business Direct Debit Scheme Rulebook Version 4.0
document
and version
number:

Date:             27.02.2012 V1.0




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: 16 November 2013


Description of the suggestion:
An early finality of the collected payment in the SEPA B2B Direct Debit Scheme is a key feature
in the businesses between corporate customers. However there is a vital interest of Creditors to
initiate a successful collection and to avoid a return due to lack of funds. Also in some legacy B2B
direct debit schemes Debtor Banks supporting this requirement by using available Return periods
to allow the Debtor to provide necessary cover. The Return Period for SEPA B2B Direct Debits is
2 TARGET business days (D+2) defined in the SDD B2B Rulebook. As a consequence Debtor
Banks have to make the final decision if they accept or return a direct debit at the latest on D+2
early in the morning.
Due to the increased use of SEPA B2B Direct Debits a problem has been identified in relation to
regional and national bank holidays. If D+1 is a national or regional holiday, the Debtor Bank has
a reduced timeframe to decide whether it accepts or returns a direct debit limited to D+2 in the
morning. Especially for indirect CSM participants in the existing clearing landscape the point in
time until the decision has to be taken can be really early, e.g. 8 a.m. The alternative to shift the
decision to D does not sufficiently work because credit entries on debtor’s account arriving in the
evening of D have to be taken also in consideration of the decision.
The proposal to solve this issue is to extend the Return period to 3 TARGET business days, i.e.
until D+3 instead of D+2.


1. Impact on the Scheme in general
A longer Return Period reduces the risk of automatic returns due to lack of funds because debtor
banks have the possibility to decide manually. This is advantageous for all parties because it
reduces the number of R-transactions.
On the other hand Creditors have to wait one day longer until their credit entry is irrevocable.


2. Impact on the interbank space
The rulebook has to be adjusted in section 4.3.2, 4.3.4 and 4.6.4 (PT-04.09, PT-04-10).


3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
   standards)
No impact on message standards.


4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
No impact.


5. The nature of the suggestion
A change (replacing an existing Rulebook element by a new one).

EPC243-11-06 BVR-VOEB-DSGV                                                                4 August 2010
2   ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide            Yes, SEPA wide acceptance is key for interoperability
acceptance?
Is the suggestion underpinned by a cost-benefit   No, but very low implementation costs (only change of a
analysis?                                         parameter) are expected.
Does the change fit in the strategic objectives for Yes, because it supports migration to B2B Direct Debits by
SEPA?                                               reducing R-transactions rates.
Do you consider that the implementation of the    Yes, absolutely, because implementation is easy (only
change resulting from the acceptance of the       change of a parameter).
suggestion is feasible?
Do you consider that the suggestion does not      Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the     Yes
scope of the scheme involved?




EPC243-11-06 BVR-VOEB-DSGV                                                                     4 August 2010
Doc:EPC243-11                                                                                                  4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Frans van Beers
contributor:

Organisation: Betaalvereniging Nederland

Address:          Beethovenstraat 300, Amsterdam

Contact           sepa@betaalvereniging.nl (successor of sepa@nvb.nl)
details:

Your              Changeproposal2012_Dutchcommunity_Digitizing_mandates.docx
reference:

Scheme and        SDD Core 6.0 and SDD B2B 4.0
document
and version
number:

Date:             February 29, 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document „SEPA Scheme Management Internal Rules‟ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: November 2013


Description of the suggestion:
Clarification on digitizing mandates.
Mandates may be stored and archived according to national legal requirements and its Terms and
Conditions with the Creditor Bank. They must be accepted by Debtor Banks as well if they are
presented by the Creditor Bank (PT-06.03) e.g. copy of mandate evidence. If a correct SEPA-
mandate is digitized according the legal requirements and conditions a copy must be considered
“valid” by the Debtor Banks.
Wherever possible, please indicate:
    1. Impact on the Scheme in general
           a. Clarification for all four-corner parties
    2. Impact on the interbank space
           a. Debtor Banks must be aware that in case of requests for copies of mandates (e.g. in
              case of “Refund for unauthorised transactions”) the Creditor Bank may sent a copy
              of the digitized mandate (received from Creditor) to them
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and
       other standards)
           a. none
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
           a. Possibly none. The existing wording should be adequate:
                       ‘Any paper Mandate, together with any related amendments or information
                       concerning its cancellation or lapse, must be physically or digitally stored
                       intact by the Creditor according to national legal requirements and its
                       Terms and Conditions with the Creditor Bank.’
    5. The nature of the suggestion:
           a. Adding an clarification alongside an existing Rulebook element. Which is useful to
              all participants if digitized copies of paperbased mandates are stored and delivered




Changeproposal2012_Dutchcommunity_Digitizing_mandates_Final1 _0.docx
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No, but it helps to improve the STP-principle between
analysis?                                          Creditors, Debtors and their banks
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?




Changeproposal2012_Dutchcommunity_Digitizing_mandates_Final1 _0.docx
Doc:EPC243-11-13                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM




                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-01
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  AGES Maut System GmbH & Co. KG                           (Mr. Frambach)
                  Easycash GmbH (Mr. Di Ruocco)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
                  Inter Card AG (Mr. Adolph)




EPC243-11-13 Bitkom - Digitising mandates      4 August 2010
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:

        The obligation to store the original mandate and its changes (in paper format) should be avoided.

        Reason:
        The same rules should apply for mandates as well as for business letters. An audit-proofed
        archiving of the digitalized mandates and the digitalized mandate changes should be enough. A
        submission of the original mandates is not intended in the EPC rulebook. An electronic copy should
        be sufficient.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.



Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-13 Bitkom - Digitising mandates                                                     4 August 2010
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide              yes
acceptance?

Is the suggestion underpinned by a cost-benefit     --
analysis?
Does the change fit in the strategic objectives for yes, it rises the acceptance
SEPA?
Do you consider that the implementation of the      yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not        yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the       yes
scope of the scheme involved?




EPC243-11-13 Bitkom - Digitising mandates                                          4 August 2010
Doc:EPC243-11                                                                                                  4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Frans van Beers
contributor:

Organisation: Betaalvereniging Nederland

Address:          Beethovenstraat 300, Amsterdam

Contact           sepa@betaalvereniging.nl (successor of sepa@nvb.nl)
details:

Your              Changeproposal2012_Dutchcommunity_TransactionTypeIncorrect.docx
reference:

Scheme and        SDD Core 6.0 and SDD B2B 4.0
document
and version
number:

Date:             February 29, 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document „SEPA Scheme Management Internal Rules‟ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: November 2013


Description of the suggestion:
Addition of new reasoncode: ‘Transaction type incorrect’
(to 4.8.53 AT-R3 , IF incorrect transaction type is used).


    1. Impact on the Scheme in general
           a. Improvement of feedback possibilities (Clarification in favour of “all four-corner
              parties”)
    2. Impact on the interbank space
           a. In 4.8.53 AT-R3 the reasoncodes for Non-Acceptance (Reject, Return or Refund)
              are stated. The Debtor Bank, or its CSM, does not have the possibility to use an
              specific reasoncode if the non-acceptance is caused by the use of an incorrect
              transaction type (as listed in AT-21 – The Transaction). Debtor Banks are forced to
              use one of the existing reasoncodes (in this case causing „wrong feedback‟ to parties
              involved)
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and
       other standards)
           a. Minor impact. Both Debtor Bank and Creditor Bank must support this new
              reasoncode IF it is used by the Debtor Bank (and they are invited to do so.....)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
           a. None.
    5. The nature of the suggestion:
           a. Variant: adding an alternative reasoncode which is optional alongside the existing
              Rulebook elements and will be useful for all parties involved when used by Debtor
              Banks. The Debtor Bank can choose a specific and correct Non-Acceptance
              reasoncode if an incorrect Transaction Type is used. The Creditor Bank can inform
              its Creditor(s) accordingly and they can use this information accordingly in its
              communication(s) to the Debtor. This will lead to less misunderstanding and/or
              dissatifiers for parties involved.
               E.g. Creditor sends a recurrent transaction instead of a First (or One-off). Debtor
               Bank cannot react with “Transaction Type Incorrect”. Nowadays Debtor Banks will
               probably use one of the existing reasoncodes instead. In that case the given
               feedback information is not appropriate.




: Changeproposal2012_Dutchcommunity_TransactionTypeIncorrect_Final1 _0.docx
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No, but it improves the feedback in the interbank space
analysis?                                          between Debtor Banks and Creditor Banks and between
                                                   Creditor Banks, Creditors and Debtors as well.
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?




: Changeproposal2012_Dutchcommunity_TransactionTypeIncorrect_Final1 _0.docx
Doc:EPC243-11-11                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of
contributor:

Organisation: Spanish Community

Address:          Clara del Rey, 26 - Planta 4, 28002 Madrid

Contact           BBVA
details:          jfernandezi@bbva.com
                  Mobile +34 616 463 301 - Phone. +34 91 374 74 61

Your
reference:

Scheme and        Doc: EPC301-07: SEPA BUSINESS-TO-BUSINESS DIRECT DEBIT SCHEME
document          INTER-BANK IMPLEMENTATION GUIDELINES
and version
number:

Date:             February 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
Review field AT-10 (Creditor’s reference of the direct debit Collection) in the Implementation
Guidelines, to be precise, the End To End Identification usage rule should be deleted.
    • In CUSTOMER-TO-BANK IMPLEMENTATION GUIDELINES:
           o This field is mandatory in Direct Debit Collection, Payment Information.
    • In INTER-BANK IMPLEMENTATION GUIDELINES:
           o This field is mandatory in Inter-bank Collection (DS-04), Direct Debit Transaction
             Information. Usage Rule: A customer reference that must be passed on in the end-
             to-end payment chain. In the event that no reference was given, ‘NOTPROVIDED’
             must be used. The reference is mandatory in the customer to bank guidelines,
             therefore, this usage rule doesn’t apply.
Wherever possible, please indicate:
    1. Impact on the Scheme in general.
       Minimum
    2. Impact on the interbank space.
       Minimum
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards).
       Elimination of the usage rule involved.
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks.
       None.
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)
       It affects to Implementation guidelines, not to Rulebook.




EPC243-11-11 Spanish community - AT-10- B2B                                         4 August 2010
2   ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide            Yes
acceptance?
Is the suggestion underpinned by a cost-benefit   No
analysis?
Does the change fit in the strategic objectives for No
SEPA?
Do you consider that the implementation of the    Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not      Yes, It does not impede SEPA-wide interoperability
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the     Yes
scope of the scheme involved?




EPC243-11-11 Spanish community - AT-10- B2B                                                  4 August 2010
Doc:EPC243-11-14                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM




                                                           Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-02
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  AGES Maut System GmbH & Co. KG                           (Mr. Frambach)
                  Easycash GmbH (Mr. Di Ruocco)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
                  Inter Card AG (Mr. Adolph)




EPC243-11-14 Bitkom - electronic mandate       4 August 2010
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
        The paper form is mandatory for all mandates except for the electronic mandate specified by EPC.
        In future electronic mandates with electronic signatures should be permitted based on
        a)   the qualified electronic signature
        b)   the authentication via the new identity card without qualified electronic signature
        c)   the signature with the help of a signature pad
        d)   via the Double-Opt-In-Procedure
        Reason:
        The same rules should apply for mandates as well as for business letters. An electronic document
        with a qualified electronic signature is equal to a written form. With the help of the new identity card,
        it is possible to open bank accounts in the internet. Insurance agreements can be signed with the
        help of a signature pad. With help of the Double-Opt-In-Procedure it is possible to request an online
        credit check


        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.



Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
             a. A change (replacing an existing Rulebook element by a new one)
             b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
                element)




EPC243-11-14 Bitkom - electronic mandate                                                           4 August 2010
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-14 Bitkom - electronic mandate                                           4 August 2010
Doc:EPC243-11-15                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM




                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-03
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  AGES Maut System GmbH & Co. KG                           (Mr. Frambach)
                  Easycash GmbH (Mr. Di Ruocco)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
                  Inter Card AG (Mr. Adolph)




EPC243-11-15 Bitkom - Mandate amendment Debtor notification   4 August 20
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
        Changes of a mandate by the debtor, which are not notifiable according to the EPC rulebooks
        (AmdmntInd is not set) should be communicated by the debtor via
           a. mail
           b. fax
           c. internet
           d. telephone

       In the case of “d” a telephone note should be sufficient.
       Reason:
       It is for the debtor’s benefit to process mandate changes as easy as possible. Insisting on an
       original paper form creates disproportional costs without any additional benefits for the debtor.
       Additional to that, most companies try to integrate paperless processes in their infrastructure.


        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-15 Bitkom - Mandate amendment Debtor notification                                                4 August 20
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-15 Bitkom - Mandate amendment Debtor notification                                       4 August 20
Doc:EPC243-11-16                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM




                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-04
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  AGES Maut System GmbH & Co. KG                           (Mr. Frambach)
                  Easycash GmbH (Mr. Di Ruocco)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
                  Inter Card AG (Mr. Adolph)




EPC243-11-16 Bitkom - Debtor Bank details change   4 August 20
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
        Changes of the banking details by the debtor should be communicated via
            a. mail
            b. fax
            c. internet
            d. telephone
        In the case of “d” sending a written acknowledgement by the creditor should be enough as
        evidence.

        Reason:
        It is for the debtors benefit to process mandate changes as easy as possible. Insisting on an
        original paper form creates disproportional costs without any additional benefits for the debtor.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.



Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-16 Bitkom - Debtor Bank details change                                                            4 August 20
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-16 Bitkom - Debtor Bank details change                                                  4 August 20
Doc:EPC243-11-17                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM




                                                           Template


               for proposing a suggestion for a change in a SEPA Payment Scheme
                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-05
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
       The requirements for the mandate should consider the IBAN-only procedure. For national account it
       should not be necessary to provide the BIC in the mandate.

       This suggestion is to be included in the EPC rulebooks.
       It impacts on:
       - the Scheme in general

       This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)




EPC243-11-17 Bitkom - No BIC on Mandate                                                    4 August 2010
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-17 Bitkom - No BIC on Mandate                                            4 August 2010
Doc:EPC243-11-18                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                           Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-06
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)



 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
        If it is allowed by national legislation to provide the account number and national sorting code
                                                              st
        instead of the IBAN for national payments until 1 February 2016, it should also be allowed to use
        the account number and the national sorting code instead of the IBAN to issue a mandate.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-18 Bitkom - National sorting code                                                  4 August 2010
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-18 Bitkom - National sorting code                                        4 August 2010
Doc:EPC243-11-19                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-07
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  AGES Maut System GmbH & Co. KG                           (Mr. Frambach)
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
       The DK (Deutsche Kreditwirtschaft) mandate samples are not in accordance to formal regulations
       of the EPC rulebook:
               o The compliance with the order of the mandate information
               o The obligation to indicate the specified identifier (field names)
               o The obligation to specify a statement to the payee for the mandate return
               o The clear separation of the mandate from any other text
       These rules should no longer be listed in the rulebooks as mandatory guidelines. They should be
       considered more as non-binding recommendations for the issue of a mandate.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-19 Bitkom - Mandate guidelines                                                   4 August 2010
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-19 Bitkom - Mandate guidelines                                           4 August 2010
Doc:EPC243-11-20                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-08
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  AGES Maut System GmbH & Co. KG                           (Mr. Frambach)
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)

 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
        Remittance information:
        The 140 characters for the remittance information are not sufficient and are a step backwards
        compared to the current German-DTA procedure. A longer remittance information (at least 1000
        characters) is necessary.
        Reason:
        If SEPA payment transaction should support the pan-European implementation of the electronic
        invoice, the remittance information length should be adjusted according to the standard for the
        electronic invoice.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the interbank space
        - the message standards (Implementation Guidelines)

        This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-20 Bitkom - Remittance information                                                 4 August 2010
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-20 Bitkom - Remittance information                                       4 August 2010
           Doc:EPC243-11-21                                                                                               4 August 2011
           (Version 1.0)                                                                                                            AM


                                                                 Template


                         for proposing a suggestion for a change in a SEPA Payment Scheme

                           (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of            Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact            Head of Department Banking&Financial Services
details:

Your               BITKOM-B2B-09
reference:

Scheme and         SEPA Business-to-Business Direct Debit Scheme.
document           EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                   This template is provided by EPC to allow any person or organisation to submit a suggestion for
                   making a change to the SEPA Schemes in accordance with the rules set out in the document ‘SEPA
For
                   Scheme      Management       Internal   Rules’    available    on      the     EPC     Website:
information:
                   http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                   *Remarks:
                   The proposal is also supported by the following associations / company:
                   BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                   BVH German E-Commerce and Distance Selling Trade Association
                   HDE German Retail Federation (MR. Binnenbößel)
                   VDZ Verband Deutscher Zeitschriftenverleger
                   AGES Maut System GmbH & Co. KG                         (Mr. Frambach)
                   Easycash GmbH (Mr. Di Ruocco)
                   Inter Card AG (Mr. Adolph)



             EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                             Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1    GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
        Waiving the pre-notification in the scope of an AOS or eliminating the specification of an exact
        amount in the pre-notification concerning certain transactions.

        Reason:
        Due to high formal demands, based on the pre-notification, SEPA direct debit cannot be applied
        anymore. Whereas today the DTA direct debit is being used and has proven its worth for the
        debtor as well as for the creditor.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is to be added as an optional rule alongside an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-21 Bitkom - Pre-notification                                                          4 August 2010
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             no
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-21 Bitkom - Pre-notification                                             4 August 2010
Doc:EPC243-11-22                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-11
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)



 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
       No consideration of blanks in the unique mandate reference (AT-01)

       Reason:
       It is not possible to identify leading and following blanks as well as the number of blanks on the
       paper mandate. If the payer wants to refuse a SDD, he needs to specify the mandate ID. If the
       blanks are considered, the debtors’ rights would be ineffective.

       This suggestion is to be included in the EPC rulebooks.
       It impacts on:
       - the Scheme in general

       This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)




EPC243-11-22 Bitkom - UMR                                                                       4 August 2010
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-22 Bitkom - UMR                                                          4 August 2010
Doc:EPC243-11-23                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-12
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)



 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
       In the context of the transaction type (AT-21) and the amendment (AmdmntInd / AT-24) clear rules
       should be taken into the rulebook. Otherwise there will be a danger that the debtor banks create
       different standards.
       Explanation:
        a) Direct debits B1, B2…Bn, which follow a FRST direct debit A with the same account
           information, are RCUR direct debits.
        b) Direct debits D1, D2…Dn without notification of changes (data element AmdmntInd missing)
           follow a direct debit C with a change notice (AmdmntInd = TRUE), if no notifiable changes have
           occurred in the meantime.

        These statements are valid, if direct debit A or direct debit C has not been returned.
        What effect does it have on the direct debits B1, B2…Bn (D1, D2…Dn),
        1) if there is a reject of the direct debit A (or C) by the creditor bank?
        2) if there is a reject of the direct debit A (or C) by the CSM? Does the return reason also have
           influence on the direct debits B1, B2…Bn (D1, D2…Dn)?
        3) if there is a refusal of the direct debit A (or C) by the debtor (pacs.002 with initiator=debtor)?
           Does the return reason also have influence on the direct debits B1, B2…Bn (D1, D2…Dn)?
        4) if there is a reject of the direct debit A (or C) by the debtor bank (pacs.002 with initiator=debtor
           bank)? Does the return reason also have influence on the direct debits B1, B2…Bn (D1,
           D2…Dn)?
        5) if there is a refund of the direct debit A (or C) by the debtor (pacs.004 with initiator=debtor)?
           Does the return reason also have influence on the direct debits B1, B2…Bn (D1, D2…Dn)?
        6) if there is a return of the direct debit A (or C) by the debtor bank (pacs.004 with initiator=debtor
           bank)? Does the return reason also have influence on the direct debits B1, B2…Bn (D1,
           D2…Dn)?
        7) if there is a refund of a non-authorized direct debit A (or C)(pacs.004) in respect to direct debit
           B1, B2,…Bn ( or D1, D2,…, Dn)? Does the return reason also have influence on the direct
           debits B1, B2…Bn (D1, D2…Dn)?

        Clear rules need to be implemented in the rulebooks. Otherwise it is to fear that the debtor banks
        apply different, unequal standards.

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space


EPC243-11-23 Bitkom - Clarification AT-21 and AT-24                                                               4 August 20
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-23 Bitkom - Clarification AT-21 and AT-24                                                4 August 20
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-23 Bitkom - Clarification AT-21 and AT-24                                               4 August 20
Doc:EPC243-11-24                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           Michael Barth (BITKOM)
contributor:

Organisation:      BITKOM e.V. *

Address:           Albrechtstraße 10a, D-10117 Berlin

Contact           Head of Department Banking&Financial Services
details:

Your              BITKOM-B2B-13
reference:

Scheme and        SEPA Business-to-Business Direct Debit Scheme.
document          EPC222-07 version 4.0 (effective November 2012)
and version
number:

Date:              27 February 2012


                  This template is provided by EPC to allow any person or organisation to submit a
                  suggestion for making a change to the SEPA Schemes in accordance with the rules set out
For
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
information:
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155
                  *Remarks:
                  The proposal is also supported by the following associations / company:
                  BDIU Bundesverband Deutscher Inkasso-Unternehmen e.V (Ms. Schmidt)
                  BVH German E-Commerce and Distance Selling Trade Association
                  HDE German Retail Federation (MR. Binnenbößel)
                  VDZ Verband Deutscher Zeitschriftenverleger
                  Easycash GmbH (Mr. Di Ruocco)
                  Inter Card AG (Mr. Adolph)



 EPC AISBL Secretariat – Av. de Tervueren 12 – B 1040 Brussels Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                 Enterprise N° 0873.268.927 www.epc-cep.eu        secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):
Description of the suggestion:
       In the context of a one-off SDD clear rules should be implemented by the rulebook. Otherwise there
       is a danger that the debtor banks will create different standards.
       Is an one-off direct debit (OOFF) allowed to be sent in again,
        1) if it has been rejected by the creditor bank?
        2) if it has been rejected by the CMS?
        3) if it has been refused by the debtor (pacs.002 with initiator=debtor)? Does the return reason
            have any influence?
        4) if it has been rejected by the debtor bank (pacs.002 with initiator=debtor bank)? Does the return
            reason have any influence?
        5) if it has been refunded by the debtor (pacs.004 with initiator=debtor)? Does the return reason
            have any influence?
        6) if it has been returned by the debtor bank (pacs.004 with initiator=debtor bank)? Does the
            return reason have any influence?
        7) if it has been refunded as a non-authorized direct debit? Does the return reason have any
            influence?

        This suggestion is to be included in the EPC rulebooks.
        It impacts on:
        - the Scheme in general

        This suggestion is a change to replace an existing Rulebook element.




Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
            a. A change (replacing an existing Rulebook element by a new one)
            b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
               element)




EPC243-11-24 Bitkom - One-off collections                                                     4 August 2010
2    Elements for evaluation
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             yes
acceptance?

Is the suggestion underpinned by a cost-benefit    --
analysis?
Does the change fit in the strategic objectives for yes
SEPA?
Do you consider that the implementation of the     yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      yes
scope of the scheme involved?




EPC243-11-24 Bitkom - One-off collections                                          4 August 2010
Doc:EPC243-11-33                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           EPC Secretariat ("EPC Secretariat")
contributor:

Organisation: European Payments Council ("EPC")

Address:          [ ]

Contact           [ ]
details:

Your              [ ]
reference:

Scheme and        Credit Transfer Scheme Rulebook – version 6.0
document          SDD Core Scheme Rulebook version 6.0
and version
number:           SDD B2B Scheme Rulebook version 4.0

Date:             [ ] February 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




               Conseil Européen des Paiements AISBL – Av. de Tervueren 12 – B 1040 Brussels
                                Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                   Enterprise N° 0873.268.927 www.epc-cep.eu    secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):       [November 2012]
Description of the suggestion:         see below


Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)


Section 5.11 of the Rulebook allows a Participant to terminate its status as a Participant by giving
no less than six months' prior written notice to the SMC of the EPC, such notice to take effect on a
designated day (for which purpose such a day will be designated at least one day for each month).
However, section 5.11 of the Rulebook does not contain any provisions allowing the SMC to agree
on a shorter notice period with the relevant Participant.
The EPC Secretariat therefore proposes to add a new second paragraph to section 5.11 as follows:
“Notwithstanding the previous paragraph, upon receipt of the Participant’s notice of termination by
the SMC, the Participant and the SMC may mutually agree for the termination to take effect on
any day prior to the relevant designated day.”
This proposed change is intended to increase flexibility in the termination process.
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No, but the suggestion is not believed to involve
analysis?                                          operational expense for the Scheme Participants.
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?
Doc:EPC243-11-34                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           EPC Legal Support Group ("LSG")
contributor:

Organisation: European Payments Council ("EPC")

Address:          [ ]

Contact           [ ]
details:

Your              [ ]
reference:

Scheme and        Business to Business Direct Debit Scheme Rulebook – version 4.0 (EPC222-07) (the
document          "Rulebook")
and version
number:

Date:             [ ] February 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




               Conseil Européen des Paiements AISBL – Av. de Tervueren 12 – B 1040 Brussels
                                Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                   Enterprise N° 0873.268.927 www.epc-cep.eu    secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):       [November 2012]
Description of the suggestion:         see below


Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)
Section 5.9.1 of the e-Mandate rules in Annex VII of the Rulebook currently mirrors the equivalent
section in Annex VII of the Core Scheme Rulebook regarding e-Mandates and contemplates that
the Debtor has Refund rights. This is not correct under the B2B Scheme. Even though
unauthorised transactions may give a Debtor the right to receive a refund under the Payment
Services Directive, the Rulebook contains no equivalent provisions to PT-04.20 to PT-04.27 or
Annex VI of the Core Scheme Rulebook. This is because the Debtor Bank under the B2B Scheme
is obliged to carry out checks under section 4.2 of the Rulebook, so as to manage the risk of
unauthorised payment transactions.
Accordingly, a right of indemnity in favour of the Debtor Bank in respect of Refunds relating to
unauthorised payment transactions is not required. This issue is correctly addressed in section 5.9.1
of the Rulebook in relation to paper Mandates, where the indemnity right in question is confined to
Returns. However, the equivalent provisions of Annex VII of the Rulebook grant an indemnity
right in relation to a Refund to the Debtor Bank, despite the fact that the Rulebook does not make
provision for a Refund payment and even though the Debtor Bank's duties relating to an e-Mandate
are greater than those applicable to paper Mandates (PT-07.04).
Accordingly, the LSG proposes to correct this discrepancy, by deleting the e-Mandate version of
section 5.9.1 and removing the reference to "e-Mandates" at the beginning of section 5.9 of the
paper-based Mandate rules.
This proposed change is intended to clarify the legal indemnity rules relating to e-Mandates in the
Rulebook and to conform them to the principles underlying the B2B Scheme. It has no impact on
the interbank space, or the message standards of the Rulebook.
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No, but none of the suggestions are believed to involve
analysis?                                          operational expense for the Scheme Participants.
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?
Doc:EPC243-11-35                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           EPC Legal Support Group ("LSG")
contributor:

Organisation: European Payments Council ("EPC")

Address:          [ ]

Contact           [ ]
details:

Your              [ ]
reference:

Scheme and        Business to Business Direct Debit Scheme Rulebook – version 4.0 (EPC222-07) (the
document          "Rulebook")
and version
number:

Date:             [ ] February 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




               Conseil Européen des Paiements AISBL – Av. de Tervueren 12 – B 1040 Brussels
                                Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                   Enterprise N° 0873.268.927 www.epc-cep.eu    secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):       [November 2012]
Description of the suggestion:         see below


Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)


Section 5.15 of the Rulebook sets out contractual provisions that govern the Rulebook.
However, section 5.15 of the Rulebook does not contain any requirements for, or other provisions
about, notices that are given in accordance with the Rulebook.
In addition, section 5.15 requires that all documents required to be provided under the Rulebook
shall be provided in the English language. However, if, for example, a Swiss bank provides a
French language document to a French bank, this requirement would involve translating the
document into English, even though both parties are able to read French. Therefore, the LSG
proposes that documents should only be translated into English if the party receiving the document
so requests.
The LSG therefore proposes that paragraph 6 of section 5.15 is deleted (which reads "Every
document that is required to be provided by one party to another or by a party to the EPC or vice
versa, under the Rulebook shall be provided in the English language") and is replaced by the
following paragraphs:
"Where a document is required to be provided by one party to another party, and this document is
provided in a language other than English, the recipient of the document may request an English
language translation of the document. If such a request is made, the person providing the document
shall also provide a translation of the document into English.
All notices that are required to be provided by one party to another or by a party to the EPC or vice
versa, under this Rulebook shall be provided in writing. Such notices may be made in any way and
using any mechanism. Notices (other than notices to the EPC) submitted via electronic means, i.e.
via e-mail shall be considered as notices in writing.
A communication by post which is correctly addressed is deemed to be made seven calendar days
after posting (postage pre-paid). A communication by facsimile transmission is deemed made
when the sending fax machine records a complete and correctly addressed transmission. A
communication by e-mail is deemed made when the e-mail has been sent, having been properly
addressed, and no notice of non-delivery has been received."
This proposed change is intended to ensure certainty as to when a notice is validly given, and when
time limits relating to notices expire, for example where a Participant is required to respond to a
notice within a certain period.
It is also intended to ensure that English translations of documents are only required where the
recipient does not understand the document in its original language.
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No, but none of the suggestions are believed to involved
analysis?                                          operational expense for the Scheme Participants.
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?
Doc:EPC243-11-46                                                                                               4 August 2011
(Version 1.0)                                                                                                            AM


                                                      Template


               for proposing a suggestion for a change in a SEPA Payment Scheme

                (Responses by e-mail to: info@epc-cep.eu or by mail to the address at the foot of this page)

Name of           EPC Legal Support Group ("LSG")
contributor:

Organisation: European Payments Council ("EPC")

Address:          [ ]

Contact           [ ]
details:

Your              [ ]
reference:

Scheme and        Business to Business Direct Debit Scheme Rulebook – version 4.0 (EPC222-07) (the
document          "Rulebook")
and version
number:

Date:             [ ] February 2012




For               This template is provided by EPC to allow any person or organisation to submit a
information:      suggestion for making a change to the SEPA Schemes in accordance with the rules set out
                  in the document ‘SEPA Scheme Management Internal Rules’ available on the EPC
                  Website:
                  http://www.europeanpaymentscouncil.eu/knowledge_bank_detail.cfm?documents_id=155




               Conseil Européen des Paiements AISBL– Av. de Tervueren 12 – B 1040 Brussels
                                Tel: +32 2 733 35 33 Fax: +32 2 736 49 88
                   Enterprise N° 0873.268.927 www.epc-cep.eu    secretariat@epc-cep.eu
1   GENERAL DESCRIPTION OF THE SUGGESTION
Suggested launch date: (if any):       [November 2012]
Description of the suggestion:         see below


Wherever possible, please indicate:
    1. Impact on the Scheme in general
    2. Impact on the interbank space
    3. Impact on the message standards (SEPA Scheme Implementation Guidelines and other
       standards)
    4. Impact on the legal rules as defined in chapter 5 of the Scheme Rulebooks
    5. The nature of the suggestion:
           a. A change (replacing an existing Rulebook element by a new one)
           b. A variant (adding an alternative – optional – rule alongside an existing Rulebook
              element)


The "description section" of PT-04.09 under section 4.6.4 of the Rulebook currently provides that
"the Debtor Bank has no refund right under the Scheme in case a consumer account is debited in
error" (emphasis added).
In determining whether the Debtor Bank is entitled to get reimbursed from the Creditor Bank, it is
irrelevant whether the Debtor is a consumer or not; for example, a business customer may use the
Core Scheme and therefore be entitled to a refund. The LSG is of the view that the above-
mentioned wording should be amended so as to warn Debtor Banks that no refund reimbursement
will be available if any account that is not authorised for B2B is credited, irrespective of the status
of the Debtor.
Accordingly, the LSG proposes that the phrase "a consumer account" is replaced by "an account
not authorised for B2B".
This proposed change is intended to clarify that the status of the Debtor as a consumer is not
relevant in making the determination as to whether a refund right is available. It has no impact on
the interbank space, the message standards or the legal rules contained in section 5 of the
Rulebook.
2    ELEMENTS FOR EVALUATION
The submitting party is requested to give an appropriate answer to each of these questions with
sufficient detail to allow the EPC to make an evaluation of the suggestion submitted.
Is the suggestion a case for SEPA wide             Yes
acceptance?
Is the suggestion underpinned by a cost-benefit    No, but none of the suggestions are believed to involve
analysis?                                          operational expense for the Scheme Participants.
Does the change fit in the strategic objectives for Yes
SEPA?
Do you consider that the implementation of the     Yes
change resulting from the acceptance of the
suggestion is feasible?
Do you consider that the suggestion does not       Yes
impede SEPA-wide interoperability?
Do you consider that the suggestion is in the      Yes
scope of the scheme involved?

				
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