2007-08-02 EPSM Comment ECB Draft Oversight

Oversight Framework for Card Payment Schemes - Requirements: thComments on the Draft Paper of the Eurosystem from 27 April 2007 Status: 2nd August 2007 In reference to the above mentioned draft paper, we would like to state the following comments: • General remarks: We support in general the five requirements in order to create a fair and transparent oversight which will be balanced towards all market participants and which will provide for reliable, trustworthy, but also cost-efficient payment schemes in a competitive market environment. It should be noted that the Eurosystem definition of a „payment scheme“ is highly unusual in the sense that it includes also the various subsystems as issuers, acquirers. Up to now, the „overall card management subsystem“ (in the Eurosystem definition) is worldwide typically called a „card payment scheme“ (e.g. organisations like MasterCard, Visa or Cartes Bancaires). For a clear and non-misleading language, we urge therefore strongly to use the existing terminology. In consequence of the graphics in Annex 1, we suggest to speak of „card payment systems“ with their various „subsystems“ instead of „card payment schemes“. • Definition of the covered systems: It should be clarified in a transparent process which systems shall be included in the oversight and which not: e.g. three party systems (American Express?), one-leg-systems with only acquiring in Europe (JCB?, China Union Pay?), or ...