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Banfico Knowledge Series: Account Name Validation Confirmation of Payee (CoP) / IBAN Name Check

Banfico Knowledge Series on Account Name Validation is an initiative where we share market updates and insights into specific areas related to Confirmation of Payee (CoP) & IBAN Name Check that are relevant to all market participants including banks, PSPs and corporates.

Understanding the scope of CoP – Payments & Account Types

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Pay.UK has mandated the following payment types and account types as part of the scope for CoP:

Payment Types
In-scope
  • Faster Payments
  • CHAPS
  • Internal Transfers
  • Bacs Direct Credit Payments
Out-of-scope
  • Cheques
  • Cash Payments
  • Card-based transactions
  • Open Banking initiated payments (PISP)
Possible Future Consideration
  • Open Banking initiated payments (PISP)
  • Bacs Direct Debit payments
  • Card-based transactions
  • Direct corporate and other third-party access
Accounts in-scope

CoP applies to personal and business accounts in the UK that can be identified using either –

  • Sort Code/Account Number
  • Sort Code/Account Number/Secondary Reference Data
Note:

There are no restrictions on performing a CoP check, even on payments not in the “in-scope”. For example, a CoP check can be performed for pay-in cash at the counter, and the teller can manually verify the payee’s account.
By definition, there are restrictions on when a CoP check can be made. For example, there must always be the intention of making a payment. However, there are many use cases where a CoP would legitimately be in scope e.g. paying a cash over-the-counter to be sent to an account (via FP/BACS)

CoP Regulatory References

PSR Policy Statement PS23/3 – APP Fraud New Reimbursement Requirement

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Start your Confirmation of Payee (CoP) Project to address your APP Fraud Reimbursements

On the 7th of June (2023), the Payment Systems Regulator (PSR) released a policy statement (PS23/3) introducing a new reimbursement requirement for Authorised Push Payment (APP) fraud within the Faster Payments system. The new reimbursement requirement will apply to all Payment Service Providers (PSPs) including high-street banks, building societies and smaller payment firms.

The new reimbursement requirement covers 10 key policies:

10 Key Policies
  1. PSPs must reimburse all customers who are victim of APP fraud in Fast Payments Scheme
  2. The cost of reimbursement must be shared 50:50 by the sending PSP and the receiving PSP
  3. First-party fraud by the customer themselves or gross negligence of the customer are exempted from reimbursement
  4. The reimbursement must be done within 5 business days by the sending PSP
  5. Sending PSPs have the option to apply a claim excess under the new reimbursement requirement. This is subject to further consultation
  6. There is no minimum claim amount set for the APP fraud reimbursement
  7. The maximum amount (by value) that needs to be reimbursed is yet to be consulted
  8. APP fraud reimbursement can’t be claimed after 13 months of its payment. Sending PSP can deny such a claim
  9. Provide additional protections for vulnerable customers
  10. The reimbursement also applies to accounts controlled by other than the customer themself – where the controlling person has deceived the customer.

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CoP Integration: Tactical vs Full Implementation Options

CoP implementation using a vendor solution includes:

  • Inbound integration – provides the ability to receive and respond to incoming requests from other participants
  • Outbound integration – provides the ability to send name check requests to other participants

For both Inbound and Outbound integrations, Banfico offers a tactical option (Day 1 go-live) and a full integration option using API.

1. Inbound Integration

Tactical Option – Bank accounts are uploaded

Full Implementation Option – API integration with the core bank and the ability to address the requirements of the Information Security team on the connectivity

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2. Outbound Integration

Tactical Option – Manual name-check on the CoP portal is available on day one

Full Implementation Option – Channel-specific integration using API. Even non-electronic channels need to be factored in (eg. file payments, branch payments, phone payments)

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Banfico can work with PSPs and help them decide their preferred option for each integration based on the following factors:

  • Go-live timeline
  • Availability of PSP’s internal team resources – esp for the customer channels’ integration
  • Nature of core-banking integration (e.g. certain legacy systems may not be able to meet Pay.UK response time SLAs with API option)
  • Business model for bank accounts management (based on the number of accounts, frequency of account additions/deletions, etc.,)
  • Phased approach on outbound or inbound or both

PSPs can also opt to choose the tactical option for Day-1 and later replace it with the API option in the near future with minimal cost implications.

Plan your Confirmation of Payee (CoP) delivery based on the integration requirements.
CoP Regulatory References

CoP Direct Participant vs Aggregator Models Share your preference to Pay.UK

Recently Pay.UK has reached out to PSPs asking about their preferred operating model for CoP participation

  • Current Direct Participant model (70+ PSPs live)
  • Upcoming Aggregator model (early 2024)
A. Direct Participant Model

A PSP has to onboard into Pay.UK and then into Open Banking CoP Directory & sign multiple contracts.

Advantages –
  • Enjoy the benefits of the CoP today
  • Start the CoP project now – minimise delivery risk
Shortcomings –
  • Higher cost of the project
  • More responsibilities with respect to onboarding and ongoing-support

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B. Aggregator Model

A PSP will work with an aggregator, who handles onboarding with Pay.UK and Open Banking CoP directory.

Advantages –
  • Pay.UK & Open Banking CoP Directory onboarding formalities eliminated for PSPs
  • Lesser cost of the project
  • Better support from the aggregator rather than directly dealing with all PSPs and Pay.UK
Shortcomings –
  • Waiting till early 2024, you miss out on the benefits of CoP today
  • Also, a late start in 2024 could lead to delivery risk

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Recommendation

Considering the operational aspects, legal contracts, pricing and time-to-deliver, we recommend you support the aggregator model, which Banfico has been campaigning for some time. However, the Pay.UK’s proposed timeline (early 2024) is a cause for concern.

CoP Regulatory References

Enabling CoP Checks for Corporate Channels

Confirmation of Payee (CoP) check is essential for payment types such as FPS, CHAPS, and BACS whether processed electronically or manually.

Typically, Corporates use the below channels to process payments with the PSP/Banks:

  • Corporate Internet Banking
  • ERP Systems
  • File payments
  • Manual Payments

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How to address CoP Checks?
  • Corporate Internet Banking: The PSPs need to update their customer experience workflow for adding payee/beneficiary details so that a CoP check is done before payment initiation. This involves changes in the UI/UX and they need to be integrated with the CoP solution via API.
  • ERP Systems: The ERP providers like SAP, Oracle Financial, and Salesforce – are all currently offering multi-bank-connectors. The CoP will be one such connectivity enabled through APIs on the Cash Management/Treasury applications.
  • File Payments: Systems like H2H, and SWIFT would generate file payment instructions and are typically processed through SFTP. Such file payments would also need to enable CoP check through the back office team manually or automated through API calls to the CoP solution.
  • Manual Payments: The PSP team handling corporate customer payment instruction (e.g. phone or branch) also needs to do a CoP check on their own PSP systems (e.g. CoP Back-office Portal) and provide feedback to the corporate customer of the CoP check result and request their confirmation to proceed with the payment.
How can we help?

Banfico CoP Solution offers the features to address all these corporate channels by means of the CoP Portal and CoP API. For a further detailed discussion on how to support your use cases, contact us for a meeting.

CoP Regulatory References

How can CoP support Direct Debit mandate setup?

Payer Name Verification – new service by Pay.UK

Pay.UK recently announced the launch of a new service – Payer Name Verification, which leverages Confirmation of Payee (CoP) for the Payer Name Check – especially focusing on the Direct Debit (DD) mandate setup.

Direct Debit mandate expects the corporates to confirm the payer before the setup is finalised. Traditionally, corporates and PSPs have not involved extra validations in this process. However, with the implementation of Payer Name Verification through CoP, such checks could now be supported and significantly reduce the risk of misdirected payments and fraud scenarios.

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The diagram above illustrates how the CoP framework can be seamlessly incorporated into the Direct Debit setup process, ensuring more accurate verification of payer names.

Payer Name Verification – Interested?

If you are a corporate or a PSP handling corporates, we encourage you to explore the benefits of Payer Name Verification and to benefit from this service you should contact Pay.UK. Please note that this service may require additional MI reporting.

CoP Regulatory References

The impact of PSD3 on the IBAN name checks

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Recently the European Commission has published further legislation proposal in regard to the next phase of financial services in the EU. The third Payment Services Directive (PSD3) will be coupled with a new Payment Services Regulation (PSR) to build on the progress made since PSD2’s introduction.

Since the introduction of PSD2, new types of fraud have emerged, such as “spoofing” (impersonation fraud), and the current prevention mechanisms such as SCA are not efficient enough to prevent such frauds. Therefore, PSD3 focuses on strengthening measures to combat payment fraud and has introduced IBAN name checks that can help prevent these types of fraud.

The new proposed prevention measures

The following are the new proposed prevention measures, and you can find the details in the new legislative proposals under the Fraud and liability section:

  • An extension to all credit transfers of IBAN name matching verification services. These have been proposed by the Commission for instant payments in Euro. All consumers should benefit from them, for both regular and instant credit transfers;
  • A legal basis for PSPs to share fraud-related information between themselves in full respect of GDPR (via dedicated IT platforms);
  • The strengthening of transaction monitoring;
  • An obligation by PSPs to carry out education actions to increase awareness of payments fraud among their customers and staff; and
  • An extension of refund rights of consumers in certain situations.
Refund rights

The new proposal enables the granting of refund rights in two situations:

  • for consumers who suffered damages caused by the failure of the IBAN name verification service to detect a mismatch between the name and IBAN of the payee
  • for consumers falling victim to a “spoofing” fraud where the fraudster contacts the consumer pretending to be an employee of the consumer’s bank, tricking the consumer into carrying out some actions causing financial damages to the consumer

Victims of “spoofing” fraud can be entitled to claim damages from their PSP for the full amount of the fraudulent transaction.

However, refunds would not be allowed in cases of “gross negligence” by the victim, including falling victim more than once to the same kind of fraud, and the “spoofing” would have to be convincing, for example replicating the bank’s exact email address or phone number. Additionally, in the previous email, we shared with you the new reimbursement requirements in the UK and you can find it here.

CoP Regulatory References

European Instant Payments (IP) Regulation requires IBAN Name Check

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IP Regulation (2022/0341 COD) proposal is in the final stage of adoption in the EU parliament. It is expected to be published by Autumn 2023. Payment Service Providers (PSPs) will then have 12 months to implement IBAN Name Checks in their instant payments.

Understanding Article 5c: Key Points
  • Validation and Notification: PSPs are obligated to verify if the payee’s name and account identifier (e.g., IBAN) provided by the payer match.
  • Authorisation Despite Discrepancy: Even if a discrepancy is identified and communicated, the process must not prevent the payer from authorising the instant credit transfer.
  • Opt-out and Opt-in Rights: Payment Service Users (PSUs) have the right to opt out of the discrepancy notification service. PSUs retain the right to opt back in.
  • Transference Risks and Information Disclosure: PSPs must inform PSUs that authorising a transaction despite a discrepancy notification could result in transferring funds to the incorrect account.
  • Interface Irrelevance: The discrepancy notification service must be provided to the payer, irrespective of the PSU interface – PoS, eCommerce, Branch, Phone, Mobile app, Web.
  • Compliance Deadlines:
    – PSPs using the Euro must comply within 12 months
    – PSPs using the non-Euro must comply within 36 months
European IBAN Name Verification – Banfico’s position
  • Timeline – 12 months is a short time to implement IBAN Name Check across all EU member states
  • Channels – Not feasible for all channels – e.g. ATM, Branches, Phone Banking and batch payments
  • Liability Framework – Important to have a clear liability framework in place
  • Name Matching Rules – Practical issues in building robust name matching rules across all member states
  • Fees – It’s possible PSPs may charge a fee for providing this service
Positions of other Key Market Players

The EBFs position on the Proposal for Instant Payment Regulation
ESBG position paper on the proposal of regulation for instant credit transfers
Industry feedback on the implementation of Instant Payment Regulation

CoP Regulatory References

CoP Event Panel Discussion – Insights & FAQ

On August 23rd, we hosted our Confirmation of Payee Breakfast Event at The Ned Hotel in London. The discussions spanned a variety of topics, from the adoption of CoP in the UK and International IBAN Name Check, to Instant Payment Regulation in Europe, Pay.UK’s Fraud Program, and best practices for CoP implementation.
We are proud to share that the event attracted more than 72 participants, representing over 38 Financial Institutions from across the UK and Ireland.

Panel Discussion and Q & As

We had the privilege of welcoming several industry experts to join us for a valuable and insightful panel discussion, including a key representative from Pay.UK. In addition to the broad range of topics discussed, our audience also had the opportunity to highlight and discuss some of their key questions and comments with our industry experts. Some of the key questions posed to our panel included:

1. What is the ‘aggregator model’ and how can this address scalability issues when a large number of financial institutions join CoP?
  • The participant (aggregator) model involves Technical Solution Providers such as Banfico becoming a direct participant within the CoP framework, with financial institutions operating as an indirect participant behind the respective TSP’s. This is a similar model to those operated by some clearing schemes and could help greatly improve the speed of onboarding new financial institutions into the CoP scheme.
2. What is the ‘Payer Name Verification’ initiative, and what are some of the use cases it can address?
  • Payer Name Verification (PNV) is an extension of CoP, allowing organisations who are already a member of CoP to perform an account name check before setting up or amending a BACS Direct Debit payment. PNV ultimately ensures that payments are collected from the correct account number, reducing the risk and costs of misdirected payments.
3. Is Pay.UK considering adding risk data to their future schemas?
  • Pay.UK, in collaboration with the UK Finance’s Enhanced Fraud Data Working Group, has now developed the ‘Enhanced Fraud Data Schema’, allowing for the categorisation of relevant customer data enabling both banks involved in the processing of a payment to more easily identify a fraudulent transaction.

We have summarised the complete set of questions and answers proposed during our panel session in a FAQ document. You can download the FAQ document below.

CoP Regulatory References

The Impact of Secondary Reference Data (SRD) on CoP

What is Secondary Reference Data (SRD)?
  • Some accounts require a reference to be entered for the payment in order for it to be reconciled with the underlying account, for example, a 16-digit credit card number when paying a credit card bill, or a roll number for some building society accounts. This is called Secondary Reference Data (SRD).
Does this impact a CoP Participant even if they don’t have accounts identifiable by SRD?
  • Yes, because a customer may want to make a payment to an account held by another bank that is identifiable by SRD. So, all participants must have the capability to support Outbound CoP requests to SRD accounts.
How can CoP participants incorporate SRD into their CoP checks?
  • As a CoP Requester, the participant uses the information available in the CoP directory to determine whether a particular payee account requires SRD and then prompts the Payer that the SRD is required to perform the CoP check on that account.
  • As a CoP Responder offering SRD identifiable accounts to its customers, the participant must use the SRD to fetch the account details for which the CoP check needs to be performed and compare the name on that account against the name sent by the payer’s PSP.

If the participant uses a CoP solution from a vendor like Banfico, the vendor will support the above SRD related requirements.

Join us for our CoP Webinar for Building Societies on Thursday the 5th of October at 11:00 AM BST, where we will be exploring a range of topics including the impact of Secondary Reference Data. Register your place here

CoP Regulatory References

Pay.UK Directory Changes & Aggregator Model Update

What is the aggregator model from Pay.UK?
  • This new participant model, named the Aggregator model, is set to give access to entities like PSPs and corporates interested in implementing Confirmation of Payee (CoP) but may lack the resources to directly implement themselves
  • The model involves third-parties such as Payment Service Providers (PSPs) and Technical Solution Providers (TSPs) becoming direct participants within the CoP service; PSPs and corporates will connect with these direct participants, operating as indirect participants in the CoP service
  • At Banfico, we have the capability to provide you with this indirect access
Is the CoP Directory changing?
  • Yes, Pay.UK is going to be building a new directory service and CoP is set to move to the new directory
  • Banfico believes this change will create some operational issues and added overhead for institutions needing to implement CoP
  • Please refer to recent communication by Pay.UK and reach out directly to representatives at Pay.UK to understand the full impact of the directory changes on your institution
Will this impact my CoP delivery timelines?
  • Yes, we anticipate this change will have an impact on your CoP delivery timelines
  • This is due to the fact a new directory service provider will need to be onboarded before institutions can implement CoP
  • Institutions should perform an impact assessment of these changes to their institution and can reach out to Banfico for support
What should we do if we are already being onboarded onto the directory?
  • Current onboarding and migration timelines are unclear
  • Institutions should wait for further communication from Pay.UK, or talk to their Pay.UK representatives directly
  • Firms should also engage with the OBIE directly as far as any contractual obligations are concerned
CoP Regulatory References

Faster Payments Participants – Implementing the Reimbursement Requirement

FasterPayments

Consultation summary and why a specific direction?
  • The reimbursement requirement for APP scams has been designed to boost protections for consumers and to help reduce scams from happening.
  • It has been deemed that Pay.UK’s current scheme rules and powers lack the reach to achieve this effectively
  • Therefore, this proposed specific direction obliges Faster Payment PSPs to comply with the reimbursement rules and provide Pay.UK with APP fraud data.
  • The deadline for responding to this consultation is 5 pm on 19 October 2023.
Which transactions will the direction apply to?
  • The proposed specific direction will apply to all Faster Payments PSPs who provide a payment account in the UK to their payment service users which can send or receive Faster Payments.
Reporting of APP scam data
  • PSPs will be obligated to report APP scam case data to Pay.UK
  • This is due to the fact a new directory service provider will need to be onboarded before institutions can implement CoP
  • Pay.UK will specify the frequency, form and nature of the reporting data required.
Implementation (go-live) date
  • The implementation (go-live) date is the date that the reimbursement requirement would come into force.
  • The industry response was that an April 2024 go-live was unachievable, therefore the PSR is inviting views on a new implementation date of 7th October 2024.
CHAPS Timeline
  • The Bank of England has announced its intention to introduce comparable reimbursement requirements for CHAPS. The PSR is working closely with the BoE on the effective implementation of reimbursement requirements for CHAPS payments.
CoP Regulatory References

Pay.UK’s Aggregator Model: Weighing the Risks and Rewards of Delaying Your CoP Programme

What is the aggregator model and when it is coming?
  • The aggregator model involves Technical solution providers (TSPs) such as Banfico becoming direct participants within the CoP framework, with financial institutions operating as indirect participants behind the respective TSPs.
  • This approach has been designed to allow more organisations to participate in CoP, and should greatly improve the speed of onboarding new organisations into the CoP network.
How will this affect how organisations implement CoP?
  • The aggregator model allows institutions to be either direct or indirect participants in the CoP network. Both direct and indirect participation will run side-by-side.
  • Direct Participants: PSPs will directly integrate into the CoP network, handling their own connections, security protocols and other technical and operational aspects.
  • Indirect Participants: Instead of connecting directly to the CoP network, PSPs will indirectly connect through a TSP or vendor who provides a CoP solution. TSPs or vendors will act as ‘aggregators’ that funnel requests of multiple PSPs through their system.
What are the benefits of waiting for the aggregator model?
  • Simplified Onboarding: TSPs or vendors will handle the complexities of onboarding, including the technical and compliance aspects.
  • Lower Technical Burden: Smaller institutions without a strong IT backbone won’t need to deal with the technical challenges.
  • Cost-Effective: The aggregator model may be more cost-effective in the short term, as institutions could avoid significant upfront integration costs.
  • Access to Expertise: Vendors like Banfico specialise in CoP, and have the expertise in the domain, ensuring efficient and secure operations.
What are the risks of waiting to implement CoP?
  • Short Timelines: The aggregator model is expected to be operational in Spring 2024, and the CoP go-live deadline is October 2024. This leaves organisations around 6 months to go live with CoP.
  • Responder & Requestor: It is mandatory for all organisations to go live with a CoP responder service, and those with applicable payment types must implement a CoP Requestor service.
  • Customer Channel Integration: Organisations must integrate CoP checks into their online and offline customer channels. These implementation timelines can reach 6-9 months for full customer channel integration.
Contact Banfico for further advice
  • Banfico can help advise on the best approach for your institution, and can fully explain the benefits and risks of starting your CoP implementation now, or waiting until the aggregator model is live.
  • Reach out to Banfico today for insightful advice tailored to your institution’s unique needs.
CoP Regulatory References

PSR Publishes APP Fraud Performance Report

The Payment Systems Regulator has published its eagerly awaited Authorised Push Payment (APP) fraud performance data report. This report encompasses data from the 14 largest banking groups (known as directed firms), as well as data from nine other smaller firms that ranked among the top 20 recipients of APP fraud (known as non-directed firms).

What data is covered in the report?

With APP fraud accounting for 40% of total fraud losses in 2022, the publication of such fraud performance data is a significant step towards greater transparency. The performance data spans from 1st January 2022 to 31st December 2022, and outlines:

  • The reimbursement of victims (from the largest 14 banking groups)
  • How much money is sent from each payment firm as a result of APP fraud (from the largest 14 banking groups)
  • How much money is received by each payment firm as a result of APP fraud (all payment firms in the UK)

The PSR will continue collecting such data from payment firms over the next 12 months and will publish the 2023 performance report next year.

The PSR’s response to APP fraud

Alongside the recent APP fraud performance report, the PSR has been taking further steps to ensure more consistent consumer protections are in place. They recently published the mandatory reimbursement requirements for APP fraud victims, due to come into force in 2024.

Additionally, schemes such as Confirmation of Payee, in which the remaining ‘Group 2’ PSPs must go live by October 2024 are being rolled out to help reduce the incidences of APP fraud.

You can view the full publication from the PSR here.
CoP Regulatory References

Provisional Agreement Reached on Instant Payments Regulation

IP Regulation Proposal

The European Council and Parliament have now reached a provisional agreement on the Instant Payments Proposal (2022/0341 (COD))..

Instant payments allow customers to transfer money within ten seconds, within their own country and any EU member state. This proposal means Payments Service Providers (PSPs) such as banks, which offer euro credit transfers, will now be required to offer the sending and receiving of instant payments in euros.

Aims and Requirements of the Regulation

The following are the aims and requirements regarding euro instant payments:

  • To make instant euro payments universally available – PSPs who offer credit transfers in euro must also offer instant transfers
  • To make instant euro payments affordable – PSPs must ensure the price charged for instant euro payments is no more than the price charged for traditional, non-instant credit transfers in euros
  • To increase trust in credit transfers – PSPs must verify the match between the account name and the account number provided by the payer
  • To remove friction in instant euro payment transfers – PSPs must preserve the effectiveness of screening persons subject to EU sanctions by verifying at least daily their clients against EU sanctions lists
IBAN Name Check

Under the agreement, PSPs are required to verify the name on the account matches that of the account number entered by the customer, to alert the payer of a possible mistake of fraud before the payment is made. Key aspects of the required IBAN Name Check are:

  • Validation and Notification: PSPs must verify if the payee’s name and account identifier (e.g., IBAN) provided by the payer match.
  • Authorisation Despite Discrepancy: Even if a discrepancy is identified and communicated, the process must not prevent the payer from authorising the instant credit transfer.
  • Opt-out and Opt-in Rights: Payment Service Users (PSUs) can opt out of the discrepancy notification service. PSUs retain the right to opt back in.
  • Transference Risks and Information Disclosure: PSPs must inform PSUs that authorising a transaction despite a discrepancy notification could result in transferring funds to the incorrect account.
  • Interface Irrelevance: The discrepancy notification service must be provided to the payer, irrespective of the PSU interface – PoS, eCommerce, Branch, Phone, Mobile app, Web.
  • Compliance Deadlines:

    – PSPs using the Euro must comply within 12 months

    – PSPs using the non-Euro must comply within 36 months

CoP Regulatory References

Pay.UK Publishes Details on the Aggregator Model

Aggregator Model Update

Pay.UK have recently released details on the changes and updates being made to accommodate the new CoP access models to support the implementation of the PSR’s Specific Direction 17: Expanding confirmation of Payee..
Currently, in order for Payment Service Providers to participate CoP, they must be regulated by the FCA, hold UK customer payment accounts, and sign up with both Pay.UK and the OBIE.

Expansion of Confirmation of Payee

With the issuance of Specific Direction 17 by the PSR, which requires a widespread expansion of CoP to include payment routes and entities not meeting one of the above criteria, Pay.UK is expanding CoP in the following areas:

  • Introduction of participation models, including
    • Direct participation (the current model in place for CoP)
    • Aggregator for PSPs
    • Aggregator for Corporates
  • Direct participation for non-regulated entities
  • Simplifying the CoP contractual framework
How will this affect your CoP implementation?

The introduction of an aggregator model by Pay.UK brings several key benefits when working with a Technical Solution Provider such as Banfico:

  • Reduced Implementation timelines: With Banfico as an end-to-end implementation partner for CoP, the implementation timelines to go live with CoP are not only reduced but also places less pressure on your key internal implementation resources
  • Simplified onboarding process: Participants are no longer required to onboard separately with both Pay.UK and the OBIE directly, but only with Banfico, who will then take care of the onboarding process.
  • New linear contract structure: Only a single contract with Banfico is now needed to go live with CoP, with a warranty letter provided to Pay.UK.
  • Reduction in costs: Given the now simplified nature of CoP for participants, there will be a clear reduction in cost to implement CoP compared to the previous direct participant model.

Please contact us directly to discuss the impact of the aggregator model changes to your firm with one of our CoP experts.

CoP Regulatory References

The Future of Confirmation of Payee in the UK and Europe: What You Need to Know

With the Payment Services Regulator’s (PSR) Confirmation of Payee (CoP) regulation set to come into effect on the 31st of October 2024, Payment Service Providers (PSPs) in the UK and Europe need to prepare for significant changes. Here’s what you need to consider to ensure a smooth transition.

Key Aspects of CoP Implementation for PSPs

As the implementation date rapidly approaches, PSPs should start planning by considering:

  • Project Start Date and Timelines: Establish a clear project timeline from the onset, ensuring that there is ample time for each phase of implementation. As of now, there are just 9 months left to comply.
  • Participation Level: Decide whether to join the CoP network as an indirect participant or leverage the ‘Aggregator Model’ for greater efficiency and cost-effectiveness.
  • Integration with Core Banking Systems: Consider how the CoP service will integrate with your existing banking systems and customer service channels.
  • Secondary Reference Data (SRD): Understand the importance of SRD in the CoP process and how it will be managed within your systems.
  • European Expansion: Prepare for the future by developing a CoP solution that not only meets UK standards but is also adaptable to forthcoming European regulatory requirements.
European Instant Payments and IBAN Name Check

The European Commission’s draft proposal for Instant Payments indicates that financial institutions will have 18 months from the regulation coming into force to incorporate a CoP-style name check for Euro Instant payments within the EU.

This service must validate the payee’s name against the provided details and highlight any discrepancies to the payer without prohibiting the transaction.

Banfico: Expertise in Confirmation of Payee Compliance

Banfico stands as an expert in the realm of Confirmation of Payee (CoP), ready to advise Payment Service Providers (PSPs) on the key considerations above for full compliance.

In addition to our current development for a single API solution to meet the European Instant Payment IBAN Name Check requirements, we already offer CoP-style name checks to multiple jurisdictions, including the Americas, the Middle East and APAC.

CoP Regulatory References

Protection against fraud

Bank Account Validation
(CoP / IBAN Name Check)

Confirmation of Payee (CoP) and IBAN Name Check service are new ways of giving business and personal customers greater assurance that they are sending payments to their intended recipient, helping them to avoid making accidental or misdirected payments to the wrong account holder, as well as providing another layer of protection in the fight against fraud, particularly Authorised Push Payment (APP) scams.


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