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The apparent demands for a lower limit are nothing more than a distraction. It potentially protects receiving firms, but does not remove the opportunity for customers to seek recourse via the FOS.

As the consultation observes the cost of compensation then falls on the sending firm and there is scope for up to £430K to be reimbursed. 

It will be interesting to see how some of the firms that have pressed for this change will react when they're the sender and the FOS rules against them based on a control failure. 

If we're victim-centric we will reject this change and embrace the current £415K limit as to do otherwise forces victims of high-value APP (who are few) to seek recourse via the FOS.

It is unethical friction, deployed on the demands of a few vocal PSPs who hope to delay the inevitable recognition that their performance in respect of financial crime is poor. 

When of comes to the clamour for a delay. I would replace reference to “banks” with some PSPs as none of the directed organisations are pressing for a delay. 

The call for a £30K limit is also a classic example of kicking the can down the road. 

The PSR came up with £415K as it aligned to the FoS limit, recognising that most APP claims will go on to be control failure claims if the PSP doesn’t address it via the APP reimbursement framework. 

As things currently stand most consumers post Oct 7 will have the scope to be awarded up to £430K (the FoS limit has increased) in the event that their PSP declines to reimburse under the FSMA provisions. 

FYI the £100 excess is optional and will likely become a differentiator in the market. I’d be surprised if many PSPs opt to use it. 

Lastly the necessity for thd PA’s to adopt this position does not reflect well on their members. 

The writing has been on the wall since 2016, only businesses with poor strategic governance ought to be exposed!