How will payment institutions be required to safeguard customer funds in the future? This episode provides the answers – tune in now!
New rules for safeguarding customer funds
Those who handle other people’s money bear a significant responsibility – especially in times of crisis. The revised frameworks of PSD3 and PSR take this principle seriously and introduce new standards: not only do they set out how customer funds must be safeguarded going forward, but they also oblige banks to offer suitable accounts for this purpose.
In this episode, Peter Frey, Partner at Annerton, joins moderator Dana Wondra from Payment & Banking to explain the safeguarding methods that are being proposed. He discusses why trust accounts remain the prevailing model, why institutions will need to use multiple accounts in the future to reduce concentration risks, and what the potential implications are of allowing access to central bank accounts – including those offered by the Bundesbank, where available.
Progress in legal certainty and flexibility
A notable step forward: the insolvency protection of trust accounts will be legally recognised going forward. This change brings increased legal certainty and puts an end to long-standing uncertainties around shortfalls and account structures. Another key update: institutions will no longer be required to transfer customer funds to a separate account on the same day. Instead, they may do so by the next business day, allowing for greater operational flexibility.
This episode offers a clear and practical overview of what these developments mean for payment institutions, which challenges remain, and what actions should be taken now.
Tune in now – available wherever you get your podcasts.
About this podcast
Alles Legal – Fintech Recht Kompakt delivers sharp, weekly insights into legal and compliance matters in the world of banking. (in German only)
This podcast is a collaboration between Payment & Banking and PayTechLaw.
Each Wednesday, we unpack the legal developments shaping the financial world – clearly, concisely, and without the legal jargon.
Since 2021, PayTechLaw authors and Annerton attorneys have brought depth and clarity to complex topics.
Whether it’s PSD3, DORA, or FiDA – we provide the legal context you need.
In 20 minutes. No detours.
