“How safe is my money?” Safeguarding of customer funds held by payment and e-money institutions
Since 2020 at the latest, many customers of payment and e-money institutions (PSPs) have been concerned with one…
Commercial Agent Exemption | FinTech online course #6
After the last few articles dealt with the various payment services, this one focuses on an exception. Even…
Limited Network and Limited Range | FinTech online course #7
16In the context of payment services and e-money, many speak of Limited Networks and Limited Range. This refers…
BaFin Guidance Notice on planned reforms regarding managing directors pursuant to the KWG, ZAG and KAGB (part 1)
BaFin is currently working on updating its “guidance notice on managing directors pursuant to the KWG, ZAG and…
Finally: vouchers and prepaid cards are still considered payments in kind pursuant to the German Payment Services Supervision Act (ZAG)
Amendments applicable to vouchers and prepaid cards Last year, I reported on the conditions under which vouchers &…
“Lex Apple Pay” – let’s pretend we don’t have a clue… what exactly are technical infrastructure services?
Everyone has been talking about “Lex Apple Pay” ever since the Finance Committee provided its recommendation to include…
Factoring – What factoring licence should I apply for?
It is clear that anyone wishing to carry out factoring in Germany first needs a factoring licence. However,…
PayTechTalk 30: BaFin licence for payment institutions – this is how it works
Since the implementation of PSD2, or most likely even before, many companies have been preoccupied with one question:…
Prepaid cards: closed loop, open loop, restricted open loop or semi-closed loop?
If you talk to insiders from the payment industry about prepaid card systems, they inevitably use terms such…
Update re intra-group exemption
The German regulator BaFin lately issued a very narrow interpretation of the BaFin intra-group exemption. However, if group…
E-Loyalty: To be or not to be
E-Loyalty: Multi-partner bonus programs under review from a ZAG perspective Since 13 January 2018 the new payment services…
Technical Service Provider or Payment Initiation Service? Clues from BaFin’s guidance notice
On 29 November 2017, BaFin issued a new guidance notice on the new Payment Services Supervisory Act (“ZAG”)…
Group companies watch out! BaFin guidance note severely limits intra-group exemption
Only a few hours after the publication of the new BaFin guidance note on payment services, PayTechLaw…
Fasten your seatbelts – new BaFin guidance notice available regarding the German Payment Services Supervisory Act
On 29 November 2017 BaFin published the long-awaited updated guidance notice regarding the German Payment Services Supervisory Act…