1 Executive Summary
1.1 The Payments Services Directive 2
The Payments Services Directive “PSD” came into effect on 1st November 2009 under the regulatory authority of the Financial Services Authority “FSA”. The FSA was replaced by the Financial Conduct Authority “FCA” on 1st April 2013 who are now the regulators overseeing financial service organisations.
All firms providing payment services by way of business must now become authorised under Payment Service Directives 2 (PSD2) and observe regulations pursuant to EBA guidelines and PSRs.
This is an example to be used as a template, we are not an SPI authorised by the FCA
Hirett Ltd trading as Hirett (hereafter also referred to as ‘the Company’, ‘We’, ‘Us’, ‘Hirett Ltd’, ‘the firm’) seeks to operate as a Small Payment Institution as of 01.03.2018. Once registered as an SPI, Hirett Ltd will follow the required principles set out by the FCA under the Payment Service Regulations 2017. Our permitted activity will be as a Money Remitter. We are undergoing registration by the HMRC for MLR purposes.
1.2 The Company
Hirett Ltd has been initially formed in October 2015 to act as a Payment Institution. The vision of our Company is to provide a personalised service to UK individuals to remit money to Africa via an online portal. Our core market is to have a dedicated portfolio of direct clients who instruct our services for FX (foreign exchange) and remittance services.
Our primary objective is to provide transparent and customer focused payments remittance advice to clients. The Company shall operate as a private limited company.
1.3 Our Core Activities
Registered Activities Table
1.4 Role of this Manual
This manual sets out the manner in which we will run and control our business. The manual has been prepared by the management and represents a commitment to maintaining, and constantly striving to improve the way in which we will offer our services to our clients.
Our objectives are:
- To manage Hirett Ltd in a controlled and transparent manner
- To present Hirett Ltd services, in a clear and transparent manner to our target
- To ensure that employees demonstrate an appropriate level of competence in the services we offer
- To periodically assess and record the standards of knowledge and competence of our employees for their own personal development and for the benefit of our clients
- To address any complaints in a timely manner and to monitor any such complaints with a view to implementing corrective and preventive actions in our procedures
- Develop a relationship with the FCA to inform them of any appropriate changes to Hirett Ltd or any of its activities and provide required information through FCA Reporting (ie Gabriel reporting)
- To develop, maintain and monitor a strategy to ensure and monitor that our customers are Treated Fairly
1.5 Our Classification, Service and Customer Group
- As a Money remitter, Hirett Ltd aims to fulfil the FCA’s requirements as a “Small Payments Institution” based on the following criteria:
- Our monthly average payment transactions will not exceed 3 million euro’s
- The individuals involved with the business have never been convicted of offences relating to money laundering, terrorist financing or any other financial crimes – they are ‘fit and proper’
- The business and head office is based in the UK
- Mind and control is via the firm’s Management
In short, we offer our services as a Payments Institute to transact overseas money remittance, offer wholesale FX services to regulated and licensed firms and manage direct client relations.
1.6 Our Customer Group
Our clients are:
- Private clients
- SME companies
2. Compliance Monitoring Programme
3. Anti Money Laundering Policy
4. Complaints Policy
5. Business Process
The FCA require Payment Institutions to provide annual reports. For SPI’s the following information is required:
- the number and value of payment transactions
- number of agents
- safeguarding arrangements, where relevant
Firms will be sent a reminder one month before the report is due. They will be required to submit the report electronically via the FCA system. A fee of £250 is levied by the FCA for late non returns.
7 ID and Payment Matrix
8 Acceptable IDs
9 Customer Data and Security Policy