Singapore – MAS Consults On New Payments Framework And National Payments Council.

Activity 

What is Regulated 

Some additional

points MAS is consulting on 

Activity 1:

Issuing and maintaining payment instruments, such as payment cards, payment accounts, electronic wallets, and cheques 

Payment instruments would include instruments that provide a user access to regulated funding sources (e.g. deposit/ checking accounts / SVFs) for the purposes of initiating payments.

Examples would include credit cards, debit cards, stored value cards, payment and interest banking portals, apps, 

The following products will be excluded:

1. Payment instruments would exclude cash and anonymous instruments, e.g. virtual currencies like Bitcoins.

2. Deposit accounts / credit facilities linked to 

Whether internet banking portals should be considered a payment account and therefore a payment instrument. 

Activity 2:

Acquiring payment transactions, such as physical and online merchant acquisition services, merchant aggregators, and master merchants 

Accepting and processing payment instruments through a payment system, including merchant acquirers (banks and three party scheme operators, merchant aggregators and master merchants). 

Will not apply to businesses, e.g. shops, restaurants and travel agents which use the merchant acquirer or gateway to accept payment instruments from their customers. 

1. Whether Activity 2 should include all participants of payment systems that acquire payment transactions or only direct participants.

2. Whether there are non-payments businesses that may inadvertently be regulated under the scope of payment acquisition. 

Activity 3:

Providing money transmission and conversion services, such as domestic and in- bound/out-bound cross-border remittance services, currency- conversion services, and virtual currency intermediation services 

The following money services would be a regulated payment activity:

1. The activities of money transmission and currency conversion, without an underlying exchange of goods and services;

2. The facilitation of, and operation of platforms that facilitate, money transmission and currency conversion.
The current money changing and remittance activities (possibly including the exchange of virtual currencies) will be subsumed under this Activity.

This will apply to the acceptance of funds and subsequent transfer of value to a beneficiary by an entity in Singapore, regardless of whether the originator or beneficiary is in Singapore (and will apply to both physical and online activities). 

Will not apply to:

1. Payments purely for goods and services;

2. Businesses that accept payment instruments from customers on their own behalf, e.g. shops, restaurants and travel agents; and

3. Intragroup payments by multi-national corporates to offices in other countries. 

Whether there are any other businesses that may fall unintentionally under this Activity 3. 

Activity 4:

Operating payments communication platforms, such as payment gateways, payment processors, and kiosks 

This activity pertains to the processing of payment instructions, and will include authorisation of payment instructions for both e-commerce and physical merchants, e.g. payment gateways, payment kiosk operators and payment processors which intermediate between merchants and acquirers. 

Will not include manufacturers of payment terminals and software developers of payment gateways and processors if they do not operate the terminals or software for the merchants and/or acquirers 

1. Whether inter-bank (domestic and international) payments messaging platforms should be subject to licensing and supervision.

2. Whether the list of potential licensees and exclusions is comprehensive. 

Activity 5:

Providing payment instrument aggregation services, such as payment card aggregation and bank transaction account aggregation 

The provision of any service which aggregates payment instrument information from various issuers of payment instruments, and allows users to initiate payment instructions, e.g. services which allow users to access multiple bank accounts and payment cards through a single portal, app, or device. 

N/A 

1. Whether this should include mobile wallets which store users' payment card information.

2. Whether the list of potential licensees and exclusions is comprehensive. 

Activity 6:

Operating payment systems which facilitate the transfer of funds through processing, switching, clearing, and/or settlement of payment transactions 

The operation of a payment system which facilitates the transfer of funds through processing, switching, clearing, and/or settlement of payment transactions (e.g. operators of the automated clearing house, domestic and international schemes and/or payment switches, and ATM switches).

Licensed payment systems that pose systemic or system-wide risk to Singapore's financial system will be subject to designation requirements similar to those currently in place under the PSOA. Certain aspects of governance could come under the National Payments Council (see proposals below). 

Intra-bank payment systems or internal corporate payment systems 

1. Whether to regulate:

a. settlement institutions; and

b. operators of international interbank payment and messaging systems.

2. Whether the list of potential licensees and exclusions is comprehensive. 

Activity 7:

Holding SVFs, such as prepaid cards and prefunded electronic wallets 

The holding of all SVFs (which encompasses the holding of funds on behalf of users whether they are used as a funding source for payment instruments or not), regardless of whether they hold S$30m of customer funds or not. This will include:

1. All holders of network- 

Mobile wallets (with store tokenised card details) may be regulated under Activity 5 instead. 

1. Whether all SVFs will have to segregate customers’ funds, regardless of whether the customers are Singapore residents, from operating accounts and safeguard customers’ funds, via mechanisms such as full bank liability,