Variation of Permissions

With few exceptions, where a particular shareholding changes in between 10% and 50%+ in increments of 10% ‘bands’ the buyer is required to submit a change of control section 178 notice after the Share Purchase Agreement (including change in control conditions) is agreed but before the purchase completes.

In some scenarios, such as acquiring more than 50% control, the buyer will need to provide a business plan, including how the business will be structured and managed and will also need to:

1. Services enabling cash to be placed on a payment account as well as all the operations required for operating a payment account
2. Services enabling cash withdrawals from a payment account as well as all the operations required for operating a payment account
3. Execution of payment transactions, including transfers of funds on a payment account with the user’s payment service provider or with another payment service provider:

   a. execution of direct debits, including one-off direct debits.
   b. execution of payment transactions through a payment card or a similar device.
   c. execution of credit transfers, including standing orders.

4. Execution of payment transactions where the funds are covered by a credit line for a payment service user:

   a. execution of direct debits, including one-off direct debits.
   b. execution of payment transactions through a payment card or a similar device.
   c. execution of credit transfers, including standing orders.

5. Issuing of payment instruments and acquiring of payment transactions
6. Money remittance
7. Payment initiation services
8. Account information services
9. Issuing electronic money

Permissions 1 to 4 relate to issuing payment accounts under a payment institution licence, although firms should be mindful of the limitations in the PSRs to the effect that payment institutions require a payment order before receiving, and to hold customer funds, including a near-future fulfilment date.

Permission 5 allows PSPs to issue card-based payment instruments, and permission 6 allows remittance without a payment account created in the name of the payer.

Permission 7 and 8 relate to payment initiation and account information service providers. Payment Initiation Service Provider(s) (PISP) assist customers in making direct payments to merchants and other service providers. Account Information Service Provider(s) (AISP) can collect information from customer accounts and display it back to the customer or their agents.

Permission 9, issuing electronic money, only applies to e-money firms, but e-money firms have all 9 permissions, plus some more. For instance, e-money firms can provide customers with an ‘account’ often called an ‘e-wallet’ to hold balances indefinitely, and without a payment order. From the consumers point of view, an e-wallet and debit card provided by an Authorised Electronic Money Institution is similar to a bank account, but the e-money firm can’t pay interest to the customer on their balance, or use the funds to earn interest themselves.

The content of the submission is similar to the requirements of your original licence application, but specific requirements depend on the permissions you are applying for. Usually you will need to provide: