JBA submitted an opinion paper on the “Draft Cabinet Order, Draft Cabinet Office Ordinance, etc. for the Enforcement of the Payment Services Act” to the Financial Services Agency on January 8.
The main points are the following:
- The draft stipulates a cap on the “transaction amount per trade” (1 million yen) that a funds transfer operator may conduct as an exchange trading in small amounts. However, we think that the Act should also establish a cap on the “amount of funds tradable in one day” pursuant to the purpose of the regulations of this Act.
- We would like the Act to clarify the scope of banks’ responsibilities when they are entrusted with remittance operations by funds transfer operators.