The Operation of the Interchange Standards: Conclusions Paper 10. Other Issues Raised in Consultation

Stakeholders raised a number of other issues in the consultation that did not directly relate to one of the eight proposals. These are discussed and addressed below.

Status of previous guidance

Some stakeholders requested clarification on the status of the guidance previously provided by the Bank in relation to the current Standards. For the avoidance of doubt, once the Standards are varied, previously issued guidance will no longer be current and therefore cannot be relied upon.

The independence of compliance certifications

In response to the draft variations, one entity sought clarification on the reporting obligations of schemes in relation to the net compensation clause of the Standards. Specifically, it noted that the proposed clause 7.3 (which relates to transitional arrangements), could potentially be read as requiring a scheme to certify to an issuer's compliance with the Standard, rather than its own compliance with the Standard. This ambiguity has been addressed. The wording of clause 7.3 has been amended to specifically refer to an Administrator of Scheme providing certification of its own compliance.

Verification of certification when an issuer and a scheme come to materially different compliance positions

A small number of entities queried what the Bank's course of action would be if a scheme and an issuer came to a materially different net compensation compliance position in relation to the same issuing agreement. For example, where one entity certifies compliance in relation to the agreement, but the other reports a breach. In this situation, the Bank would, in the first instance, follow up with both parties to investigate the matter more fully.