Bank Mobility Law : Macron is not yet ready…
Three weeks ago, the Macron law on banking mobility came into force. Banks offering this service are encountering numerous operational difficulties. Some institutions have not fully initiated the compliance work. Market practices are not yet clearly defined…
The changes brought about by the reform on banking mobility
The new regulatory framework for banking mobility, which took effect on 6 February, is a free service for individuals. This legal framework obliges the new bank, when signing a mobility mandate, to ensure the transfer of direct debits relating to recurrent transfers and direct debits. In order to obtain the list of transactions, this “new bank” contacts the old bank, which is obliged to respond. The change of direct debit is carried out within a maximum of 22 working days from receipt of the mobility mandate signed by the customer.
The aim of this reform is to increase the mobility of bank customers and to bring them closer to European standards (in 2014, 4.5% of French people changed banks compared to 10% of Europeans) by considerably simplifying the procedures for customers.
The situation three weeks after the entry into force
Operationally, financial institutions rely on standardised and automated exchanges. These are carried out via a messaging system dedicated to banking mobility: AigueMarine from SEPAmail.
More than fifty small and medium-sized banks are still not connected to SEPAmail’s Aigue-Marine messaging system. This situation prevents them from issuing and receiving banking mobility requests. This delay in implementation is detrimental to all banks because of their intrinsic interdependence on this new system.
Moreover, the banks offering this service are encountering numerous difficulties, particularly with regard to compliance with the required message formats and regulatory deadlines.
Indeed, the messages exchanged very frequently contain information that is not filled in or does not comply (e.g. data exceeding the authorised size limit). With regard to deadlines, several banks do not respond within the time limits set by law, particularly when they are in the initial bank position. In such a case, the bank mobility mandate is considered by some financial institutions (in the “receiving bank” position) as expired. As a result, they ask the customer to sign a new mandate in the hope that the bank of departure will be more reactive. Several online banking players find themselves in this situation and it negatively impacts their customer relationships.
Market practices are not yet clearly defined
Moreover, market practices are not yet clearly defined (e.g. conditions for rejecting a file). The CFONB should soon formalise more precise operational rules.
As regards the sales and marketing policies of financial institutions with regard to this new system, they aim either to win new customers or to reduce attrition. To this end, several players are offering money for each effective mobility. The most offensive ones would force the instructions of the customers by asking for the closing of the mobile account at the departure institution. As for the banks with a defensive position, the most aggressive ones would rely on a voluntary slowing down, or even a halt, of the process of changing direct debit. In practice, they would invoke unfounded reasons for refusal and would voluntarily set a longer deadline for responding. Some would inform their customers that the mobility mechanism is not sufficiently secure.
In the early days of this law, online banks, particularly Boursorama, are the big winners. However, they remain dependent on other establishments respecting the deadlines and message formats in order to effectively implement their mobility requests…
The current challenges
For banks that have not fully initiated their compliance with the law, the major challenges are as follows
- Choosing the method of processing requests (automatic or manual). This choice depends in particular on the estimated volume and the aversion to operational risk
- Selection of a mobility solution (Docapost, Isilis, Wordline, etc.)
- Establishment of the operational and organisational model involving the network, the back office, legal affairs, marketing, payment methods and IT. We must try to take advantage of this new provision by planning targeted marketing actions
- Joining SEPAmail’s Aigue-Marine messaging service
- Operational implementation
For the banks connected to the AigueMarine messaging system, the main challenges are to correct their malfunctions, to report the identified anomalies of third party banks and to be flexible in terms of deadlines during these first weeks. In addition, an adjustment of marketing and sales policies is to be considered concerning :
- Customer communications related to this scheme (e.g. limiting advertising, communication on operational difficulties)
- Actions to limit attrition
Continue reading the Ailancy Conviction Note by clicking HERE
Macron Law – Etienne Jaouen in Capital n°309 – June 2017
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Find Etienne JAOUEN, Manager at Ailancy in the latest issue of Capital – June 2017 (n°309) in a special report on banks with a complete subject on the “mobility mandates” created by the Macron law. Extract : Only twenty-two working days; this is, on paper, the maximum time l
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