Representation in proceedings before the FSC to obtain SPI status
The client’s intention was to expand the catalogue of provided services by granting payment credit and issuing credit cards. Our cooperation began with an analysis of the planned business model and determining the preferred model of provision and scope of services.
Together with the client, we determined the scope of payment services that it intends to provide, in order to properly qualify them for the relevant types of payment services defined in the Payment Services Act.
Based on the arrangements with the client, we prepared an application for entry in the register of small payment institutions (SPI).
An element of the application is always a description of the services and graphical diagrams covering the flow of information and funds between the payer and the payee, which we prepare and develop.
Our support for the client also consisted of preparing internal documentation for the payment institution and representing the client in responding to the so-called sector letter sent by the Polish Financial Supervision Authority (KNF) together with the notification of entry into the register of small payment institutions.
In response to the sector letter, the internal procedures of the payment institution , and a number of statements required by the FSA must be submitted to the FSA.
The response to the sector letter is an integral part of the proceedings before the FSA for entry in the register of payment institutions. Failure to respond would result in the deletion of the newly entered entity from the register of small payment institutions.
When conducting proceedings before the FSA, we take care of every detail of the process, not limiting ourselves to merely submitting an application for entry in the register of small payment institutions, but comprehensively preparing the Client for the provision of payment services
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For our client, during regular legal advice, we developed documentation for an anti-money laundering and counter-terrorist financing system (hereinafter “AML/TF system”, maximum penalty for violating those laws may result in financial penalty up to 5 million EUR).
As part of our ongoing cooperation with a client, a small payment institution, providing payment services including issuing of credit cards and providing payment credit to consumers, we represent the client in the proceedings for obtaining a license to provide payment services as a national payment institution.