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EPA Response to the FCA’s CP21/13 – ‘A New Consumer Duty’

This paper sets out the Emerging Payment Association’s response to the FCA’s Consultation Paper, “A New Consumer Duty”. We welcome the FCA’s focus on consumer protection and the broad objectives behind the CP. However, we have comments on the application of certain aspects of the proposed framework to firms that provide payment services and/or issue e-money. We fear that, despite the good intention of protecting consumers, this proposition will create extra burdens on firms, providing extra costs and another layer of administration which will inevitably exclude smaller players and will create an extra barrier to market entry, resulting in the consolidation of bigger players alone and harming broader competition. We urge the FCA to consider excluding all payment that are not retail consumer-facing.