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Harmonising Payments Insights to Progress on the European Payments Services Directive

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This report presents the results of an Accenture research study to understand bank preparations for the PSD in the EEA. The research was facilitated by the EBA (Euro Banking Association) who distributed the survey to their membership, and wasconducted on-line using facilities provided by Finextra. The survey objectives are to understand the current state of PSDreadiness and to allow banks to compare their progress against the market. The research was conducted during May 2009-

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Page 1: Accenture Payments Survey

Harmonising PaymentsInsights to Progress on the European Payments Services Directive

Page 2: Accenture Payments Survey

Foreword

payments; contactless cards are spreading rapidly, leading the way for mobile payments at point-of-sale; and new business models on the internet and mobile internet such as in games and social media are driving demand for real-time and micropayments solutions.

In the meantime, European banks are deep into their PSD programmes and are using this period to become compliant with the new legislation – they are analysing the impact of the PSD, and are planning and implementing changes to their payments contracts, procedures, processes, products and IT systems.

Accenture conducted this survey to get a snapshot of bank readiness for the PSD and for the new competitive landscape it enables.

Not just by banks who have a new opportunity to compete across borders, by expanding their reach and by developing new pan-European financial and payments products to acquire new customers, retain existing ones and create new revenue streams; but also by new entrants and non-banks such as telcos who have new opportunity to provide alternative payments services across all 30 EEA (European Economic Area) countries.

We seem to be in a quiet period, which is no doubt being subdued further by the financial and economic crisis. Nonetheless, there is plenty on the horizon to suggest that the European payments landscape is changing irreversibly and that competition enabled by regulation such as the PSD will drive new innovations – for example, mobile banking is on a clear path towards mass adoption opening the way for over-the-air mobile

The Payments Services Directive (PSD) is designed to open up the European payments market to competition, but, so far, few competitive shots have been fired.

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An opportunity to offer pan-European Payments

Banks believe that the PSD gives them opportunity to offer services across Europe, but few plan to acquire new customers in doing so. This implies their focus is on customer retention. However, customer retention may prove to be difficult in corporate banking if corporates rationalise banking relationships for payments across Europe.

Few new products will be launched on the back of the PSD in 2009 and 2010

PSD efforts are heavily focused on achieving compliance with only a few respondents planning new products this year and next. It will be interesting to see whether this also applies to the SEPA Direct Debit, which is also due to be implemented in November 2009.

New entrants are not perceived as a threat

Some respondents see new entrants as a serious threat, but most do not. Payments Institutions, soon to be allowed under the PSD, have yet to make an impact in the payments industry.

This report presents the results of an Accenture research study to understand bank preparations for the PSD in the EEA. The research was facilitated by the EBA (Euro Banking Association) who distributed the survey to their membership, and was conducted on-line using facilities provided by Finextra. The survey objectives are to understand the current state of PSD readiness and to allow banks to compare their progress against the market. The research was conducted during May 2009. The study’s key findings are as follows:

Banks are getting a clear idea of the PSD impact

All respondents have completed their impact assessments, and many have completed planning with implementation well underway. We can assume from this that banks have got to grips with PSD issues and know what needs to be done to become compliant.

Compliance programmes extend across the enterprise

The scope of PSD changes appear to be similar in size in retail and corporate banking, with less scope in card issuing and acquiring. In response, most respondents have set up holistic, enterprise-wide programmes to manage the work.

PSD compliance is as much a business as an IT initiative

IT changes account for about 30% of the scope of PSD programmes, with changes to terms and conditions (ts & cs) the next biggest component, followed by internal and external communication.

Not all banks will be fully compliant by November 2009

90% of respondents say they will be compliant by 1 November 2009, but work will continue past the implementation date, particularly to finish off IT and process changes.

PSD programmes are manageable in size

Respondents indicated their PSD budgets range from less than €1m to more than €20m, with an average of €4m. Even allowing for the diversity in size of responding institutions, this is a wide range. In the unlikely event some banks have overestimated or over engineered their PSD programmes, it is possible that instead some may have underestimated the effort required (with implications for their ability to be compliant by 1 November 2009).

Correspondent banking arrangements have still to be addressed

50% of respondents plan no change to their correspondent banking agreements. This does not seem viable given the originating bank requirements in the PSD, so it is likely that many banks have not decided yet how they will operate correspondent banking under the PSD.

Summary

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Background

level playing field for competition. The key rules which are being standardised concern, inter alia, value dating, fees, execution times, responsibility/liability and Payments Institutions (new non-bank, but “bank-lite”, entities which can hold and process payments).

Implementation of the PSD by the EEA countries is a parallel activity to the implementation of the Single Euro Payments Area, SEPA, by European banks. SEPA is a Banking industry, self-regulated initiative to standardise euro payment schemes and mechanisms (to replace national ones), and the PSD provides the common legal framework in which all payments, including these SEPA payments, can operate.

The PSD is due to be transposed into the national law of each EEA country by 1 November 2009, with the exception of Sweden which has delayed until 2010. The PSD impacts terms and conditions in customer contracts, products, processes, and IT systems and banks have a significant amount of

The PSD is an EU directive designed to establish a modern and harmonised legal framework for an integrated payments market in the 27 EU countries and in the additional three countries in the EEA. Its objectives are to enhance competition, improve consumer choice and promote greater efficiency. Currently, each national government has its own national payments regulations, for example rules on value dating payments, on direct debit guarantees, on access to payments systems. Unsurprisingly, these rules differ across the EEA, and banks and non-banks wishing to offer payments have to comply and configure their operations for each country where they operate.

This patchwork of regulations is inefficient, costly and a barrier to pan-European competition. The PSD provides one set of rules and regulations common across the EEA, thereby breaking down national barriers and creating a transparent and

business and IT change to implement in order to be compliant with the PSD.

The purpose of this survey is to enable banks to gauge their PSD compliance progress against others in the industry.

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24

10

54

2

Provide Pan Europeanpayment and bankingservices

Launch new products Reduce Cost Acquire newcorporate customers

Acquire newretail customers

What opportunities do you see with the PSD?Number of respondents for a particular category

Source: Accenture research

The “Calm before the Storm”?

An opportunity to offer pan-European Payments

24 of 29 respondents (82%) see the PSD as an opportunity to offer pan-European payments and banking, but only 4 (14%) believe it is an opportunity to acquire new corporate customers, and 2 (7%) believe it is an opportunity to acquire new retail customers.

This implies that we may not see many efforts to acquire retail or corporate customers across borders. However, it also implies that corporate customer retention will become a battle ground – if a corporate has, say, five banking relationships in five EEA countries, it could reduce those to one. If so, only one of the five banks will retain its customer, the other four will lose. Provision of new pan-European services will not be enough – differentiation is required to win, and banks which are planning new products and services have an advantage.

The purpose of the PSD is to harmonise legal conditions for payments across the EEA and to promote competition. We asked respondents for their view on the opportunities and threats from this competition:

What opportunities do you see with the PSD?

What is your view of Payments Institutions and new entrants encouraged by the PSD?

Only a small number of respondents see their PSD work as an opportunity to reduce cost. Although the work requires a comprehensive overhaul of processes, procedures and IT, its use as

Exhibit 1: The PSD provides an opportunity to offer Pan-European payments and banking

a catalyst to take out complexity and cost (e.g. through outsourcing) is a clearly not an objective in most cases.

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What is your view of Payments Institutions and new entrantsencouraged by the PSD?% of respondents within a particular category

Source: Accenture research

11%

8%

63%

18%

Marginal or nocompetitive threat

Opportunity to formstrategic partnerships

Serious competitivethreat

Opportunity to follow/acquire new entrants

An industry perspective

These survey results give the impression that the PSD’s goal to drive competition is a distant one. While the Banking industry may be gearing up to comply with the PSD, only a few banks are preparing to compete for new customers with new products, and fewer still see new entrants as a threat. This, perhaps, is to be expected given the natural inertia in the industry (current payments mechanisms after all work, and have worked efficiently and effectively for many years) and banks often prefer to be fast followers rather than leaders in innovation. Deep cost cutting initiatives in progress across the Banking industry do not help, making it difficult to invest in new products and capabilities in the current economic climate.

With the exception of credit cards in retail, and cash management and trade finance in corporate banking, historically, payments have not been a competitive battleground. Banks have competed on selling products such as current and savings accounts, mortgages, consumer and corporate loans, but they have not on payments – it is not easy to differentiate on cash, cheque, and electronic payments alone.

However, transaction banking has proved to be a sustainable and resilient business during the Banking crisis, and its growth over the past 5 years, its ability to generate liquidity and its low capital intensity make it an area worth competing in; but it is a volume and reach game favouring the large international banks. Therefore, for most banks, competing in payments means competing in value added services, and, in our view, value added payments services are best developed by bundling or embedding payments with something else.

For example, Paypal bundled with eBay has boosted both businesses considerably; payments bundled with cash management and treasury services is boosting revenues in corporate banks; micropayments embedded into online games are creating new revenue streams for games providers.

New technology (in devices, channels and software applications) is a key factor in value added services, as it provides the means to bundle and embed payments in other products and services. This is the battleground for payments, and non-banks will participate as well as banks, for they have the products and services that can

Few new products will be launched on the back of the PSD in 2009 and 2010

10 (34%) of respondents plan to launch new products; only a small number are aiming for 1 November 2009, some for the end of the year (also see Exhibit 8), and the remainder plan to do so in 2010 or later. In our experience, PSD programmes and SEPA Direct Debit projects are often separate streams of work in a bank, so we are unsure whether respondents considered SEPA DD as a new product in their responses – however, the SEPA DD is also due for implementation in November 09 and it will be interesting to see whether the same spread of intentions for launching new products applies to the SEPA DD.

New entrants are not perceived as a threat

Most respondents do not see new entrants as a threat. This implies that many banks see little evidence at the moment that Payments Institutions

Exhibit 2: Most do not see new entrants as a threat

be bundled with payments – e.g. telcos with location services for m-commerce, utilities with mass-billing services and smart meters, merchants with new business models, social media with a large customer base to monitise. The PSD makes it much easier for non-banks to run their own payments services, whether they do so with, or without, banks.

The increased competition enabled by the PSD may not yet be apparent; but there will come a point when it does. We might see signs of banks losing business as corporates rationalise relationships, or it might be the emergence of a new entrant such as a concerted drive by a telco to provide payments services, or it might be mass-adoption of new business models demanding new payments types.

The current period is like the calm experienced by mariners before an impending storm – while the timing and intensity of the storm are difficult to predict, the PSD is providing the conditions for major and irreversible change in both the nature of payments services and those who provide them.

permitted under the PSD will become a significant force in European payments. However, this view is not universal and 11% do see new entrants as a serious threat, and 26% see them as an opportunity to partner, acquire or follow.

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What is the status of your current PSD implementationplanning effort?% distribution of responses

Source: Accenture research

Not started

Impact AssessmentCompleted

Detailed AnalysisandPlanning Completed

ImplementationUnderway

Completed

28%

28%

0%

0%

44%

28% InitialPhases ofPreparation

0% finished

72% in detailedplanning andexecution

The State of Play (May 2009)

What is the state of your current PSD implementation planning effort?

What is the relative proportion of business scope of your PSD programme, within your institution?

What is the governance structure of your programme?

What is the relative proportion of effort within your PSD programme?

As of May 2009, there is less than 6 months to go before the PSD implementation on 1 November 2009. To achieve compliance by then, banks have a large volume of effort to identify the impact on their customers, products, business processes and IT systems and to plan and implement changes to them. At this stage, we would expect most banks to be making good progress, so, to take a snapshot of how the industry is actually getting on and tackling the compliance work, we asked:

Exhibit 3: PSD programmes are progressing well

Banks are getting a clear idea of the PSD impact

All respondents have completed impact assessments, and over 70% are in the detailed planning or execution phases. No one reported that they have completed their compliance activities.

The scope of the PSD work is determined by the impact assessment, and the schedule and approach to complete the work is determined by the planning work. From the responses, PSD compliance work appears to be progressing well across Europe, and most banks should have a good understanding of the impact of the PSD and of what is required to achieve compliance. At this stage there should be few unknowns in the process, although we know through our PSD client engagements that there are open issues in interpreting the PSD for the characteristics intrinsic in some local payments systems.

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What is the relative proportion of effort within your PSD programme?

High-> 15% of programme budget

Medium-Between 5-15% of the programme budget

Low- < 5% of the programme budget

Policies and Processes, 16%

CustomerCommunications, 15%

InternalCommunications,12%

Channels IT, 11%

Others , 9% Terms and Conditions, 19%

Back Office IT, 18%

Figure 1: Proportion of high, mediumand low level efforts in Compliance areas

Figure 2: Proportion of programmebudgets for each Compliance area.

Total programme budget: 100%

0

10

20

30

40

50

60

Terms andConditions

Channels Processesand Policies

Back OfficeIT

InternalCommunications

Others

Source: Accenture research

Compliance programmes extend across the enterprise

Compliance efforts are focused mainly on retail and corporate banking in equal measure, with much less focus on card acquiring and issuing (possibly reflecting the limited number of PSD articles which directly refer to cards).

With no single dominant or focal business unit, and with the impact spread across business units, it is not surprising that most banks (76% of respondents) have set up holistic, enterprise wide programmes for these compliance efforts, rather than separate business unit or geographic programmes.

Exhibit 4: The PSD scope is broadly the same in retail and corporate banking

Exhibit 5: Three quarters of PSD programmes are centrally directed

Exhibit 6: IT is the biggest overall component of PSD compliance effort

PSD compliance is as much a business as an IT initiative

Respondents have replied that changes to terms and conditions (ts&cs - 19%) and to back office IT (18%) are the two biggest components in a PSD programme. Overall, IT change (back office and channel) is about 29% of the effort, ts&cs, process and procedure changes 35% and communication (internal and external) 27%.

It is clear that PSD compliance is about both business and IT change, and that communication, both internally with employees, and externally with customers is also a large component.

What is the relative proportion of business scope of yourPSD programme, within your institution?average % proportion in each category

43%

39%

10%8%

Retail Banking Corporate Banking Card Issuing Merchant acquiring

Source: Accenture research

What is the governance structure for your programme?% distribution of responses

Source: Accenture research

Centrally Directed,enterprise wideprogramme

Centrally directedenterprise wideprogramme withCountry-specificprojects

Country-specificprojects

Separate businessunit projects

21%

3%

59%

17%

76%IntegratedApproach

24%FederalApproach

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A programme management view

Accenture works with banks across Europe on PSD programmes, and in our experience the initial impact assessment is a very diverse exercise across the enterprise, requiring participation from a large number of stakeholders.

Typically, the first step is to identify which products are in scope and which are not in scope, then a central team works with the product owners in the different business units, and with operations and IT owners to identify the different impacts. Such is the breadth of change and checking required, that no-one person is likely to have sufficient knowledge of the business to define all these impacts. Consequently, a PSD programme is an enterprise-wide programme requiring extensive cooperation and coordination – it is not a single project, nor is it simply a risk or a legal exercise, but a large number of parallel business, IT and operations projects.

This diversity in the impact assessment flows through to the planning – as well as multiple projects, there is no single critical path but multiple critical paths, and many dependencies between them. This can be difficult to manage, but it does mean that many activities can be done in parallel, both in planning and in implementation, and across businesses and geographies.

The two biggest areas of scope identified in the survey, IT and ts&cs reflect our experience of PSD client engagements. Both of these areas are time critical, whereas communication, internal and external, is less so. IT is time critical because there are some large IT changes driven by the PSD requirement for immediate availability of funds when received. This is a real-time processing requirement that is particularly difficult to implement where payments and accounting systems operate as batch processes (typically overnight), as is often the case in many banks.

Ts & cs are time critical due to the volume of changes required and to the turnaround time to get corporates to sign up to them. In our experience, ts &cs for corporates may not always exist, or may be decades old and not reflect additional terms agreed

with relationship managers over the years. The PSD is proving to be a good opportunity to clean up and standardise ts & cs, but it is proving to be a time consuming one.

The approach to external communications requires careful consideration. It is less time-critical than other areas, but it is dependent on the ts &cs activities. Some banks are getting legal advice to send their customers separate communication letters specific to PSD changes, and not include them with regular communication such as with bank statements – for high volume retail businesses this is expensive, and can cost €200k – €300k for every 1m letters sent out. If banks do not have a single view of the customer, then a separate letter for each product a customer uses is required, increasing costs further.

The PSD work for many banks has entered the implementation phase. From our experience with other regulatory compliance programmes such as MiFID (Markets in Financial Instruments Directive, another regulatory harmonisation directive that became effective on 1 November 2007), as implementation progresses, the focus will soon turn to preparing for the implementation date itself. Testing and training will become important activities for this – testing to check the end-to-end process and IT changes work, and training to train all impacted employees in a consistent way and to track training completeness to show the bank has met its compliance obligations. Customer communication is also a critical activity in this phase. Key factors for effective communication programmes are the clearness of the messages, the level of detail for different customer types and the optimum time to send out communications (not too early nor too close to 1 November).

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What is your approach to PSD compliance?% of Responses

Source: Accenture research

Confidence to achievefull compliance byPSD book byNovember 1, 2009

Making risk baseddecisions to becomemostly compliant byNovember 1, 2009

Would only becompliant in certainproducts/businessareas by November 1,2009

No confidence inachieving thecompliance byNovember 1, 2009

7%

0%

72%

21%

The Road to Compliance

We also asked “What is your intent/preference for correspondent banking in Europe?” to get an idea on how banks are addressing correspondent banking under the PSD. The PSD places accountability for the end-to-end execution time of a payment and for fee arrangements on the originating bank – thus in corresponding banking, where originating banks typically are accountable only for sending payments on the first leg of their journey in the network, under the PSD they are accountable for the end-to-end journey with significant implications for how correspondent banking operates in the EEA.

With change pervasive across the enterprise, the goal of compliance by November 2009 is a challenge, even for the well prepared and well resourced institutions – bringing together all the business and IT streams of work to a successful conclusion is a complex exercise. It is inevitable that some work will carry on past the 1 November effective date, to tidy up loose ends, complete non-critical tasks and to set up new products and services.

To get an idea of how big this challenge is, and how confident banks are of achieving compliance on time, we asked:

What is your approach to compliance?

What are your completion expectations?

How much are you budgeting for your PSD programmes.

Not all banks will be fully compliant by November 2009

Although 90% of respondents say they will be legally compliant by 1 November, only 72% are confident they will be fully compliant by then, while 21% say they are taking risk based decisions on compliance. Interestingly, the Swedish respondents (whose regulator has said the PSD will be implemented in 2010 after the rest of the EEA) expect to be compliant by November this year.

We may infer from this that there is high confidence to complete ts&cs changes by 1 November 2009, but that confidence is less high for delivering all the process and IT changes needed to support these ts&cs by the same date.

Some banks (21%) are exercising judgement to be compliant in critical but not all areas by 1 November, and work will continue past 1 November 2009. In our experience, these judgements are needed not only for interpretation of the PSD for specific local requirements e.g. collection products in Italy, which may need

Exhibit 7: Compliance will not be uniform by 1 November 2009

clarification with the local regulator, but also for complex IT changes which may require compromises in how they are implemented (e.g. where real time processing is required in batch processing).

Although no institution will want to be the first to request dispensation from

their regulator for some leeway on the implementation date for all compliance aspects, it is clear that regulatory authorities will need to be realistic that not all banks will be fully compliant on time. They will need to give guidance on what non-compliance is acceptable and for how long, and to start planning now to develop this guidance.

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How much are you budgeting for your PSD programmes?% of respondents within a particular category

Source: Accenture research

31%

48%

10%

7%4%

< €1m € 1-5 m € 5-10m €10-20m >€ 20m

The average PSD programme is budget at around € 4m

Efforts going on past 1 November 2009 will be work to complete process and product changes, and to launch new products. Temporary fixes may be required e.g. temporarily not charging correspondent banking fees, until compliant processes and products are in place. Additionally it is likely that work to complete and implement corporate opt-out agreements will continue past 1 November 2009. Under the PSD, banks can agree opt-outs with corporates e.g. on non-mandatory information requirements. While opt-outs can be agreed and documented in ts &cs before 1 November 2009, the IT and process changes to implement them may follow later. It is also likely that corporate opt-outs may take time to stabilise once both banks and corporates experience them in practice.

Exhibit 8: Legal compliance is achievable without completing all work by 1 November 2009

Exhibit 9: the average PSD programme is budgeted at around €4m

PSD programmes are manageable in size

31% of respondents said their PSD budget is less than €1m, and 48% indicated between €1m and €5m. Some budgets are much larger, with 21% greater than €5m, with one estimating the effort at greater than €20m. The average of the responses is €4m.

The wide range of the responses is not surprising given the spread of banks who responded, ranging from small domestic banks to large global banks. However, given 66% of respondents describe themselves as global or multi-country banks, and given the enterprise-wide nature of the work required, the €4m average budget seems low.

It is possible that banks are executing PSD work under “business-as-usual” business unit budgets, and that mainly centralised budgets for central coordination and centralised changes e.g. in IT, have been included in the survey results. It is also possible that banks have underestimated the work

required, but the survey does not provide evidence for this, and with 72% having completed planning (and quantification of the work), they should have a good grasp of the budgets they need. The impression from the survey overall is that banks have PSD work under control, and

the size of programmes reported are manageable, even for banks which may have delayed starting work until this year.

25

2017

4

17

21

36

1

6

36 6 6

26

1

9

14

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Not planned Later than 2010 During 2010By December 31, 2009 By November 1, 2009

1

What are your completion expectation?% distribution of responses in each category

LegallyCompliant

CustomerCommunicationstartted

All process changescomplete

All product changescomplete

New products launched

All IT changes completed

Source: Accenture research

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Correspondent banking arrangements have still to be addressed

Only about half respondents plan to renegotiate correspondent banking agreements, and only about a third of these will negotiate collective agreements (common agreements with a number of banks), with no discernable pattern by geography. This may indicate that many banks have not yet decided how to approach correspondent banking, as the “do nothing” option does not seem sustainable given the shift of obligations (charges and reach) onto the originating bank. It also suggests that banks may be finding it easier to negotiate new individual agreements than collective ones.

Exhibit 10: Many banks are planning no change to their correspondent banking arrangements

With sending banks responsible for end - to - end paymentsprocesses, existing correspondent agreements between banksmay not be sufficient under the PSD. What is your preference/intent for correspondent banking in Europe?% of respondents within a particular category

Source: Accenture research

Negotiate new individual agreementswith other banks

Negotiate newcollective agreementswith other banks

Exit correspondentbanking

Leave existingagreements in place

Not a correspondentbank

3%

49%

3%

28%

17%

48%Changedarrangements

52% NoChange

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Conclusion

The survey indicates that preparations in the European Banking industry for PSD compliance are underway and under control. Approaches to compliance are pragmatic, with enterprise-wide governance tending to be in favour to deal with the holistic and pervasive nature of the changes

However, work is being scheduled to continue after the 1 November 2009 implementation date, and although banks are working hard to be compliant on time, it is unlikely that all banks in all 30 EEA countries will be fully compliant by November 2009. In practice, this means that contractual agreements and their ts & cs are likely to be in place, but not all the IT and operational changes will necessarily be so. Given the fixed schedule and pervasive scope of PSD changes, this is unsurprising.

Even with augmented resources, on-time delivery of the IT solution for a PSD requirement may not always be feasible. In this case, the business, legal and IT Teams will have to work together to prioritise scope and define operational workarounds to bridge the gap between the 1 November regulatory deadline and the full implementation of a particular requirement solution.

Where delivery of a PSD requirement solution remains feasible but at risk, Banks will need scenario planning for the eventuality that compliance is not delivered in some areas on 1 November. These plans must be accompanied by a clear date and process by which the plan is invoked, and regulators will need to be prepared for such an eventuality.

There is a wide range of estimates for PSD programme budgets – without knowledge of the underlying detail it is difficult to draw conclusions from this. One hypothesis could be that some banks have underestimated the effort required – it would not be the first time that large programmes with significant IT components have been underestimated. Another could be that budgets for PSD work are decentralised and buried in business-as–usual activities. Time will tell over the coming months.

At this stage, the focus is more on compliance than on competitive positioning – the impact of the PSD on the competitive landscape will be a story for 2010.

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Multi-CountryBanks

3%

3%

28%

38%

28%

Savings Banks

Domestic Banks

Global Banks

Other Banks

29

Slovenia

Total

8UK

2Sweden

1Spain

1Austria

2Netherlands

1Latvia

1Italy

2Ireland

4Germany

1Luxembourg

1Slovenia

2Denmark

3Belgium

OrganizationsCountryWhat best describes your institution?

Source: Accenture research

Methodology

The survey was conducted on-line over a three week period in May 2009. The EBA invited its membership to participate, Finextra provided the on-line survey facilities and provided the results in anonymous form (institution names removed) to Accenture for analysis and insight. 29 separate institutions responded to the survey. Although there are around 7,000 banks in Europe, only around 90 of these are significantly sized, and of these, 19 responded to the survey.

Exhibit 11: 29 institutions from 13 countries participated

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Copyright © 2009 Accenture.All rights reserved.

Accenture, its logo, andHigh Performance Deliveredare trademarks of Accenture.

About Accenture

Accenture is a global management consulting, technology services and outsourcing company. Combining unparalleled experience, comprehensive capabilities across all industries and business functions, and extensive research on the world’s most successful companies, Accenture collaborates with clients to help them become high-performance businesses and governments. With more than 181,000 people serving clients in over 120 countries, the company generated net revenues of US$23.39 billion for the fiscal year ended Aug. 31, 2008. Its home page is www.accenture.co.

To discuss this survey or to find out more about how Accenture can help you with your PSD efforts please contact:

Jeremy LightGlobal Banking Industry [email protected]

Zbigniew SedzimirBanking Practice, [email protected]