New Payment System Operator (“NPSO”), the organisation charged with delivering the UK’s New Payments Architecture (“NPA”) and the “End User Needs” services dependent upon it, seems to be backing away from its sense of responsibility towards “Confirmation of Payee”, or “CoP” for short.
The CoP service is where a payer confirms that the payee they already stated in their payment order is the payee that should receive the money and not someone else entirely.
Leaving aside firstly the nonsense as to why the payer has to repeat part of their payment order and secondly the fact that CoP is a sticking plaster over an entrenched vulnerability within the Faster Payments system, CoP has been a core part of all the project stages since 2014 that led to NPSO’s creation, and has been endorsed by NPSO executives multiple times along the way, albeit wearing a series of hats as the project progressed.
NPSO’s stance bears out an intrinsic flaw in the “layered market model” of which NPA is an example: market actors can point at one another, in the same layer, or in other layers, to shift responsibility for failure. They can CoP-out of commitments which, if not explicitly made, were strongly inferred and – most important – were accepted by others as commitments.
CoP has been sold by the Payment Systems Regulator (“PSR”) to the Treasury Select Committee as a 2018 deliverable to solve Authorised Push Payment fraud (“APP fraud”). It is therefore unacceptable that NPSO take any other stance than that they must deliver it, soon, and as written.
This imperative is belied by the NPSO Board Meeting of 6th June 2017. It is recorded in the minutes under para 135, “End-User Council Report”, that the Board first noted the summary report and the minutes of the 16th May meeting of their End-User Advisory Council.
On CoP, Matthew Hunt – NPSO’s COO–then went on to say that the manner in which this regulatory initiative interacted with another regulatory initiative – called “the liability model” – was the root cause of some of the complexity around CoP. Then a portion was redacted on the grounds of commercial sensitivity. Finally there is a bald statement that “The Board agreed that a way forward was required but that it was not NPSO’s responsibility to come up with the solution, it could only create the standard on which the industry would build”.
It is unacceptable that NPSO should term CoP a “regulatory” initiative. This is the first element in the CoP-out. CoP was born and lived for 3 years as a commercial initiative and has only become “regulatory” since November 2017 when the PSR quoted CoP as one of “their” initiatives onAPP fraud, in apparent desperation to dredge up some credible response to the Which? super-complaint on this subject and to demonstrate that they had not been asleep at the switch.
Which? lodged their super-complaint in September 2016. The PSR’s first emission of substance came under a press release of 16th December 2016 which was misleadingly entitled “PSR kick-starts industry-wide effort to tackle payment scams”, as if the PSR had taken the first initiative. The PSR laid out a programme of proposed work and then reported on it 11 months later. An action plan of 11 points was set out in a chart on p5 of its report published under a press release of 7th November 2017. CoP featured as one of the “Prevention” measures and was labelled as “Starting 2018”.
The presentation of this list of actions inferred that they were both new actions and had been framed as a direct response to the Which? super-complaint. In fact, the 11 actions were a compendium of pre-existing work undertaken for a variety of reasons, with just one or two actions specific to this topic. 6 out of the 11 streams – including CoP – had already been underway for some time within the Payment Strategy Forum (“PSF”) and were not directly triggered by the super-complaint. The PSR behaved much like Valerie Singleton when cooking for “Blue Peter”: “Here’s one I made earlier” and then “Here’s another one I made earlier”, followed by another and another.
One wonders whether the PSR seriously believed and believes that CoP will be “Starting 2018”. On 23rd January 2018 Hannah Nixon of the PSR gave oral evidence to the Treasury Select Committee in answer to Qu 35 from John Mann: “When will confirmation of payee be brought in?”.
The answer was: “The standards are being worked up as we speak. They should be in place by mid-year. We want to see banks starting to use that functionality later this year”, and John Mann said: “Later this year we should expect to see it and you will be taking action if that has not happened”.
Hannah Nixon’s statement would surely be taken by the committee members as meaning CoP would be in production in 2018, and yet this does not square with CoP being an “overlay service” on the back of NPA, as Hannah Nixon must have known: the PSF was the PSR’s creature and the PSF drafted NPA with this interdependency. NPA is a multi-year project and will probably not exist in stable production before 2021, only after which the “overlay services” like CoP can come into being.
The CoP timeline fits with this relationship between CoP and NPA.
NPSO has only just issued a “call for industry views” on the initial CoP logical Application Programming Interface specification. Note “initial”, not “final”, and “logical”, not “technical”. This is an early specification of the business model using Universal Modelling Language, one of the steps on the way to producing a final, technical specification in ISO20022 XML and a service rulebook.
It can take a year from this stage for the final technical specification and rulebook to be signed off, if we are only now looking at an initial logical specification. In fact, a year would be quick, given previous experience in the Eurozone (on the Single Euro Payments Area project) which used the same methodology. Then the results have to go through development, testing, implementation, conversion, roll-out and post-conversion support at many market actors before the new service can be said to exist “in stable production”. In this case testing involving multiple market actors must be on the agenda, and not just testing by individual market actors within a closed testing environment.
To roll CoP out comprehensively across the universe of the UK’s 1,400+ payment service providers (including credit unions and Open Banking intermediaries), we have to be considering a 3-year timeline from the point when the specifications are finalised, which would fit in with its being an “overlay service” on the back of NPA. Roll-out would then be in 2022.
So we are a ways away from having a service specification, and we are years away from being in production.
But it isn’t even this good: we are a ways away from having certainty that the service is even feasible from a legal and regulatory point of view.
The NPSO Board Minutes of 2nd May 2018 against point 97 contained a laundry list of issues of a legal/regulatory nature that stand in the way of CoP: “disclosure of personal data, fraud, PSD2, privacy and consumer protection”.
After 4 years of work on CoP, then, we do not know if the service is even feasible.
“…and it’s not our fault”, seems to be NPSO’s stance.
This does not hold water. CoP was conceived as part of the World Class Payments project run by Payments UK in 2014/15. There is a graphic on p10-11 of the project’s Initial Report and CoP appears on it.
The Programme Director of World Class Payments project was a Mr Timothy Yudin, who is now “NPA Lead” at NPSO. P19 of the project’s Initial Report states, “We would like to thank all the following organisations for their invaluable input” and quotes Nationwide Building Society, where NPSO’s current CEO Paul Horlock was Head of Payments, the role he occupied then and while he was member of the Payment Strategy Forum, until he switched over to NPSO in October 2017.
Mr Yudin kept the CoP flame alive during Payment Strategy Forum Phase 1 “Strategy Setting”, as a member of the “End User Needs WG”. CoP appears as one of the recommendations of this WG on p15 in the draft strategy of July 2016 (under the name of “Assurance Data”), and it appears on p32-33 of final strategy of November 2016 (named this time as “Assurance Data/Confirmation of Payee aspect”).
Under Payment Strategy Forum Phase 2 “Design and Implementation”, CoP was allocated into the “NPA Development Hub” stream, co-chaired by Paul Horlock, who was co-signatory of the NPA Project Initiation Document of May 2017. Point 3.2 on p8 makes the NPA project unequivocally responsible for the development of the rules and standards for CoP, up to and including transition but not after it.
The paper trail is completed by point 2.3 p32 of the NPA Blueprint that went out to consultation in July 2017, and finally by part 4 p38-59 of the “End User Requirements and Rules Blueprint” component of the final NPA Blueprint that was handed over by the “NPA Development Hub” to NPSO in December 2017 for implementation.
The co-chair of the “NPA Development Hub” by then also being CEO of NPSO, Mr Horlock could have saved time by just handing the documents to himself.
The chain of responsibility is clear: NPSO as owner of NPA must now deliver CoP, whether they regard it as a regulatory initiative or not. NPSO executives have framed CoP, nurtured it, recommended it, endorsed it, all the while within programmes that occupied the crease in UK payments landscape, and which – due to their wide apparent participation and claimed support – precluded any private initiatives from developing in the same market space.
Having squatted on the pitch for 4 years and queered it for others, they now have to go one step beyond framing, nurturing and so on. They have to deliver.
Washing one’s hands of responsibility for getting CoP to fly at this very late stage and making out it is the “industry” that has to deliver does not hold water. That is a prime example of a CoP-out.
Robert Lyddon is the current Director of Lyddon Consulting and former General Secretary of the IBOS Association secretariat in London. In a career in international banking spanning 17 years, Robert designed the “Connector” network for Bank Boston, and arranged numerous syndicated loans and derivatives transactions for Chemical Bank/Manufacturers Hanover and for Lloyds Bank International.
Tim Yudin as a member of “End User Needs WG”
Payment Strategy Forum “NPA Development Hub”: Paul Horlock as co-chair
Hong Kong’s Cathay Pacific warns of capacity cuts, higher cash burn
(Reuters) – Cathay Pacific Airways Ltd on Monday warned passenger capacity could be cut by about 60% and monthly cash burn may rise if Hong Kong installs new measures that require flight crew to quarantine for two weeks.
Hong Kong’s flagship carrier said the expected move will increase cash burn by about HK$300 million ($38.70 million) to HK$400 million per month, on top of current HK$1 billion to HK$1.5 billion levels.
Hong Kong is set to require flight crew entering the Asian financial hub for more than two hours to quarantine in a hotel for two weeks, the South China Morning Post reported last week, citing sources.
“The new measure will have a significant impact on our ability to service our passenger and cargo markets,” Cathay said in a statement, adding that expected curbs will also reduce its cargo capacity by 25%.
The airline, in an internal memo seen by Reuters, requested for volunteers among its crew who could fly for three weeks, followed by two weeks of quarantine and 14 days free of duty, adding it will be a temporary measure and not all its flight will require such an operation.
“We continue to engage with key stakeholders in the Hong Kong Government,” the memo said.
The government did not immediately respond to a request for comment.
Separately, a company spokeswoman said the airline could not detail the impact on vaccine transport specifically in terms of cargo shipments.
The aviation industry has been hit hard by the COVID-19 pandemic as many countries imposed travel restrictions to contain its spread.
In December, Cathay’s passenger numbers fell by 98.7% compared to a year earlier, though cargo carriage was down by a smaller 32.3%.
($1 = 7.7512 Hong Kong dollars)
(Reporting by Shriya Ramakrishnan in Bengaluru; Additional reporting by Jamie Freed in Sydney and Twinnie Siu in Hong Kong; Editing by Bernard Orr and Arun Koyyur)
Travel stocks pull FTSE 100 lower as virus risks weigh
By Shashank Nayar
(Reuters) – London’s FTSE 100 fell on Monday, with travel stocks leading the declines, as rising coronavirus infections and extended lockdowns raised worries about the pace of economic growth, while fashion retailers Boohoo and ASOS gained on merger deals.
The British government quietly extended lockdown laws to give councils the power to close pubs, restaurants, shops and public spaces until July 17, the Telegraph reported on Saturday.
The blue-chip FTSE 100 index dipped 0.1%, with travel and energy stocks falling the most, while the mid-cap index rose 0.1%.
“Stock markets are crawling between optimism around the rollout of vaccines and worries that a jump in virus infections and fresh local lockdowns could further affect recovery prospects,” said David Madden, an analyst at CMC Markets.
Britain has detected 77 cases of the South African variant of COVID-19, the health minister said on Sunday while urging people to strictly follow lockdown rules as the best precaution against the country’s own potentially more deadly variant.
Prime Minister Boris Johnson had earlier warned that the government could not consider easing lockdown restrictions with infection rates at their current high levels and until it is confident that the vaccination programme is working.
The FTSE 100 shed 14.3% in value last year, its worst performance since a 31% plunge in 2008 and underperforming its European peers by a wide margin, as pandemic-driven lockdowns battered the economy.
Online fashion retailers Boohoo and ASOS surged 4.8% and 5.9%, each. Boohoo bought the Debenhams brand, while ASOS was in talks to buy the key brands of Philip Green’s collapsed Arcadia group.
Recruiter SThree Plc gained 0.9% after its profit, which nearly halved, still managed to beat market expectations and the company said it had resumed dividends.
(Reporting by Shashank Nayar in Bengaluru; editing by Uttaresh.V)
Top 8 Tax Scams to Watch Out For
It is tax time and that means finding the best way to file your taxes and to get a refund of any amount you’ve overpaid. Unfortunately, tax time also means plenty of scammers are thinking of new and clever ways to try and get their hands on your money or on your personal information (which they can use to get money).
Those who specialize in IRS tax scams are clever and can be very convincing. Your first line of defense is to always know what to be looking for in terms of common tax fraud in order to avoid being another victim.
8 Most Common Tax Scams
Protecting yourself from IRS tax scams can be tricky if you’re not aware of what the threats are. A good tax scam seems legitimate, and that is what makes them dangerous. Always be on the lookout for the eight most common tax scams, including:
- IRS Phone Scams
- Fake IRS Emails
- Fraudulent Tax Preparers
- Fraudulent Tax Refunds
- Fake Charities
- Set Up Offshore Accounts
- Empty Promises
- Frivolous Returns
To know what exactly you need to watch out for, let’s look at them in more detail.
1. IRS Phone Scams
If someone calls you claiming to be from the IRS, it is almost certainly one of many IRS phone scams. The IRS will never call you to demand money for back taxes or to confirm your personal information, so be immediately alert. Never give personal information over the phone, and don’t head to the bank to follow the demands for money.
If you do wind up on the end of an IRS phone scam, don’t become flustered by aggressive tactics by the fake “agent”. They are good at sounding threatening and demanding information or payments. Remain calm and ask for contact information. Tell the scammer you’ll call them back with the information. Either the scammer will give you fake information or he will work to avoid leaving any information at all. Regardless, don’t call him back. Simply report the call to the local police or the IRS.
2. Fake IRS Emails
Another very common fake IRS scam is phishing, or sending fake IRS emails, in a ploy to gather personal information. Fake emails will look authentic and will ask you to click on a link or to log in to a fake IRS website. The purpose of these emails is to simply gather your personal information to be used for other fraudulent purposes.
Just like with IRS phone scams, you should be immediately wary if the IRS appears to send you an email. The IRS does not contact citizens through email. All official IRS communication will come through standard mail. If you do find a fake IRS email in your inbox, forward it to the IRS. The IRS investigates these scams and has a dedicated email address for this very purpose: [email protected].
3. Fraudulent Tax Preparers
Some scam artists show up in a suit, open a storefront and offer to prepare your tax return for you. These tax preparers appear by all accounts to be absolutely legitimate, and many go to great lengths to convince customers of their years of experience and authenticity.
As a fraudulent tax preparer, however, the person is not legitimate. The scam artist can use your tax return in many ways for his own benefit. He can inflate your refund and skim off the top. He can charge outrageous fees for filing on your behalf. He can file your return correctly this year and gather all of your information to make a fake return for his benefit next year.
If you are going to have someone else prepare your taxes, be sure to look carefully through tax service reviews. Tax service reviews are available on many different websites that offer feedback on companies and services. These reviews will give you a very good idea about the legitimacy of the business and the reliability of the preparer. If a company doesn’t have any tax service reviews on any website, like e.g PissedConsumer.com, or BBB, that may be a sign that it’s a pop-up company that will disappear as soon as the scammer has what he wants.
4. Fraudulent Tax Refunds
Another very popular tax scam starts well before the tax season. To file a fraudulent tax return, the scammer must gather all pertinent personal information including a social security number. He then uses the information he gathered to file a fake tax return on your behalf. Naturally, he’s not going to send you the refund he’s claiming – that goes into the scammer’s pocket.
The best way to prevent a fake tax return is to guard your personal information close at all times. If nobody is able to steal your identity, they can’t file a tax return. Another good step is to file your own tax return as early as possible. That way, even if your information was stolen somehow, you will get your refund correctly and the IRS will be alerted when someone files a second return using your information.
5. Fake Charities
Charitable donations are tax-deductible if you’re itemizing your deductions. This creates possibilities for scammers to take advantage of others who are looking to reduce their tax burden and increase their refund by making donations. Fake charities can take on many shapes and forms.
Some may appear conveniently around tax time or be affiliated with fraudulent tax preparers. The claim is that by donating to a fake charity you will help others and reduce your own tax liability. Instead, you’re giving someone free money and you won’t be able to deduct the donation as it’s not a real charitable organization. Other fake charities involve you in a scam by promising to give you back your donation as soon as the tax return is filed, for example. It goes without saying that claiming a donation you didn’t actually make is tax fraud and highly illegal.
At the advice of his tax preparers, a famous country singer Willie Nelson moved some of his money into tax shelters and charities to help reduce his tax bill. The IRS grew suspicious of the moves and investigated. In one of the most famous IRS cases in the United States, Willie Nelson was hit with a tax bill in the millions when his charities and shelters were found to be invalid.
Willie didn’t have the funds to make the payments, so the bill continued to grow until the IRS finally grew so frustrated they raided and seized all of Willie Nelson’s properties including a recording studio, a ranch, and his home. Even that wasn’t enough to pay the bill, so eventually, Willie made a deal with the IRS. He recorded an album and all proceeds from that album went directly to the IRS to whittle away his debt. Willie did file suit against the accounting firm that advised the tax shelters in the first place, but the two parties settled out of court.
6. Set Up Offshore Accounts
Some tax scams sound good but require your participation in illegal activities. For example, you may meet an unscrupulous tax “professional” who offers to help you move some of your money into an offshore account.
This sounds legitimate as many people use offshore accounts for valid reasons, but by moving your funds into an offshore account with the intent of hiding that income from the IRS, you’re committing tax fraud. Additionally, if you’re working with a shady professional, it’s highly likely that neither you nor the IRS will see your extra income ever again. And you can still wind up with a legal case with your money stolen and gone.
7. Empty Promises
The tax preparer who encourages you to sign a blank tax form is nobody you want to work with. These preparers encourage you to simply sign the form because he or she is going to work out the numbers for you so that you can get the highest possible refund. If you do this, you are almost certainly subjecting yourself to tax filing scams.
Signing a blank tax form is potentially worse than simply signing a blank check for a stranger. Not only are you at risk of losing your personal information and any refund you might be owed, but you are also at risk of legal action by the IRS for signing your name on a refund that is almost certainly going to contain false and fraudulent information.
8. Frivolous Returns
The IRS sees a ridiculous number of what they call “frivolous returns” every year. A frivolous return is a tax return that is filed with the intent of simply wasting time. These frivolous claims have already been thrown out in court, so filing a tax refund making a frivolous claim is simply opening yourself up to additional action by the IRS including fines of at least $5,000. The top “frivolous claims” include:
- Refusing to pay taxes on moral or religious grounds
- “Opting out” of paying taxes
- Invoking the First Amendment to “protect” you from taxes
- Claiming only Federal Employees pay federal taxes
- Claiming you have no income and therefore no tax liability (when you clearly do)
Top 3 Tips on How to Protect Yourself from IRS Tax Scams
Protecting yourself from tax fraud is a matter of being vigilant and mindful that there is always a possibility of something going wrong. Work with a trusted advisor or study up and file taxes yourself to avoid the uncertainty of allowing others to handle your financial matters. Often a bit of knowledge goes a very long way.
1. Know How the Tax System Works
One of the most common negative IRS reviews is that the tax refunds aren’t released immediately. In many IRS complaints, customers complain that they don’t get their refunds immediately.
While frustrating to wait, the IRS is usually very clear about processing times and has never sent refunds immediately after the filing window opens. The government doesn’t move quickly and reviews of documents and financial information submitted in your returns are necessary.
Additionally, relying on others to help you file your taxes every year can open you up to the possibility of fraudulent activities. Reviewing the tax codes and reading through the laws and requirements may not be exciting, but it will give you at least a basic understanding of how the process works so that you can look out for problems if you are trusting someone else with your information and money.
2. Always Read Carefully
The safest way to file your taxes is to do them by hand on the original IRS paper forms and to mail them using certified mail. Many people don’t choose to do this, however, as it can be very tedious and confusing if you do not know the tax system backward and forwards.
Instead, many filers rely on tax software and paid tax preparers. When using software or allowing someone to use the software on your behalf, it never gets too comfortable. There might be hidden fees in the software or glitches to overcome.
Reviewing choices carefully as the software takes you from screen to screen is a good way to avoid accidentally accepting hidden fees. Another option to avoid paying for fees you aren’t comfortable with is to simply abandon the return on one piece of online software and to try again with another – there are multiple tax return software options available.
3. Always Look for Tax Filing Scams
If you always expect to find a scam, you’ll never be surprised when one appears. Even tax preparers who have been in business for years can have some deceptive business practices that others assume are necessary or haven’t noticed them at all.
Tax time can be exciting if you’re entitled to a large refund, but it can be stressful if you don’t feel in control of the tax filing process. Educate yourself on the risks and tax scams that exist, and always exercise caution when choosing a method to file your taxes. Your personal information is closely tied to your money, so protecting both of them is often simply a measure of keeping your eyes wide open and using your knowledge to avoid traps and scams.
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