Bank of Lithuania
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The Bank of Lithuania has initiated a public consultation, seeking the opinion of payment service providers and users, market experts and public sector representatives on safeguarding customer funds held by electronic money and payment institutions (EMIs/PIs), i.e. what measures would help to increase the protection of such funds and strengthen market and public confidence in these institutions.

“Lithuania has managed to attract a good handful of new market entrants: we are currently one of the leading European countries in terms of licensed electronic money and payment institutions. It is especially important to ensure that businesses and the general public trust these payment service providers, which is why we are analysing how we could improve the regulatory environment in light of new challenges emerging within the sector,” said Tomas Karpavičius, Head of the Market Infrastructure Policy Division at the Bank of Lithuania.

The consultation document gives an overview of the existing legal framework, indicates potential risks, and provides an analysis of measures that could help to increase the protection of EMI/PI customer funds, especially in cases when the credit institution where these funds are held becomes insolvent. The document outlines measures that could be implemented on a national level and also encourages discussion on changes requiring amendments to EU legislative acts.

While deposits held in banks are covered by deposit insurance, customer funds held with EMIs/PIs are protected using other means. The most important one is separation of customer funds from EMI/PI own funds, ensuring that they are held in a separate account with a credit institution that cannot be subject to the claims of EMI/PI creditors. Other ways to safeguard funds include investment in secure and liquid low risk assets or private insurance. Such differences in protection methods might be one of the reasons why there is a credibility gap between EMIs/PIs and banks.

To voice your opinion on safeguarding EMI/PI customer funds, answer the questions provided in the Bank of Lithuania’s public consultation and send your replies by email to [email protected]. The consultation will close on 1 August 2019. 

Creating a competitive and advanced payments market in Lithuania is one of the Bank of Lithuania’s strategic directions for 2017-2020. 

•    Public consultation – Increasing the Protection of Customer Funds Held by Payment and Electronic Money Institutions