Mr. Bill Cox:

There is regulation of e-money vouchers or e-money gift cards in respect of what is called the redemption fee which applies if one wants one's money back. The money is stored in the electronic money account, which can be done for an electronic money product, and under the electronic money directive a fee can be charged that is reasonable and proportionate.

The directive is silent about other fees. The argument of the electronic money providers is that they do incur substantial costs in safeguarding the money. They must keep 102% of the funds in the segregated account. In the present interest rate environment, they are charged up to 0.5% by the bank for the privilege of keeping their money. They also incur costs under anti-money laundering legislation and normal business costs that they must meet to provide the product. They argue that, if they cannot charge those fees, their product will not be viable. The main purpose of the recent consultation was to get information on the fees and the revenue from them in order to assist the Minister to determine fees in the future.