Mr. John Palmer:

Sure. We will review all the answers we provided to the Deputy. If we are in the wrong, we will go to the Minister and correct the record. However, there was never an intention to say that because frankly, we have been poring over this quite a bit, when we have had a chance, to see what the situation is. There are several provisions in the payment services directive that run one way and then the other. It is silent on APP fraud because that was not envisaged back when the directive was done. We knew there was a possibility there, but we also have to see whether there are other provisions in the directive that might run contrary to it or cause a problem.

We run into potentially the same issue with the new proposals from the Commission, which we have yet to study in detail as they only came out a couple of hours ago. This time it will be a regulation. We would not normally be allowed to go beyond what a regulation says because it has got direct application and we will have to see whether there is any member state discretion in that and whether it is possible. The Commission has decided to expand refunds for APP in two spaces; namely, impersonation and if the new IBAN name verification check is not carried out correctly. It specifically states in the review that it will not go to full liability because it anticipates significant upheaval and large costs if it did. It seems a bit strange that the Commission would decide it will not introduce it but then suggest that we can. We will have to review it and see whether we can.