Interbank fees: interchange on French direct debits to be halved
- The French antitrust authority, Autorité de la Concurrence, has announced a commitment of French banks to reduce the main multilateral interbank fees (MIF) applicable to all kinds of direct debits, after complaint has been filed. These so-called interchanges will get down by 50% starting 1st October 2012, and will disappear on 1st February 2014, with the end of the SDD migration.
- A “market test” has been collecting the opinion of all non-financial involved parties until 10 May (creditors, mainly). If the “Autorité” gathers enough supporting assurance at the end of this test, the 0.122 euro MIF on French legacy direct debit will be lowered at 0.061 euro as of October. On the paper-based one-off direct debit “TIP” (Titre Interbancaire de Paiement), this interim decrease will see the applicable MIF go from 0.137 euro to 0.068 euro next October. Lastly, the MIF for electronic one-off direct debits (“télérèglements”) will be stepped down from 0.076 euro to 0,038 euro. When final SEPA compliance is achieved on 1st February2014, these new level will be suppressed permanently.
Source: Press release from the Autorité de la Concurrence
- The French banks’ commitment proposal takes place before completion of the legal investigation. The “Autorité” namely allows an amiable compromise when all parties agree to a settlement. It may however request more concessions from the defenders. It also retains the possibility to restart the legal proceedings at any time (such had been the case in 2010 in a similar issue about cheque interchange, which resulted in a heavy fine for banks). MIF levels proposed by banks on direct debits could decrease even further when the complaint is eventually handled.
- This French step only anticipates a broader, unfavourable regulatory context. The recent European Regulation of 14 March 2012 (N°260-2012) has forbidden MIFs on all intra-national direct debits as of 1st February 2017, and as soon as next 1st November for the (still very few) cross-border direct debits. Moreover, an earlier European Regulation compels financial institutions not to surcharge cross-border transactions with regard to domestic ones to the end customer. Lastly, the SDD mandate being entirely managed by the creditor, and no more by banks, the new SEPA circuit undermines the rationale behind a MIF due to the debtor bank.
- Indeed, just like for card payments, the creditor (the payee) pays a service charge to its financial institution. It is usually a fixed fee per operation. Its debtor however incurs no such recurring fee. Part of the creditor’s fee recoups the French MIF due by the creditor’s bank to the debtor’s bank. The announced MIF decrease opens up avenues of reduced fee levels for creditors. Let us note that the traditional revenue model for banks also includes, for a large part, penalties levied on both the creditor (charge-backs, technical rejects, etc.) and the debtor (insufficient funds, mistakes, etc.).