How do the PSRs apply to banks operating in Bacs, CHAPS or Faster Payments through an agency agreement with a settlement bank?
The key test is whether they are offering payment services to a customer. If the customer requests that the agency bank executes a transaction for them and the transaction is executed, then the conduct of business requirements apply in relation to the transaction. The agency bank is responsible for ensuring that the requirements are complied with. The arrangements that the agency bank puts in place to effect the transaction are not relevant to the question of whether the PSRs apply.
