Self-assessment fo the SEPA-compliance of infastuctues Based on Tems of Refeence established by the Euopean Cental Bank as published in the 5 th Pogess Repot of SEPA (July 2007) and available on the website of the ECB, www.ecb.eu The ECB Tems of Refeence have been tansfeed to this pape and we have povided ou esponses to the questions on the following pages. Page 1 of 6
Citeion 1 Pocessing capabilities To pomote the SEPA-compliance of infa-stuctues, infastuctues ae asked to comply with the equiements of the PEACH/CSM Famewok, the SCT Rulebook and / o the SDD Rulebook(s), the Implementation Guidelines and the associated UNIFI (ISO20022) XML standads, and to be eady to suppot the scheme testing as planned by the EPC. 1. Q Have you sent a Disclosue Lette to the EPC egading you intention to become a SEPA compliant CSM? The Disclosue Lette was sent 25 Januay 2008 to the EPC confiming Euogio s intent to be a SEPA Cedit Tansfe compliant SCM. 2. Q Ae you compliant with the elevant PEACH /CSM Famewok? 3. Q Ae you compliant with the elevant SCT Rulebook? 4. Q Ae you compliant with the elevant SDD Rulebook(s), i.e. coe sevice and, if and when adopted, Business-to-Business sevice and e-mandate sevice? A We will povide the basic messaging exchange of SDD to paticipants accoding to the specifications, but will not povide add-on sevices like e-mandate sevices. 5. Q Ae you complying with the elevant guidelines that equie the use of the UNIFI (ISO 20022) XML message standad? 6. Q Ae you able to delive all mandatoy payment infomation (fom the so-called yellow data fields) in full and without alteation between the involved paticipants? 6a. Q Please povide infomation on you ability to pocess the full SEPAsubset of the ISO 20022 XML messages (i.e. the yellow and white data fields) A Fully compliant with SEPA Cedit Tansfe Scheme Inte-Bank Implementation Guidelines v3.2 7. Q If you povide convesion between XML and legacy fomats (and/o v.v.), do you ensue that no payment data is lost? 8. Q Have you adequately tested you pocessing pocedues? Page 2 of 6
8.a Q Please descibe the famewok, the oganization, the scope (national o coss-bode) and the each (SCM-bank, bank-csmbank, end-to-end) of the testing A Ou tests have been: bank-scm-bank with seveal banks Coss-bode by dedicated test team Citeion 2 Inteopeability To pomote the SEPA-compliance of infastuctues, infastuctues ae asked to adopt inteopeability ules, i.e. inteface specifications and business pocedues fo the exchange of SEPA cedit tansfes and SEPA diect debit payment odes between banks and infastuctues, and between infastuctues, that ae pefeably mutually ageed upon by the elevant CSMs, and undetake to establish a link with any othe infastuctue upon equest, based on the pinciple that the cost fo establishing the link is bone by the equesting infastuctue. 9. Q Have you adopted inteopeability ules, i.e. inteface specifications and business pocedues fo the exchange of SEPA cedit tansfes and SEPA diect debit payment odes between banks and infastuctues, and between infastuctues? A Yes, between banks and Euogio. 9a. Q If yes, ae the inteopeability ules you ae using mutually ageed upon by the elevant CSMs? 9b. Q please descibe, especially whee you ae not using mutually ageed inteopeability ules, the elevant elements fo inteopeability (message fomats, cut-off times, cleaing and settlement pocedues, econciliation and contol pocedues); 9c. Q ae you compliant with othe elevant ules, guidelines o pactices which aim at ensuing inteopeability (e.g. the CSM Maket Pactices )? 10. Q Would you undetake to establish a link with any othe infastuctue upon equest? A Yes, if so equested by anothe CSM o a Euogio custome. 10a. Q Have one o seveal links been established? If yes, please povide names of the paticipating infastuctues; A No. 10b. Q a link would ideally be ceated on the basis of a mutually beneficial Page 3 of 6
A business case. In absence of such a business case, the equesting infastuctue povide would have to bea the costs of the equested link (setting up and maintenance theeof). Who beas the costs of the established link(s)? Not applicable. 10c. Q have you consideed, eithe on you own initiative o upon equest, changing the intenal pocessing pocedues in ode to incease the efficiency of a link? Have any such changes been caied out? A Has not yet been elevant. Howeve, we egulaly conside ou pocessing pocedues in ode to incease efficiency. 10d. Q how ae the tansfes between CSMs settled? A Not applicable. Citeion 3 Reachability To pomote the SEPA-compliance of infastuctues, infastuctues ae asked to be able to send o eceive euo payments to and fom all banks in the euo aea, eithe diectly o indiectly though intemediay banks, o though links between infastuctues (in othe wods, to povide full eachability) 11. Q Ae you able to send euo payments fom you paticipants and eceive euo payments fo you paticipants, to and fom all SEPA scheme paticipating banks in the euo aea, eithe diectly o indiectly though intemediay banks, o though links between infastuctues? Diectly if both paties ae paticipants in Euogio, indiectly via paticipating banks that offe to act as intemediaies. We have standad offes to the Euogio community fom Deutsche Postbank, Deutsche Bank and Banco Bilbao Vizcaya Agentaia (BBVA) who ae all diect paticipants in EBA Step2 and also link to othe CSMs. 11a. Q Please descibe how many SEPA scheme paticipating banks you can each (diectly o indiectly) on the basis of contactual aangements; A Minimum equivalent to the each povided by EBA Step2 & Step1 and Taget2. 11b. Q how do you ensue that you ae able to oute a payment to each bank in the euo aea that is paticipating in the SEPA scheme(s)?; A By offeing ou paticipants to choose to connect via one of the patne paticipants that offe indiect links to the EBA Step2, supplemented by links to additional CSMs. 11c. Q please descibe how you obtain the necessay outing infomation. If you use you own outing database, how do you update it, i.e. Page 4 of 6
A how do you obtain the latest infomation fom all SEPA scheme paticipating banks in the euo aea? How do you addess possibly conflicting infomation if a SEPA scheme paticipating bank is eachable via seveal payment channels? How is outing decided whee thee ae seveal possibilities fo eaching a SEPA scheme paticipating bank?; We use global egistation of the capacity of each diect membe. Sending membe decides outing based on this infomation. 11d. Q How much time (in days) do you need to each evey SEPA scheme paticipating bank, espectively be eached by evey bank in the euo aea that is paticipating in the SEPA scheme(s)? Will you be able to each evey SEPA scheme paticipating bank within one business day at the latest by 2012?; A Ou sevices enable the paticipants to obseve the timelines fo the pocessing of SCT, as defined in the SCT Rulebook. We intend to enhance ou sevices to meet the timefames that will be equested in the futue. 11e. Q If you cuently do not offe full eachability to you paticipants, do you intend to offe it at a late point in time? If so, how will you achieve this and by when? Citeion 4 Choice fo banks To pomote the SEPA-compliance of infastuctues, infastuctues ae asked to enable financial institutions to make infastuctue choices based on sevice and pice, and theefoe not apply undue access estictions, no set obligations fo uses to pocess cetain types of payment in a specific infastuctue, o via specific popietay standads, no to impose paticipation obligations on uses of othe infastuctues, and to ensue full tanspaency of sevices and picing 12. Q Have you made you etail payments cleaing sevice offeings and you fee stuctue (including infomation (and amounts) about all types of applicable fees, such as admission fees, peiodical fees, tansaction fees o package fees) publically available? A This infomation is available on ou website fo customes and on equest against signing of a NDA. 13. Q Do you efain fom applying diffeent access conditions depending on the type of applicant, its location o othe kind of consideations? 14. Q Do you efain fom obliging you paticipants to pocess cetain SEPA payments in a specific infastuctue? Page 5 of 6
15. Q Do you efain fom obliging you paticipants to use specific popietay standads fo SEPA payments? 15a. Q If no, please descibe the popietay standads fo SEPA payments that you oblige you paticipants to use; 16. Q Do you efain fom imposing paticipation obligations on the uses of othe infastuctues when anothe CSM is equesting a link?? Date: 11 June 2009 Signed by: Tjeed Riensta CEO of Euogio A/S Page 6 of 6