PREPARATORY STAGE

• assessment of entity and service compliance with MIP requirements (procedures and policies, prohibition of cross-border activity, transaction and user limits, cooperation models with partners, user agreements and rules)
• legal qualification of services in terms of their allocation to specific payment servicesh
• drafting descriptions of payment services and graphic diagrams

APPLICATION DOCUMENTATION STAGE

• a model activity programme and financial plan for the first 12 months of operation to be completed by the Principal in terms of figures as well as specific solutions and objectives
• model internal procedures (risk management, AML/CFT)
• assistance in the operationalisation of the model documentation ( guidance in completing the business programme and financial plan)
• guidelines regarding the documentation to be collected by the Principal (statements, documents)
• application to the PFSA

PROCEEDING STAGE

• periodic communication with the authority on the progress of the case
• in case of controversial issues – workaday contact with the FSA, including drafting the provision of additional explanations and documents and, if necessary, making the adjustments requested by the FSA
• obtaining the licence (including receipt of the certificate of entry in the MIP register)

START-UP STAGE

• drafting a response to the FSA’s supervisory request (MIP’s sector letter)
• preparation of procedures required of a payment service provider and not submitted with the MIP application (security strategy, incident management, complaints)
• preparing a draft payment services agreement (payment services regulations)
• preparing a draft of outsourcing, agency agreement
• assistance with the registration of a qualified agent/outsourcer with the FSA
• assistance in updating information in registers, letters, websites
• guidelines for filling all positions and functions and registry changes
• workshop on the implementation of internal procedures
• instruction on the payment of supervisory fees
• instruction on the execution of reporting obligations
• negotiation of an account agreement to protect users’ funds
• assistance in obtaining KIP authorisation in case of reaching a transaction limit or seeking to expand to other EEA countries or to AIS/PIS services