Martina Sjöblom - Improving consumer protection with commercial VRPs
Tink Senior Legal Counsel, Martina Sjöblom, has been named to a new sub-working group – focused on consumer protection – as part of the Joint Regulatory Oversight Committee’s (JROC) push in the UK to introduce and develop commercial, non-sweeping variable recurring payments (VRPs). Read on to find out more about Martina’s role and the purpose of the group.
Tink Senior Legal Counsel Martina Sjöblom is part of a new JROC sub-working group focused on the consumer protection within commercial VRPs.
“It’s essential to assess our current practices within the industry, map our existing framework and then determine its compatibility with the evolving commercial VRP landscape.”
Martina and the team are also closely monitoring the recently announced PSD3/PSR and FIDA proposals from the European Commission.
Martina has been with Tink since early 2020, joining us from one of Sweden’s largest banks, and now is a key member of our regulatory legal team, monitoring and advising on regulatory matters that have implications for our business.
Tink is involved in many areas of the JROC VRP workstream, with Head of VRP Andrew Boyajian part of the parent VRP working group, while Product Solutions Director Sam Jennings is included in the sister group of Martina’s, focused on commercial models.
“You can really see a difference in how we have matured as a company in the time since I joined,” said Martina. “We’re involved in so many key discussions on the future of finance both in the UK and EU. It's clear that when it comes to this kind of regulation we do play a big part. We’ve worked hard for our position as the market leader in open banking, and I think we should be really proud of that.”
What will the consumer protection group focus on?
“There are numerous critical factors to consider when implementing commercial VRPs. Consumer protection is of course one of the most important aspects. This means establishing effective protocols for dispute handling and liability arrangements, to ensure a robust consumer protection framework.”
But consumer protection is a large topic – and it can be useful to look at it in smaller components.
For example, a good starting point could be ‘what protections are there for payment errors?’ And the good news is that protections already exist. They're part of the Payment Service Regulations (2017) in the UK (as well as the 2015 Payment Services Directive in the EU), which clearly outline the roles and responsibilities that Payment Initiation Service Providers (PISPs) and Account Servicing Payment Service Providers (ASPSPs) have for the payer in case of errors.
A lot of these responsibilities mirror the UK Direct Debit Guarantee, with which many consumers will be familiar. And they're a great level of protection that VRP already has for lower-risk use cases, like bill payments.
Following payment errors, Martina said it will be useful for the group to focus on any needs for additional protections such as ‘would purchase protections help ensure a purchase is delivered as it should be?’ Consumers are broadly protected with frameworks like the Consumer Rights Act (2015) – but perhaps it might be possible to make those protections more accessible within VRP payments.
“It’s essential to assess our current practices within the industry, map our existing framework and then determine its compatibility with the evolving commercial VRP landscape. If necessary, we should propose a new framework tailored specifically for VRP, which may involve suggesting additional regulatory requirements where appropriate."
PSD3/PSR on the horizon
The recently announced PSD3/PSR draft legislation from the European Commission is another big development that Martina and the team are monitoring, especially as she worked closely on the implementation of PSD2 at her last company.
Will PSD3 be keeping her busy? “Yes absolutely! PSD3/PSR, as well as the FIDA (Financial Data Access) proposal, will play a pivotal role in governing our operations. They encompass a significant portion of our activities, particularly concerning the handling of payment data and other crucial financial information.”
Martina also said that working with our legal colleagues at Visa helps Tink differentiate itself from others in regulatory open banking discussions.
“There’s a comprehensive collaboration between our legal team and Visa’s, being able to leverage the expertise that they have is massive for us.”
Reflecting on her time at Tink, Martina finished by saying that the atmosphere was what made it a special place to work.
“One of our values is to be friendly and we really live up to that. It's a very warm, open atmosphere and we have been able to retain that going from this small tech company to a much larger organisation that is now part of the Visa family.”
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