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Issue | Example / Requirement | Liable Party | Responsible Party | Extent of Redress | OF Compensation / AED |
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Inaccurate or inconsistent payment initiation / execution due to incorrect beneficiary details supplied and approved by User | The User has provided an incorrect beneficiary proxy and not verified the resolved beneficiary details resulting in an error. | User | User | N/A | N/A |
Inaccurate or inconsistent payment initiation / execution due to incorrect beneficiary details supplied by TPP | The TPP has incorrectly configured the receiving account of their onboarded merchant resulting in misdirected payments from users for purchase of goods eventually causing fulfillment issues. | TPP | TPP | Direct Losses & Open Finance Compensation | 350 |
Inaccurate or inconsistent payment initiation / execution due to incorrect beneficiary details supplied by LFI (including via inaccurate proxy resolution) | The LFI has incorrectly resolved the beneficiary proxy provided by the User resulting the payment sent to the incorrect beneficiary. | LFI | LFI | Direct Losses & Open Finance Compensation | 350 |
Payment initiation by TPP request contains mismatch to User stated intention / awareness | The shipping and/or service charges were obfuscated while requesting authorization for an eCommerce purchase resulting in the User feeling overcharged. | TPP | TPP | Direct Losses & Open Finance Compensation | 350 |
Fraudulent or erroneous payment initiation occurring using VRP or Delegated SCA payment consent by TPP | The User acknowledges that they authorized a Long-lived consent but is unable to recognize/reconcile transaction(s) for which they were not physically present Or they had not physically authorized the TPP to initiate the transaction(s). | TPP | TPP | Direct Losses & Open Finance Compensation | 500 |
Fraud monitoring of all payment activity from LFI held accounts | The LFI was not able to flag alerts and protect the User from fraud in spite of sharp increase in the transaction frequency or value for payments initiated by TPP using VRP or delegated SCA. | LFI | LFI | Direct Losses & Open Finance Compensation | 250 |
Payment initiated outside of VRP / future dated payment / bulk payment / part payment / refund consent | Processing errors possible by LFI where an LFI makes the incorrect copies of the consent from OFP and therefore add an inaccurate validation process. | TPP | TPP | Direct Losses & Open Finance Compensation | 350 |
Fraudulent payment requests (including RTP and similar) issued via a TPP | Fraudulent Request to pay using OF wherein User ends up making payments to a fabricated bank account. | TPP | User (Requesting) | Direct Losses & Open Finance Compensation | 500 |
Failure to execute payment within SLA by LFI, following valid payment initiation | The User has lost out on favorable contracts which depend on time sensitive purchases like trading for stocks or buying forex because the LFI took too long to execute such payments. | LFI | LFI | Direct Losses & Open Finance Compensation | 350 |
Inaccurate or Incomplete articulation of Payment Consent for VRP or Delegated SCA to User | User was not unambiguously presented the available controls in form of transaction limits for a VRP which resulted in payments being initiated which were not as expected by the User. | TPP | TPP | Direct Losses & Open Finance Compensation | 350 |
Payment amount / date / currency / description / LFI / source account incorrect due to User Input | Payment details such as amount, date, currency, or account source are incorrect due to errors entered by the user, leading to failed or erroneous transactions. | User | User | N/A | N/A |
Payment amount / date / currency / description incorrect due to LFI processing error | The LFI system had addition or transposition errors or a glitch where mandatory payment references like those for Card/Bill payments were truncate. All of these could lead to erroneous execution of payment. | LFI | LFI | Direct Losses & Open Finance Compensation | 350 |
Payment amount / date / currency / description incorrect due to TPP processing error | The TPP system had addition or transposition errors or a glitch where mandatory payment references like those for Card/Bill payments were truncate. All of these could lead to erroneous execution of payment by the LFI. | TPP | TPP | Direct Losses & Open Finance Compensation | 350 |
AML / Financial Crime responsibilities for Payments including Transactional Monitoring and PEP / Sanction / Terrorism screening | The LFI must screen all payments required to be screened by AML regulation and legislation. | LFI | LFI | Direct Losses | N/A |
Payment execution duplication by LFI | The Payment has been executed incorrectly by the LFI (e.g. taken twice due to technical glitch). | LFI | LFI | Direct Losses & Open Finance Compensation | 350 |
Payment initiation duplication by TPP | The TPP system has a technical glitch where the Payment initiated as part of a VRP or delegated SCA is duplicated. | TPP | TPP | Direct Losses & Open Finance Compensation | 350 |
Breach of contract or misrepresentation by Merchant | Failure to deliver complete, usable or functional goods / services , as they were described, despite valid and completed payment via Open Finance, including in the case of Merchant insolvency | Merchant | Merchant | Direct Losses & Open Finance Compensation | 100 |
Merchant legitimacy and consistency of Entity Name / Account Name / KYC Status at LFI / Trading Name as presented to the User | The TPP must onboard the merchant via a KYB process which ensures that the trading name represented to their customers as part of payment collections processes are legitimate and are approved legally with relevant authorities. | TPP | TPP | Direct Losses & Open Finance Compensation | 500 |
User legitimacy and consistency of Legal Name / Account Name / KYC Status at LFI as presented within Open Finance ecosystem | The TPP must onboard individual users via a process which utilizes their KYC-ed record at an LFI, which contains verified data and has not expired as a valid KYC record. The user must only represent themselves on the OF platform and in OF transactions with the same name to be held at the LFI. | TPP | LFI | Direct Losses & Open Finance Compensation | 350 |
Inaccurate or invalid charging of customer for goods / services, when payment for those goods / services is settled via Open Finance payment initiation | The shipping and/or service charges were obfuscated while requesting authorization for an eCommerce payment resulting in the User feeling overcharged. | Merchant | Merchant | Direct Losses & Open Finance Compensation | 100 |
Refund failed to be initiated and completed from Merchant, despite complete return of goods / inability to utilise services, as they were described or delivered | The refund was only partially paid, despite a full refund being agreed / an entitlement of the customer, given the circumstances. | Merchant | Merchant | Direct Losses & Open Finance Compensation | 100 |
Payment funded from an incorrect account, caused by LFI error | The debited account for an OF initiated payment was one other than the one selected by the User with the TPP, due to a LFI processing error. | LFI | LFI | Direct Losses & Open Finance Compensation | 150 |
Payment funded from an incorrect account, caused by TPP error | The debited account for an OF initiated payment was one other than the one selected by the User with the TPP, due to a TPP user interface error. | TPP | TPP | Direct Losses & Open Finance Compensation | 150 |
3. Indirect and
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Consequential Losses
3.1 Indirect Losses
Losses that do not flow directly and immediately from the act but are a result of the act in a more roundabout way
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