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Für jede weitere Nutzung ist keine weitere Authentifizierung mehr nötig. In initiating this new process, it would appear the ECB assumed that institutions already have access to this information in a structured data form.

After decades of capital requirements regulation and a growing push towards improved digital information flows, such an assumption may have seemed reasonable.

However, the reality is somewhat different. Firms want to default to the legal response — the tried and tested reams of lawyerly words — to meet this requirement rather than a constructive, consistent response based on client, product, opinion and agreement data.

When pressed for more detailed information, the only option is to undertake cumbersome ad hoc reporting, relying on spreadsheets and searching for original documentation.

Because firms are still failing to capture and retain the level of granular detail required. The excuse is that the ECB has not defined a specific taxonomy for this compliance requirement — leaving firms to come up with their own responses.

The reality is that the ECB expected firms to have robust data governance and classifications to support both compliance with capital requirements regulation and, more critically, netting decision-making.

For instance, under the new requirements institutions may continue to determine if a change is material or not according to their internal processes.

This implies that a reporting institution must also be able to document for each new trading agreement whether or not a core netting provision has been amended, and if amended, whether or not the change is so material as to require a supplemental opinion which must be notified to the ECB.

Fundamental to satisfying these new requirements is the way in which firms view their data — most notably, counterparty types, agreement types and agreement type data.

Of course, firms are. But that is the issue — firms have not bothered with, for example, updating client onboarding data taxonomies for close-out netting determination purposes.

As a result, essential aspects of the data capture process have been overlooked — hence the cumbersome, burdensome and manual reporting required to meet the ECB demands.

For example, simply recording a counterparty as an Investment Fund may meet business and compliance data needs; but the close-out netting determination requires far more granularity.

The legal opinion will be — must be — far more specific about the different types of funds because each may result in different close-out netting analysis.

Or take the case of a bespoke legal opinion which simply reflects only those types of funds which the law firm has been asked to include, to the exclusion of other types.

And what about agreement vintage? A firm may have identified agreement types, but not noted agreement versions. Yet there are multiple versions of, for example, certain French, German and Spanish domestic netting agreements.

If all agreement vintages are under one heading, how is the institution going to make a valid distinction between them other than by a laborious manual process?

It should also be a red flag for the institution. Close-out netting is a vital process and correctly taking its benefit underpins financial stability and has implications for billions of pounds of regulatory capital.

How can a firm confidently take the decision to net without accurate and well-governed data and without the ability to confidently and rapidly show its working?

It is extremely concerning that institutions are not looking to the data to support these decisions or to confirm that the regulatory requirements are being met before the netting benefit is taken.

These callers would then report a software issue with the cards, and asking them to issue new cards from the system and give them the PINs to check whether the issue had been resolved.

These victims were then told that when the problem had been rectified codes would be given reverse the transactions, however, as soon as the victim gave the activation codes for the cards, the caller hung up and would not contact the merchant again, nor would they respond to any contact efforts.

While this did not cause an issue for those who bought Paysafecards, as the victims were shop owners and, more regularly, shop employees, it added a sense of concern to the safety of Paysafecards.