RCEF — Payments Safeguarding Module
Evidence questions for the exact payment institution and service.
PSCR applies the developing RMCA Conduct Evidence Framework to payment permissions, relevant funds, safeguarding, settlement, complaints and operational evidence. The module is being developed from the Responsible Markets RM10 standards architecture.
What the module does
The Payments Safeguarding Module translates common RCEF dimensions into sector-specific evidence questions. Each published field is intended to preserve the institution, service, customer category, jurisdiction, source date, evidence character, limitation and review history relevant to the stated scope.
Payments-specific evidence architecture
Ten working dimensions
Entity, perimeter and licence identity
Exact EMI, PI, bank or related entity, official identifiers, permissions, agents, distributors and service perimeter.
Governance, accountability and conduct culture
Safeguarding oversight, senior accountability, audit, complaint ownership and operational governance.
Client classification, distribution and access
Customer categories, merchant sectors, channels, territorial access and agent governance.
Customer funds, safeguarding and protection
Relevant funds, applicable requirement, safeguarding method, insurance or guarantee where relevant, and return-of-funds route.
AML/CFT, sanctions and KYB
Customer or merchant KYB, transaction monitoring, agents, corridors, sanctions and suspicious-flow controls.
Marketing, communications and intermediaries
Permission, FSCS or safeguarding claims, service scope, customer-fund wording, agents and introducers.
Payments, withdrawals and transaction integrity
Receipt allocation, reconciliation, settlement, reserves, refunds, freezes and processing incidents.
Complaints, cooperation and remediation
Internal handling, eligible external route, root cause, cooperation and remediation evidence.
Outsourcing, technology, data and resilience
Processors, safeguarding banks, cloud services, outsourcing, incidents, continuity and resolution readiness.
Evidence file, annual narrative and change control
Dated evidence, audit material, returns, bank changes, expiry, material events and historical status.
Evidence character — development preview
Evidence character may differ field by field. Strong evidence for legal identity does not establish a separate safeguarding, reconciliation or return-of-funds claim.
DEVELOPMENT PREVIEW — NOT A LIVE INSTITUTION STATUS SYSTEM.
Operating principles
- 01Exact institution before brand or app.
- 02Permission and service perimeter before implication.
- 03Field-specific evidence before overall status.
- 04Source, date and limitation visible.
- 05No silent methodology change.
- 06Corrections preserve history rather than erase it.
- 07Separate programme scope and independent checks.