Subject Matter
Use by CASPs of payment accounts provided by non-bank payment service providers for holding clients’ funds
Question
May an authorised CASP temporarily place clients’ funds in an account held with a non-bank payment service provider, such as an electronic money institution or a payment institution, while maintaining adequate arrangements to safeguard clients’ ownership rights in accordance with Article 70(2) of MiCA, provided that those funds are subsequently placed in an account held with a credit institution or a central bank no later than the end of the business day following the day on which they were received, in accordance with Article 70(3) of MiCA?
Furthermore, may clients’ funds remain beyond that deadline in an account held with a credit institution where that account has been opened in the name of, and is held by, a non-bank payment service provider specifically for the CASP and is technically segregated from all other accounts?