(Prepared based on page 4 of the secretariat materials for the 2nd Working Group on Regulations on Payment and Settlement and Regulations on Cross-Sectional Financial Services Intermediaries of the Financial System Council, held on October 24, 2019) The regulations set forth in Sections (l) and (m) above are different from those for Funds Transfer Services and prepaid payment instruments in that they apply to deferred payment services where users pay after purchasing goods. The Installment Sales Act is under the jurisdiction of the Ministry of Economy, Trade and Industry, and not the Financial Services Agency. Issuance of cash-convertible electronic money (Funds Transfer Services) Electronic money that can be used for the purchase of goods or services from a merchant is generally issued based on registration for Funds Transfer Services or as an issuer of a prepaid payment instruments for third-party business, but prepaid payment instruments are not in principle allowed to be converted to cash (Article 20(5) of PSA). If electronic money is freely convertible to cash, it becomes possible to obtain the cash prepaid into that electronic money, which is considered an "exchange transaction." Therefore, the issuance of cash-convertible electronic money requires registration for Funds Transfer Services. Issuance of non-cash-convertible electronic money (prepaid payment instruments for third-party business) In contrast, non-cash-convertible electronic money generally falls under the definition of prepaid payment instruments, and therefore it is regulated as a "prepaid payment instrument for third-party business" if it can be used at merchants other than the issuer. However, it should be noted that even non-cash-convertible electronic money may constitute an exchange transaction and require registration a Funds Transfer Service Provider if it can be exchanged for cash-convertible electronic money. (2) Most Common Structures Example Settlement Structure a. 53
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