(Prepared based on page 3 of the secretariat materials for the 1st Working Group on Regulations on Payment and Settlement and Regulations on Cross-Sectional Financial Services Intermediaries of the Financial System Council, held on October 4, 2019) (1) C to C (Transfer from the sender's account balance to the recipient's account): In this example, both the sender and the recipient have an account with the Funds Transfer Service Provider, and the funds are transferred between accounts. If the recipient converts their account balance to cash, they can pay it out into their personal bank account. (2) C to B (Recipient receives sales into their account): In this example, the customer purchasing goods and services (the sender, an individual) and the seller (the recipient, a company) each have an account with the Funds Transfer Service Provider, and the funds are transferred between the accounts. If the recipient converts their account balance to cash, they can pay it out into their personal bank account. (3) C to B (Recipient receives sales directly into their bank account): In this example, only the sender has an account with the Funds Transfer Service Provider, and the funds are transferred from the sender's funds transfer service account to the recipient's bank account. (4) B to C (Sender deposits an amount into their account in advance of sending to multiple recipients): In this example, the multiple recipients may include those having accounts with the Funds Transfer Service Provider and others without, so the sender deposits a certain amount into its own account with the Funds Transfer Service Provider and conducts remittances on demand. The recipients receive funds either into a funds transfer service account or a bank account. Funds Transfer Services The following services constitute "exchange transactions," and require registration as a Funds Transfer Service Provider (Articles 2 and 37 of PSA). Type 1 Funds Transfer Service Provider Upon registering as a Funds Transfer Service Provider and receiving authorization for its business implementation plan, a Type I Funds Transfer Services Provider can handle "large-amount" remittances of over 1 million yen (Article 37 and Article 40-2(1) of PSA). A Type 1 Funds Transfer Service Provider is not permitted to receive user funds without clear and specific remittance instructions (including the amount, date and recipient) or to hold user funds for longer than operationally and technically necessary (the period necessary to complete administrative procedures for the funds transfer) (Article 51-2 of PSA, Article 32-2 of the Funds Transfer Service Business Order). For this reason, a Type 1 Funds Transfer Service Provider cannot receive user funds into a funds transfer service account in cases such as the B to C remittance example above, where there are no specific remittance instructions. Likewise, in the case of a C to B remittance (where the recipient receives sales proceeds into its funds transfer service account), funds received from another person cannot be kept in the user’s account; this restriction on the retention of funds applies even in the case of remittances of less than 1 million yen per transaction as a Type I Funds Transfer Service. Type 2 Funds Transfer Service Provider A Type 2 Funds Transfer Service Provider can only conduct remittances of up to 1 million yen per transaction (Article 12-2(1) of the PSA Enforcement Order). It is possible for a user’s account balance with a Funds Transfer Service Provider to contain a large amount of funds, for example if the sender in a B to C remittance described above prepays a large amount in order to make multiple payments of less than 1 million yen each, or a recipient of C to B remittances (which receives 55
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