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---
title: "EBA Q&A 2023_6951 — Q&A — Requirement for loan agents to register [Rejected question]"
shortTitle: "EBA Q&A 2023_6951 — Q&A — Requirement for loan agents to register [Rejected question]"
answer_id: EBA_QA_2023_6951
status: "Rejected question"
type: qa
instrument_type: qa
authority: EBA
binding: false
binding_character: non_binding
legal_status: withdrawn
regulation: "PSD2"
psd2_level3: true
mica_level2: false
legal_basis: "Article 4(22) PSD2"
date: 13 February 2024
source_link: https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6951
lifecycle: "Rejected question"
text_version: "EBA Q&A register, 13 February 2024"
source_url: "https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6951"
check_status: matched
verified: true
last_checked: 2026-10-26
checked_against: "the EBA publication"
source:
  prepared_by: "not stated in the document"
  published_by: "EBA"
  published_in: "EBA Single Rulebook Q&A tool"
  evidence:
    prepared_by: "Other"
    locator: "EBA Q&A register entry 2023_6951: no answer; the register names only the 'Type of submitter'"
document_type: "qa_question"
legal_nature: "not_legislation"
addressees: "not stated in the document"
dates:
  published_on: "2024-02-13"
  question_submitted_on: "2023-12-21"
  locators:
    published_on: "EBA Q&A register entry 2023_6951, field 'Rejected publishing date'"
    question_submitted_on: "EBA Q&A register entry 2023_6951, field 'Submission date'"
lifecycle_label: "Rejected question"
---

**Question published in the EBA Q&A tool · no answer · not legislation · published 13 Feb 2024 [Rejected question]**

*Rejected question · EBA Q&A register, 13 February 2024 · Checked against the EBA publication on 26 Oct 2026 · [Official source](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6951)*

| | |
|---|---|
| **Full title** | EBA Q&A 2023_6951 — Q&A — Requirement for loan agents to register \[Rejected question\] |
| **Prepared by** | Not stated in the document |
| **Published by** | EBA, in the EBA Single Rulebook Q&A tool |
| **Reference** | EBA_QA_2023_6951 |
| **Document type** | Q&A |
| **Legal nature** | No answer · not legislation |
| **Addressees** | Not stated in the document |
| **Dates** | Published 13 February 2024; question submitted 21 December 2023 |
| **Legal basis** | Article 4(22) PSD2 |
| **Related instruments** | None recorded |
| **Text on this page** | Word for word — the full text of the EBA publication |

**Requirement for loan agents to register as payment service providers under EU's Second Payment Services Directive 2015/2366 ("PSD2").**

### Question

I would like some clarification on Directive 2015/2366/EU (PSD2) Article 4 paragraphh 22 - Money remittance.

If a firm performs administrative services (including but not limited to the calculation of interest/fees and principal owing between lenders and a borrower) and as part of this service is required to regularly transfer money between lenders and a borrower (no fee involved), does this qualify as money remittance? No fees are charged for the transfer of money.

### Background

This transfer of money is a small part of the services provided by a loan agent to a borrower. The movement of money is ancillary to the other parts of the loan administration business but it is a regular part of the functions. Loan agents are required as part of a triparty loan agreement to receive and forward on monies from lenders and borrowers as a third party. The independence of this third party is a key element to the transaction.

In the UK for instance, the FCA's guidance in its Perimeter Guidance Manual ("PERG"). PERG 15.22 (Question 9) explains that simply because a firm provides payment services as part of its business does not mean it requires authorisation or registration. Instead, firms have to be providing payment services, themselves, as a regular occupation or business to fall within the scope of the PSRs. The FCA goes on to state that this means that the services must be provided as a regular occupation or business activity in their own right and not merely as ancillary to another business activity.

Are you able to point me towards the position of national regulators on this matter so i can get a full picture of where a loan agent may operate with or without a license from a national regulator?

***

### Answer

This question has been rejected because it does not fulfil the formal criteria for submission. For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”.

***

**Source:** [EBA original document](https://www.eba.europa.eu/single-rule-book-qa/qna/view/publicId/2023_6951)

## Related Level 1 articles

- [Article 4 — Definitions](../../../articles/4.md)