Invest & ISA - Account Funding Conditions Update

Thank you, my opinion is you’re correct. I was trying to find the official document from 2018, forgot regulations usually keep the same year and just get updated :joy: going to take a quick read

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Yes I think we were correct before, in my opinion. It is simply referring to not being able to charge more than it actually costs. See this section:

9.1 What can be charged
9.2 It is important that surcharges can only consist of costs borne by the payee/trader for use of the payment method in question. For card payments, the government considers that legitimate surcharges could include fees directly charged to the payee such as:
• The Merchant Service Charge, which companies pay to their payment service provider. This includes the interchange fee paid by the company’s payment service provider to the card issuer, the fees paid by the company’s payment service provider to the scheme (for example, Visa or Mastercard); and the margin retained by the company’s payment service provider to cover costs and profit; or
• The transaction/overhead fees paid by the company to intermediaries for some or all of the merchant services usually provided by the payment service provider. This is where an intermediary acts as a point of contact for companies and typically deals with the payment service provider, charging a mark-up on the payment service provider’s fees for the relevant services.
9.3 Importantly, the government’s intention is that the general costs of running a business not directly incurred in consequence of use of the payment method in question cannot be included in a surcharge. Consequently, indirect costs, such as general administrative overheads or staff training, equipment installations and set-up fees must not be included in any surcharge.
10.1 Calculating a surcharge
10.2 The amount of any surcharge must be limited to a fee not exceeding (under regulation 6A(2)) the costs borne by the payee for use of the specific payment instrument or (under regulation 4) the cost of the given means of payment. It follows that a payee / trader must be able to identify those costs derived directly from the payment service in question. Accordingly, the government’s intention is that costs must not be calculated on an average basis across two or more individual methods of payment (e.g., credit and debit cards together) and applied as a flat fee across those means of payment.
10.3 However, recognising the difficulty of calculating costs for specific transactions, the government considers it reasonable, within a single method of payment, for the payee / trader to impose its charge on an averaged basis (rather than a per-transaction basis). For example, the government would consider it acceptable for a payee / trader to impose a standard charge for a credit card transaction, based on average credit card transaction costs.
10.4 Depending on the circumstances, it might be appropriate for the payee/trader to make that surcharge on a flat fee basis or as a percentage of the headline price.

Seen as t212 has unpinned there own post relating to the upcoming change to the conditions for card transactions I thought I would post it here and see if someone in the @Team212 can actually answer

How have you overcome the laws in the uk banning credit debit card charges?

Like the leverage change- this chsnge appears to have been ā€˜snuck’ in via what feels like less that open and transparent business practice.

Things like this make me nervous when increasing the value of my investments on this platform.

Legitimate concern or being paranoid?

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I’m with you 100% there never seems to be a genuine offer anymore does there

It’s like you haven’t read the article you posted yourself. They can do this and it’s still free to deposit if you use instant open banking.

I used it today for the first time myself, set up in moments and my deposit was actually instant.

Although I do agree they should of added BACs and direct debit for auto invest users before they implemented this. As they did push auto invest pretty hard.

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@A_A Ideal then how can they do it? A global ban is a global ban

I’m not sure what your talking about as the charges aren’t due to be applied until January 2021

You can’t fund your isa in that way yet either so I think you need to read again and answer carefully

Are you referring to instant open banking method? This is available for ISA deposits.

Direct debit is far better than depositing via card anyway. Both are instant but at least you don’t have to worry about card details being leaked in any possible data hacks etc. I don’t see the issue with T212 covering what it costs them in allowing customers to do card deposits, I just hope they roll out auto invest direct debits as fast as possible

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More fees coming could be expected. No such thing as free lunch. The product stays solid anyway

@Lenos1980 As I read it, paragraphs 10.2, 10.3 and 10.4 answer the question of how it is proper that Trading 212 make these charges. I expect they have taken advice about what the regulations allow.

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Deposit into the CFD account for free and just transfer to the Invest/ISA accounts?

See above (20 chars)

That was changed again in 2018

Yes it clearly says last updated June 2018, what’s the problem? All the information in the document is accurate as of the last update

It states all businesses unless you operate outside of the EEA then the actual cost of the transaction is allowed to be charged. Seen as debit cards and credit cards have different charges these would still have to vary to be legal and as far as I’m aware t212 is inside the threshold for the EEA

Having read the guidance document it seems clear to me that T212 are able to charge transaction fees and use an averaged cost figure (sections 9,10)…

The guidance was subsequently updated in 2017 and 2018, but sections 9 & 10 still stand.

I’ve never seen another company manage to do it, or they all would.

As I’ve said if I’m wrong I’m wrong but why have t212 elected not to comment?