The Asia Internet Coalition (AIC) and its members wishes to express our sincere gratitude to Bank Negara Malaysia (BNM) for the opportunity to submit comments on BNM’s Exposure Draft on Merchant Acquiring Services.
First and foremost, we commend BNM for your efforts in publishing the Merchant Acquiring Service Exposure Draft. We take note that BNM is looking to expand its regulation and supervision over Qualified Acquirers and align the regulatory regime that applies to Qualified Acquirers with licensed financial institutions. We append with this letter herewith, our proposed comments and recommendations for your kind consideration, please.
We also wish to highlight that parts of the Exposure Draft (particularly Section 20) has followed through from the previous BNM Risk Management in Technology (RMiT) policy document. We are of the view that this section in particular maybe worth a relook and perhaps another round of consultations to better understand the operational issues related to RMIT.