We support EBA´s general decision to take a broad approach to defining services related to a typical bank current account, which is focused by the PAD. However, the consumer should be able to understand and compare the services which are usually offered by bank payment account. Despite the broad approach taken by the EBA, these services should be still comparable to other accounts, which could have more limited payment functions. According Recital 12 of the PAD, “accounts with more limited functions should be excluded. For example, accounts such as savings accounts, credit card accounts where funds are usually paid in for the sole purpose of repaying a credit card debt, current account mortgages or e-money accounts should in principle be excluded from the scope of this Directive.” Account-based e-money products (e.g. prepaid IBAN cards in Italy) could have similar functionalities like a traditional bank payment account, e.g. cards related to a prepaid account with IBAN registration, which can be used for making credit transfers from the e-money account to traditional bank accounts or receiving funds from traditional bank accounts by third parties, which are not identical with the account holder. According Recital 12, this kind of account-based e-money products will fall within the scope of the PAD, which makes sense. In order to prevent the classification of legal requirements which are inherent to e-money and its definition as being typical bank account payment functionalities, which are subject to the PAD (place funds, withdraw cash and execute and receive payment transactions to and from third parties, including the execution of credit transfers), we suggest to exclude the following e-money specific features and legal requirements from the suggested “broad” definitions of standardized terminology for the most common services linked to a payment account:

• The required redemption of e-money according Art. 11 (2) of the Directive 2009/110/EU is not a “cash withdrawal
• Issuing e-money at par value on the receipt of funds according Art. 11 (1) of the Directive 2009/110/EU is not “placing funds in a payment account”.
• Transferring e-money from an e-money account to another e-money account hold at the same PSP is not a “credit transfer”.

These exclusions will prevent the not-intended inclusion of specific e-money products which are not offering comparable services of typical bank payment accounts.