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Romanian Association of Banks

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1. Chapter II, point 20 alin 2: From our understanding, SEPA transactions are assimilated to transfers of funds within the Union, even if the banks involved are not EU members. E.g. The Incomings from Switzerland can be treated as incomings from the EU.
Is this approach compliant with Regulation (EU) 2015/847?
In the case of SEPA incomings with the non-EU sender (eg Switzerland), the payee's PSP must detect the missing information on the payer's name + payer's account number + payer date / date and place of birth or only Missing name information Payer + payer account number?

2. Chapter II, point 33 - For the case when PSP of the payee decides to send reminder to the sending PSP, must it be within the terms of point 32 (3 days for the EU / 5 days for Non EU) or add another 3/5 days?
Is there a limited number for sending reminders?
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Regarding Non EU transfers, can we consider as “complete information regarding the payer” the following scenarios:
o “PO BOX” + Town+Country
o Building name + Town +Country
o Airport name +Country?
Rodica Tuchila