ABI

Italian Banking Association

Interbank agreement for offering the additional optional service (AOS) of the SEPA Direct Debit Scheme named SEPA compliant Electronic Database Alignment (SEDA)

Release 3.0A September 30th 2014

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 0/41

ABI

Italian Banking Association

DOCUMENT UPDATES

Date

Release

Effective Date

07/08/2013

1.0

14 October 2013

24/12/2013

2.0

31 December 2013 ABI Communication n° 32 of 23 December 2013

13/03/2014

3.0

30/04/2014

3.0A

13 March 2014

Reference Documents Free network message (A97) of 08 August 2013

ABI Communication n° 10 of 12 March 2014

30 September 2014 ABI Communication n° 15 of 29 April 2014

NOTES: Release 1.0 Release 1.0 of this document has been prepared on the basis of the release 1.0 of the document “Functional Specifications” published on 28 December 2012 on the website www.sepaitalia.eu and has been updated with integrations related to the standardized framework contract and to the remuneration model. Release 2.0 Release 2.0 has been updated in order to align the document to the contents of the “Agreement for adherence to the SEDA service”. From an operating point of view, the current release has been also updated with: -

the attributes of the messages foreseen in the service remuneration model have been numerated;

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 1/41

ABI -

Italian Banking Association

Appendices I and II have been updated (the field Reference of the Underlying Contract is no more mandatory in compliance with the SEPA Direct Debit Core and B2B Scheme Rulebook).

Release 3.0 Release 3.0 has been updated in order to take in to account the following aspects: -

paragraphs 7 (Remuneration model) and 8 (Obligations and responsibilities) have been reviewed to be aligned to the contents of the Implementation Guidelines for the exchange of SEDA Remuneration Messages and to correct some misprints; changes related to the Tax identification number/VAT no. of the Debtor and to the Tax identification number of the subscriber and review of the forms for the subscription of SEPA Direct Debit mandates in the SEDA context; changes related to the AT-09 “The address of the Debtor” that is no more mandatory in accordance with the last release of the SEPA Direct Debit Core and B2B Scheme Rulebook.

Release 3.0A Release 3.0A includes some clarifications and the following changes: -

-

a prevision was inserted in paragraphs 6.2.4 (Request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP), 6.2.5 (Communication to amend mandate data initiated by the Debtor PSP) and 6.2.6 (Communication to cancel the mandate initiated by the Debtor PSP) in order to allow the Alignment PSP to transmit a negative response to the Debtor PSP in case it is not able to send the message received by the Debtor PSP to the Beneficiary due to formal errors; the equalisation of values “First” and “Recurrent” in the attribute AT-21 “The Transaction type” was provided for in paragraph 6.3 (Management of SEPA debit requests); Appendices I and II (mandate forms) to clarify that all the elements of the Creditor Address are mandatory.

Changes are highlighted in yellow.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 2/41

ABI

Italian Banking Association

INDEX 1

Introduction ......................................................................................................................................................... 5

2

Parties involved ................................................................................................................................................... 6

3

Agency relationship among PSPs ..................................................................................................................... 7

4

Operating modules ............................................................................................................................................. 8

5

Participation and master data .......................................................................................................................... 10

6

7

8

5.1

Participation by Payment Service Providers ................................................................................................... 10

5.2

Participation by Creditors ............................................................................................................................. 11

5.3

Amending and updating the Table of participating PSPs and master data .................................................... 13

Operating rules .................................................................................................................................................. 14 6.1

Direct debit mandate signed by the Debtor .................................................................................................... 14

6.2

Messaging and functionalities ........................................................................................................................ 15 6.2.1

Request for a new Direct Debit mandate signed by the Debtor and given to the Creditor ....................... 15

6.2.2

Request to amend mandate data initiated by the Creditor ..................................................................... 17

6.2.3

Request to cancel the mandate initiated by the Creditor ........................................................................ 18

6.2.4

Request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP ................ 19

6.2.5

Communication to amend mandate data initiated by the Debtor PSP .................................................. 20

6.2.6

Communication to cancel the mandate initiated by the Debtor PSP ...................................................... 21

6.3

Management of SEPA debit requests ........................................................................................................... 22

6.4

SEDA data set ........................................................................................................................................... 25 6.4.1

DS-01: The mandate .......................................................................................................................... 25

6.4.2

DS-02: The dematerialised mandate ................................................................................................... 26

6.4.3

DS-SEDA-01: Request for a new Direct Debit mandate signed by the Debtor ................................... 27

6.4.4

DS-SEDA-02: Request to amend mandate data initiated by the Creditor .......................................... 28

6.4.5

DS-SEDA-03: Request to cancel the mandate initiated by the Creditor.............................................. 28

6.4.6

DS-SEDA-05: Communication to amend mandate data initiated by the Debtor PSP........................ 29

6.4.7

DS-SEDA-06: Communication to cancel the mandate initiated by the Debtor PSP ........................... 29

6.4.8

DS-SEDA-04: Responses to messages initiated by the counterparty .................................................... 30

Remuneration model ........................................................................................................................................ 31 7.1

Determination and publication of the price .................................................................................................... 31

7.2

Count of active mandates and sending the “Forecast report” .......................................................................... 32

7.3

Payment of fees ............................................................................................................................................. 33

7.4

Detailed mandate reporting ........................................................................................................................... 34

Obligations and responsibilities...................................................................................................................... 36

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 3/41

ABI

Italian Banking Association

8.1

Obligations of the Alignment PSP................................................................................................................ 36

8.2

Obligations of the Debtor PSP ..................................................................................................................... 37

Appendix I: SEPA DIRECT DEBIT CORE mandate form............................................................................. 39 Appendix II: SEPA DIRECT DEBIT B2B mandate form................................................................................ 41

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 4/41

ABI

Italian Banking Association

1 Introduction SEDA is an additional optional service (“AOS”) of the Pan-European direct debit schemes (SEPA Direct Debit Core and SEPA Direct Debit Business to Business1) as defined by the Italian banking community in compliance with the rules set by the European Payment Council (EPC)2. This service has been developed in response to needs expressed by the representatives of companies participating the National Committee for Migration to SEPA3 (known by the Italian acronym CNM), wishing to incorporate the functionalities offered today by the RID Electronic Archives Alignment procedure of SITRAD (hereinafter referred to as the “AEA procedure”) into SEPA standards, in order to use the Pan-European direct debiting system with the same methods and service levels to those currently guaranteed by the RID domestic debit service. On the basis of CNM‟s recommendation, the Italian Banking Association (“ABI”) is the manager of the said AOS, is responsible in this capacity for coordinating activities for the definition and development of the SEDA service, and for participation in the service by Payment Service Providers (“PSPs”). Participating PSPs provide the service to Creditors on the basis of an executed contract, which is written according to a template, made available on the website www.sepaitalia.eu. This service is not offered to Creditors that belong to the category of consumers as defined in Italian Legislative Decree no. 206 of 6 September 2005 (the “Consumer Code”)4. PSPs offer the service in compliance with the terms and conditions laid out in this Interbank Agreement. Terms and conditions of this Interbank Agreement have been defined in line with: the provisions of EU regulation no. 260 of 14 March 2012 (art. 1, paragraph 3), hereinafter referred to as Regulation; the provisions of Bank of Italy Implementing Law of 12 February 2013 (articles 6 and 8), laying out instructions for applying the Regulation, hereinafter referred to as Implementing Law; the content of the Rulebooks of the SEPA Direct Debit Core (SDD Core) and Business to Business (SDD B2B) schemes, hereinafter referred to as Rulebooks.

It can be assessed in the future whether the scope of application of the SEDA service may be extended to any additional pan-European debit schemes that may be defined by the EPC. 2 To meet the specific needs of clients, the EPC recognises the possibility for individual Participants or communities of Participants to offer additional optional services (AOS) in addition to and in compliance with the basic Schemes. 3 The National Committee for Migration to SEPA (CNM) is the body - jointly monitored by the Bank of Italy and the ABI - which provides guidelines for and monitors the process of the national migration to SEPA. To ensure respect for multiple interests, representatives of all SEPA stakeholders participate in the CNM (business associations, the Public Administration, consumer associations, the post office). 4 “Consumer” is defined as a natural person who acts for purposes extraneous to any business, commercial, craft or professional activities carried out. 1

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 5/41

ABI

Italian Banking Association

2 Parties involved The following parties are involved in providing and using the SEDA service: Creditor – is the party, not belonging to the category of consumers, which uses SEPA direct debit services and the related SEDA service, as identified by one or more identification codes (“Creditor Identifiers”5). Alignment PSP - unique for each Creditor Identifier; is the PSP that: transmits/receives SEDA messages to/from Debtor PSPs on behalf of the Creditor; participates in the SDD Core Scheme and possibly in the SDD B2B Scheme as well; coincides with the (or one of the) PSP that also acts in the role of “Creditor PSP” for the Creditor (PSP that accepts the SEPA direct debit collections). Debtor PSP – is the PSP that participates in the SDD Core Scheme and possibly in the SDD B2B Scheme as well, to which the SEPA direct debits sent by Creditors participating in the service are addressed. Debtor – is the party that authorises SEPA direct debits on the account held at the Debtor PSP; at the choice of the Creditor, these debits may be managed in accordance with the rules of the SEDA service. The Debtor has no active role within the SEDA service. SEDA messages are exchanged through the parties qualified to operate in the role of Clearing Mechanisms (CMs) in the SEPA Direct Debit schemes. To carry out the functions associated with the transmission/receipt of SEDA messages, the PSPs that rely, under their own responsibility, on another party to offer the service (called Operative Intermediary) must report this circumstance, by qualifying their participation as “indirect” and specifying the information of the chosen Operative Intermediary.

The Creditor Identifier (corresponding to data element 2.7 of ISO 20022 standard “Creditor Scheme Identification”) consists of a code format with a maximum of 35 alphanumeric characters broken down as follows: from the 1st to 2nd position, the ISO code of the country in which the code was issued; from the 3rd to 4th position, the check digits calculated using the MOD97-10 algorithm (ISO7064); from the 5th to 7th position, the Business Code as indicated by the Creditor for its business needs (if not indicated, the default value „ZZZ‟ is used); from the 8th to 35th position, the national identification code. 5

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 6/41

ABI

Italian Banking Association

3 Agency relationship among PSPs PSPs wishing to offer the SEDA service to Creditors shall execute a contract to them through the Alignment PSPs who has authority to enter into the SEDA service agreement on their behalf by virtue of this provision that sets the agency relationship among the PSPs involved. In particular, the PSPs participating in the SEDA service, already chosen or which will be chosen by the Creditors to carry out the function of Alignment PSP, accept the role of agent and commit to implementing all activities associated with entering into the SEDA service agreement by using the Template available on the website www.sepaitalia.eu (hereinafter referred to as “Agreement for adherence to the SEDA service”), in the name and on behalf of each principal, who are all the PSPs time to time published on the “Table of participating PSPs”). The agency relationship is free of charge and granted in the exclusive interest of each principal. The agent is vested with direct and exclusive representation of each principal in relation to the Creditor and third parties for the transactions strictly required to enter into the SEDA service agreement. The agency relationship becomes effective on the date of each principals adherence to the SEDA.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 7/41

ABI

Italian Banking Association

4 Operating modules The SEDA service is an additional service of the SEPA Direct Debit service, and it is offered through two different operating modules: the “Basic” and the “Advanced” module. The “Basic” module allows the Creditors of SEPA Direct Debits to: send - through an electronic communication with its own PSP (“Alignment PSP”), which in turn communicates with the PSPs to which the direct debits are destined (“Debtor PSPs”) - the information about the mandates acquired; send and receive information about any amendments or cancellations of mandates to/from Debtor PSPs using the same electronic communication process; obtain a confirmation of the existence and chargeability of the Debtor‟s account before sending the first direct debit collection and decrease errors in debit management through consistency checks that the Debtor PSPs will conduct between the information present in the debit request and the information recorded in the mandate archive. In particular, Creditors that adhere to the “Basic” module can receive and transmit the following messages and the associated responses: “Request for a new Direct Debit mandate signed by the Debtor and given to the Creditor”; “Request to amend mandate data initiated by the Creditor”; “Request to cancel the mandate initiated by the Creditor”; “Communication to amend mandate data initiated by the Debtor PSP”; “Communication to cancel the mandate initiated by the Debtor PSP”. The “Advanced” module supplements the functionalities of the “Basic” module by giving the possibility to the Creditor to delegate to the Debtor PSPs the activities connected with the acquisition and storage6 of the mandates signed by the Debtor at its PSP (the so called Debtor Bank Mandate Flow or DMF scheme - not provided in the SDD Schemes). The additional message foreseen within the “Advanced” SEDA module is: “Request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP”. The SEDA service applies for all mandates (and associated direct debits) relating to a Creditor Identifier of the Creditor participating in the SEDA service, that are registered in the archive of the Debtor PSPs which are also participants. The definition of mandate, and therefore the scope of application of the SEDA service, also includes direct debit authorisations issued in compliance with domestic schemes which, by virtue of what is expressly laid out in art. 7, paragraph 1 of the Regulation, shall remain valid during the transition to Pan-European Direct Debit schemes7. The service is provided through the “Basic” module when the Creditor adheres to that module. See art. 5, paragraph 3, letter a), point ii) of the Regulation: “the payee’s PSP must ensure that the payer gives consent both to the payee and to the payer’s PSP (directly or indirectly via the payee), the mandates, together with later modifications or cancellation, are stored by the payee or by a third party on behalf of the payee and the payee is informed of this obligation by the PSP in accordance with Articles 41 and 42 of Directive 2007/64/EC”. 7 For debit authorisations issued in Italy (called RID mandates), migration to SEPA Direct Debit schemes takes place based on the rules described in ABI Circular - technical series no. 10 of 23 April 2013. 6

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 8/41

ABI

Italian Banking Association

The service is provided through the “Advanced” module when the Debtor PSP and the Creditor adhere to that module

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 9/41

ABI

Italian Banking Association

5 Participation and master data 5.1

Participation by Payment Service Providers

All PSPs participating in the SDD Core Scheme can adhere to the SEDA service. For PSPs, participation in the SEDA service entails offering the service at least in the role of Debtor PSP. Offering the SEDA service in the role of Alignment PSP is possible for all participating PSPs that also act as Creditor PSP for a specific Creditor. All ABI-associated PSPs participating in the SDD Core Scheme8 must participate in the “Basic” module of the SEDA service. Participation in the “Advanced” module is optional for all PSPs. PSPs that offer the service as Alignment PSP provide this service to Creditors based on the “Basic” or “Advanced” operating module chosen by the Creditor. Debtor PSPs participating in the SDD B2B Scheme also offer the “Basic” or “Advanced” SEDA service for mandates referred to the aforementioned Scheme. The list of PSPs participating in the SEDA service (“Table of participating PSPs”) is available on the website www.sepaitalia.eu. A specific procedural master data of the participating PSPs, named SED000, is used to manage and route messages. In the service‟s initial phase, this master data is managed by SIA9 since it also manages the registers currently used for the domestic debit procedure. The SED000 master data comply with the population, access and distribution rules of the master data currently in use for the domestic procedures, as described in detail in the document SIA RI ANA 001 available on the website techinfo.sia.eu. In order to participate in the SEDA service, PSPs must provide the following information in compliance with the methods announced from time to time on the website www.sepaitalia.eu: a) company name, ABI code and BIC code10; b) adherence date11; c) direct or indirect participation mode12 and, for indirect participation, company name and ABI Executive Committee Resolution of 17 April 2013. SIA‟s management of the SED000 record may be reconsidered (confirmed or changed) by sending a notice 6 months in advance. 10 So it can be registered, the PSP indicates only one BIC 11 characters long (for 8-character BIC codes, the conventional rule of inserting “XXX” as the last 3 characters must be observed). 11 For all ABI associates that participate in the SEPA Direct Debit Core Scheme, adherence to the “Basic” SEDA module is required beginning on 14 October 2013. 12 The direct participant independently carries out the application activities associated with the transmission/receipt of flows to/from the interbank network in the role of Debtor PSP/Alignment PSP and, possibly, Intermediary PSP on behalf of other indirect participants. The indirect participant delegates the functions associated with the transmission/receipt of flows to/from the interbank network in the role of Debtor PSP/Alignment PSP to a direct participant. 8 9

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 10/41

ABI d) e) f) g) h)

Italian Banking Association

BIC code of the Operative Intermediary; company name and BIC code of the Clearing Mechanism (CM); participation in the SDD Core and/or SDD B2B Scheme; adherence to the “Basic” or “Advanced” module; maximum quarterly price applied for each active mandate acquired and stored at the Creditor; maximum quarterly price applied for each active mandate acquired and stored at the Debtor PSP.

The Table of participating PSPs provides the information referred to in letters a), b), e), f), g) and h) above. The SED000 master data includes the information referred to in letters a), b), c), d) and f) above, as well as any withdrawal date and the ABI code/company name of the incoming PSP.

5.2 Participation by Creditors Creditors that use SEPA Direct Debit services may optionally participate in the SEDA service. In order to participate, Creditors must enter into the “Agreement for adherence to the SEDA service”, available on the website www.sepaitalia.eu, with the Alignment PSP (which signs the agreement in the name and on behalf of itself and of the Debtor PSPs participating in the SEDA service) and provide the following information: the Creditor Identifier code(s) that they will use to be uniquely identified within the operations of the SEDA service13; the operating module of participation in the service (“Basic” module or “Advanced” module) for each of the Creditor Identifier codes indicated; IBAN of the account held at the Alignment PSP against which the Debtor PSPs participating in the service are allowed to send SEPA Direct Debit collections relating to fees due by the Creditor for using the SEDA service. Participation by Creditors will be noted within specific procedural master data named CRI000, also initially managed by SIA for the reasons already mentioned with respect to the SED000 master data. Creditors that participate in the SEDA service must be included in the CRI000 master data in order to participate in the service. In fact: SEDA service messages may be exchanged only if those messages come from or are sent to a valid Creditor Identifier code recorded in the CRI000 master data; the controls established by the SEDA service when receiving SEPA Direct Debit collections are carried out by the Debtor PSPs only if the Creditor Identifier code indicated in the direct debit collection is valid and listed in the CRI000 master data.

It is clarified that Creditors may participate in the service using a Creditor Identifier code not generated in Italy. Creditor Identifiers not generated in Italy are registered in the CRI000 Record based on the same rules as those used to register Italian Creditor Identifiers. Please also note that SIA has automatically generated a “proposed” Italian Creditor Identifier code for all companies participating in the domestic AEA-RID procedure, for which information relating to the company‟s tax identification number is available in the RAC procedure. 13

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 11/41

ABI

Italian Banking Association

CRI000 includes the following information for each Creditor Identifier participating in the SEDA service14: a) company name of the Creditor; b) address of the Creditor; c) SIA code of the Creditor; d) participation in the “Basic” or “Advanced” SEDA module; e) adherence date; f) BIC of the Alignment PSP (unique for each individual Creditor Identifier code); g) date of adherence and possibly of withdrawal by the Alignment PSP (including an incoming BIC in the case of withdrawal); h) IBAN indicated by the Creditor to be used by Debtor PSPs to charge the SEDA service fee15. Data is populated in the CRI000 master data by the Alignment PSP using the SITRAD RAC procedure (“Companies” and “Alignment” segments) based on the methods and timing defined in the following documentation available on the website techinfo.sia.eu: SIA-RI- RAC-001 AZI, SIA-RI-RAC-003 AZI, SIA-RI-RAC MODCAR AZI, SIA-RI-RAC-001 Align, SIA- RI-RAC003 Align, SIA-RI-RAC MODCAR Align. The CRI000 master data is distributed based on the rules set forth in the document SIA-RIANA 001, also available on the website techinfo.sia.eu. By participating in the SEDA service, Creditors enter into a contractual relationship with all participating Debtor PSPs by virtue of the agency mandate granted by all participating Debtor PSPs to the Alignment PSPs16. However, Creditors are entitled not to use the service provided by one or more specific Debtor PSPs and to stop using the SEDA service for certain mandates at any time: the participating Creditor that does not intend to use the service for mandates that will be signed by Debtors after its adherence to the SEDA service must identify such mandates using a Creditor Identifier code not registered in the CRI000 master data; the participating Creditor that does not intend to use the service for mandates issued at Debtor PSPs with a Creditor Identifier registered in the CRI000 master data must send the Debtor PSPs a “Request to amend Request to amend mandate data initiated by the Creditor” to change the Creditor Identifier code from a code registered in CRI000 to a code not registered in CRI000; the Creditor that decides, after its adherence to the service, to use it for certain mandates that have a Creditor Identifier code not registered in CRI000, must send the Debtor PSPs a “Request to amend mandate data initiated by the Creditor” to change the Creditor Identifier code from a code not registered in CRI000 to a code registered in CRI000. Creditors are also entitled to withdraw from the SEDA service at any time in relation to a specific Creditor Identifier. Withdrawal is carried out by deleting the Creditor Identifier code from the CRI000 master data, after which the PSPs (Alignment and Debtor) will stop transmitting and The Creditor Identifier codes of non-profit organisations participating in the “RID anch‟io” initiative (see ABI circular letter of 4 August 2006 Prot. SP (OC/OF004347)) are also registered in the CRI000 record. Such organisations do not necessarily participate in the SEDA service. 15 The IBAN indicated by the Creditor identifies an account at the Alignment PSP. 16 See par. 3 (Granting the agency mandate between PSPs). 14

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 12/41

ABI

Italian Banking Association

sending SEDA messages. By virtue of this withdrawal, the Debtor PSPs also stop carrying out the controls established by the SEDA service on direct debit collections (which will be managed without interruption in compliance with the rules set by the SEPA Direct Debit Core or B2B Scheme Rulebooks).

5.3 Amending and updating the Table of participating PSPs and master data The PSPs are entitled to announce any changes in participation that could occur in relation to: change in the operating module for providing the service (“Basic” or “Advanced” module); change in the participation mode (direct or indirect); amendment of maximum prices applied; choice of a new Clearing Mechanism; choice of a new Operative Intermediary; withdrawal from the SEDA service (e.g., during merger/incorporation procedures). If a PSP withdraws from the SEDA service, an incoming PSP may be indicated. By virtue of this withdrawal, the PSPs do not offer the service in the role of either Debtor PSP or Alignment PSP. The aforementioned changes must be announced by the PSPs in compliance with the methods and deadlines published from time to time on the website www.sepaitalia.eu. Updates to the SED000 procedural master data also follow the rules defined in the document SIA-RI-ANA 001 available on the website techinfo.sia.eu. The “Table of participating PSPs” and the SED000 procedural master data are updated on a monthly basis. Creditors are entitled to report, through the Alignment PSP, any changes in participation that may involve: change in the operating module for using the service (“Basic” or “Advanced” module); choice of a new Alignment PSP; change in the IBAN of the account to be debited for the SEDA service fee; change in the Creditor Identifier code(s) registered; withdrawal from the service. These changes must be reported by the Alignment PSP using the SITRAD RAC procedure (“Companies” and “Alignment” segments) based on the methods and timing defined in the following documentation available on the website techinfo.sia.eu: SIA-RI-RAC-001 AZI, SIARI-RAC-003 AZI, SIA-RI-RAC MODCAR AZI, SIA-RI-RAC-001 Align, SIA-RI-RAC-003 Align, SIA-RI-RAC MODCAR Align.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 13/41

ABI

Italian Banking Association

6 Operating rules This paragraph describes the service‟s operating rules, the types of messages available (“Dataset”) and the information (“Attributes”) required within these messages. SEDA interbank messages: are managed with the same infrastructures used by PSPs for SDD Schemes, under a system of interoperability between Clearing Mechanisms (CMs); comply with the exchange and intermediation rules established for the same Schemes (although the PSPs are entitled to rely on Clearing Mechanisms and operative intermediaries other than those that may have been chosen for adherence to the SEPA Schemes); are exchanged using the File transfer transmission method, based on the ISO 20022 standard “Payments Mandate” (XML language). The interbank messages described in this paragraph are subject to the rules set by the document “Implementation Guidelines and Interoperability Agreement between Clearing Mechanisms (CMs)”, which describes the technical rules of the procedure used by Clearing Mechanisms (CMs) to exchange SEDA messages.

6.1 Direct debit mandate signed by the Debtor The SEPA debit Schemes establish that the mandate filled out on paper and signed by the Debtor or, alternatively, filled out electronically and signed in a secure manner, must be transmitted to the Creditor. The Creditor is responsible for storing the original mandate along with any amendments that may be made to the mandate for its entire period of validity. The mandate is stored after it is cancelled in compliance with what is laid out in domestic regulations and in compliance with the deadlines by which the Rulebooks establish that the Debtor is allowed to request reimbursement of a direct debit associated with an unauthorised mandate. The mandate must comply with the instructions set by the EPC. In particular, for both SDD schemes (Core and B2B), the mandate is required to have a clear heading entitled “SEPA Direct Debit Mandate”. (with the addition of “Business-to-Business” for that type of mandate) and must contain the following attributes: Unique Mandate reference Name of the Debtor Debtor‟s account number IBAN Creditor company name Creditor‟s identifier Address, city and postal code of the Creditor Country of the Creditor Type of payment (“Recurrent” or “One-off”) Signature place and time Signature(s).

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 14/41

ABI

Italian Banking Association

Mandates issued in favour of Creditors participating in the SEDA service must follow the following instructions in addition to the rules set by the SDD Scheme Rulebooks: a) the Debtor‟s identification code number must be obtained; b) it is also possible to include the personal data (surname, name and identification code) of the party that signed the mandate if different from the Debtor. The identification code of the Debtor and/or of the party that signed the mandate must be acquired so the Debtor PSP can verify that operations may be carried out on the account of the party that issued the mandate. For participation in the “Advanced” module, the Creditor must provide the Debtor with all information for which it is responsible that is needed to issue the mandate at the Debtor PSP: Unique Mandate reference Creditor company name Creditor‟s identifier Address, city and postal code of the Creditor Country of the Creditor Type of payment (“Recurrent” or One-off”) If such information is not provided, the Debtor PSP cannot acquire the mandate. Appendices I and II include the mandate forms that Creditors participating in the SEDA service (and, for the “Advanced” module, participating Debtor PSPs) must use to obtain the SEPA Direct Debit Core and SEPA Direct Debit B2B Mandates, respectively. The layout of those forms may be customised, but they must contain the mandatory information. For extensive and more precise information on mandatory elements of the mandate and possible layouts, please refer to the document “Guidelines for the Appearance of Mandates” published on EPC‟s website.

6.2 Messaging and functionalities The messages that may be exchanged through the SEDA service are described below, along with the rules and controls to be carried out by the PSPs when receiving/sending such messages. Any reference to business days shall refer to the Target calendar.

6.2.1 Request for a new Direct Debit mandate signed by the Debtor and given to the Creditor This process is initiated by the Creditor after the Debtor has signed the mandate to request that the Debtor PSP activate the mandate itself.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 15/41

ABI

Italian Banking Association

Figure 1 – Description of flow for issuing and validating a mandate - Creditor side

1. The Creditor acquires the mandate signed by the Debtor (dataset – DS 01). 2. The Creditor dematerialises and files the information on the mandate in its archive (dataset – DS 02). 3. After receiving the mandate from the Debtor, the Creditor sends the Alignment PSP a SEDA message containing the information on the mandate (dataset – DS-SEDA 01). 4. The Alignment PSP sends the Debtor PSP a SEDA message containing the information of the mandate (dataset – DS-SEDA 01). 5. The Debtor PSP performs the following minimum required controls on the information received: that the mandate received is not already present and active17 in its archive; that the IBAN provided by the Debtor identifies an active account that can be debited18 through SDD; that the party that signed the mandate is entitled to carry out operations on the debit account; that the mandate scheme code (AT-20 – Core, B2B, other Schemes) is compliant with the debit account classification. 6. For B2B mandates, after receiving the alignment flow, the Debtor PSP obtains confirmation of the mandate data pursuant to the provisions of the SEPA B2B Scheme Rulebook and according to methods established with its client (including transmission of a copy of the mandate immediately after it is signed). 7. If the verifications have a positive outcome, the Debtor PSP activates the mandate in its archive by using the following attributes of the SEDA message received as unique key: i. The unique Mandate reference (AT-01); ii. The identifier of the Creditor (AT-02), excluding the business code19; iii. The identification code of the Scheme (AT-20 - Core, B2B, other schemes). If the mandate is present but inactive, the Debtor PSP shall reactivate it upon receipt of this new request message. “Chargeability” includes the debit limitations that the debtor may choose pursuant to Regulation no. 260/2012. 19 Please note that although the business code is not used to create the unique mandate key, the Debtor PSP records attribute AT-02 “Creditor Identifier” in the archive including the business code component. That element is relevant to the management of mandates and SEDA direct debits. 17 18

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 16/41

ABI

Italian Banking Association

8. The Debtor PSP transmits the SEDA message containing the results of the verifications conducted to the Alignment PSP within five business days from the date of receipt of the request message (dataset – DS-SEDA 04). 9. The Alignment PSP transmits the SEDA results message received from the Debtor PSP to the Creditor (dataset – DS SEDA 04). The mandate is deemed active beginning on the business day subsequent to that on which the positive results message transmitted by the Debtor PSP is sent.

6.2.2 Request to amend mandate data initiated by the Creditor This process is initiated by the Creditor to communicate the Debtor PSP amendments to the mandate agreed between the Creditor and the Debtor, in relation to changes to the unique mandate key (unique mandate reference and/or Creditor identifier) or to the name of the Creditor.

Figure 2 - Definition of mandate amendment flow - Creditor side

1. The Creditor manages the amendment of the mandate with the Debtor. 2. The Creditor dematerialises and files amendments made to the mandate in its archive (dataset – DS 02). 3. The Creditor sends the Alignment PSP a SEDA message containing the information on the amendment of the mandate (dataset – DS-SEDA 02). 4. The Alignment PSP sends the Debtor PSP a SEDA message containing the information on the amendment of the mandate (dataset – DS-SEDA 02). 5. After receiving a “Request to amend mandate data initiated by the Creditor”, the Debtor PSP checks that: the original unique mandate key is present in its archive; the Creditor Identifier indicated in the request (including the business code) is the same recorded in the archive for that mandate20; The Creditor Identifier AT-02 (including the business code) filled out in this amendment message must coincide with the identifier present in the archived mandate; if there is a specific change in the Creditor identifier, it must be 20

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 17/41

ABI

Italian Banking Association

the attribute being changed coincides with the corresponding archived information. 6. For B2B mandates, after receiving the alignment flow, the Debtor PSP obtains confirmation of the mandate data according to the provisions of the SEPA B2B Scheme Rulebook and according to methods established with the client (including transmission of a copy of the amendment) when the changes concern: i) the unique mandate reference, ii) the Creditor Identifier. 7. If the verifications have a positive outcome, the Debtor PSP modifies the data of the mandate in its archive effective starting on the business day subsequent to the clearing day on which the results message pursuant to the point below is sent. 8. The Debtor PSP transmits the SEDA message containing the results of the verifications conducted to the Alignment PSP21 within five business days from the date of receipt of the mandate data amendment flow (dataset – DS-SEDA 04). 9. The Alignment PSP transmits the SEDA results message received from the Debtor PSP to the Creditor (dataset – DS SEDA 04). The mandate data amendment is deemed valid beginning on the business day subsequent to that on which the positive results message transmitted by the Debtor PSP is sent.

6.2.3 Request to cancel the mandate initiated by the Creditor This procedure is initiated by the Creditor to communicate to the Debtor PSP the cancellation of mandates managed through the SEDA service.

Figure 3 - Definition of mandate cancellation flow - Creditor side

1. The Creditor manages the cancellation and revocation of the mandate with the Debtor; 2. The Creditor dematerialises and files in its archive the information related to the verified whether the amended Creditor identifier (including the business code) coincides with the identifier present in the archived mandate. 21 If the Creditor Identifier (AT-02) is amended via this amendment message, and the new Creditor identifier is not registered in the table of participants, the Debtor PSP indicates in the response message the amended Creditor identifier and transmits the message to the Alignment PSP associated with it. Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 18/41

ABI 3. 4. 5. 6. 7. 8.

Italian Banking Association

cancellation of the mandate. The Creditor sends the Alignment PSP a SEDA message for cancellation of the mandate (dataset – DS-SEDA 03); The Alignment PSP sends the Debtor PSP the SEDA message for cancellation of the mandate (dataset – DS-SEDA 03); The Debtor PSP verifies whether the cancelled mandate, identified by its unique key, is present in its archive; If the verifications have a positive outcome, the Debtor PSP cancels the mandate in its own archive effective starting on the business day subsequent to the date of receipt of the communication sent by the Creditor; The Debtor PSP transmits the SEDA results message to the Alignment PSP within five business days only if, following the verifications performed, it finds that the mandate is not present in its archive (dataset – DS-SEDA 04); The Alignment PSP forwards the result to the Creditor in a SEDA message if the Debtor PSP confirms that the mandate does not exist (dataset – DS-SEDA 04).

The mandate is deemed cancelled and therefore no longer active beginning on the business day subsequent to the date of receipt of the request by the Debtor PSP.

6.2.4 Request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP This process is initiated by the Debtor PSP participating in the “Advanced” module, to notify the Creditor, through the Alignment PSP, registered in the table of SEDA participants, of the new mandates acquired by the Debtor PSP on behalf of the Creditor that adopts the “Advanced” module.

Figure 4 – Definition of the flow for issuing and validating a Mandate - Debtor PSP side

1. The Debtor PSP acquires the mandate signed by its client (dataset - DS-01) after verifying that the mandate includes a Creditor Identifier (AT-02), including the business code, identified in the CRI000 master data as an “Advanced” SEDA module participant. Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 19/41

ABI

Italian Banking Association

2. The Debtor PSP carries out the verifications indicated in paragraph 6.2.1 (point 5). 3. If the verifications have a positive outcome, the Debtor PSP creates an entry in its archive and registers the mandate information, using the following mandate attributes as a unique key: i. The unique Mandate reference (AT-01); ii. The identifier of the Creditor (AT-02), excluding the business code22; iii. The identification code of the Scheme (AT-20 - Core, B2B, other schemes). 4. The Debtor PSP sends the SEDA new request message to the Alignment PSP of the Creditor registered in the table of SEDA participants (dataset – DS-SEDA 01). 5. The Alignment PSP sends the Creditor the SEDA message regarding the new mandate (dataset – DS-SEDA 01). If the Alignment PSP is not able to send the SEDA message regarding the new mandate to the Beneficiary due to formal errors, it sends a negative response to the Debtor PSP (dataset – DS-SEDA 04). 6. The Creditor files the dematerialised information received. If the request is not successful, it sends the response message to the Alignment PSP within five business days (dataset – DS-SEDA 04). 7. The Alignment PSP transmits the response message to the Debtor PSP. If there is no negative response message from the Creditor, the mandate must be deemed active in any event (dataset – DS-SEDA 04). The mandate is deemed active beginning on the sixth business day subsequent to the date on which the request is sent by the Debtor PSP.

6.2.5 Communication to amend mandate data initiated by the Debtor PSP This process is initiated by the Debtor PSP to notify the Creditor, through the Alignment PSP, of changes in the debit account information (IBAN) due to reorganisation processes between PSPs23 or of changes in the account provided by the Debtor within the same PSP.

Please note that the business code is not used to create the unique mandate key, but the Debtor PSP records attribute AT-02 “Creditor Identifier” in the archive including the Business Code component. 23 For example, due to mergers/acquisitions or following the sale or acquisition of branches by the Debtor PSP. 22

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 20/41

ABI

Italian Banking Association

Figure 5 - Definition of mandate amendment flow - Debtor PSP side

1. The Debtor or its PSP determines the change in the debit account information (IBAN). 2. The Debtor PSP updates its archive of mandates (dataset – DS-02). 3. The Debtor PSP sends the Alignment PSP the mandate amendment message (dataset – DS-SEDA 05). 4. The Alignment PSP sends the Creditor the mandate amendment message (dataset – DSSEDA 05). If the Alignment PSP is not able to send the SEDA message regarding the amendment of the mandate to the Beneficiary due to formal errors, it sends a negative response to the Debtor PSP (dataset – DS-SEDA 04). 5. The Creditor files the dematerialised information received. 6. The Creditor sends the Alignment PSP the SEDA results message within five business days only if, following the verifications performed, it is found that the mandate does not exist in its archive (dataset – DS-SEDA 04). 7. The Alignment PSP sends the Debtor PSP the SEDA results message received (dataset – DS-SEDA 04). The mandate is deemed amended beginning on the sixth business day subsequent to the date on which the request is sent by the PSP.

6.2.6 Communication to cancel the mandate initiated by the Debtor PSP This process is initiated by the Debtor PSP to notify Creditor, through the Alignment PSP, of cancellations or revocations of mandate originated by the same PSP or by the Debtor, for any reason (e.g., withdrawal of PSP authorisation, closure of the account, death, closure of the account to SDD debit requests, etc.).

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 21/41

ABI

Italian Banking Association

Figure 6 - Definition of mandate cancellation flow - Debtor PSP side

1. The Debtor or its PSP establishes the cancellation of the mandate. 2. The Debtor PSP updates its archive of mandates effective starting on the business day subsequent to the day on which the SEDA message is sent. 3. The Debtor PSP sends the Alignment PSP the SEDA message for cancellation of the mandate (dataset – DS-SEDA 06). 4. The Alignment PSP sends the Creditor the SEDA message for cancellation of the mandate (dataset – DS-SEDA 06). If the Alignment PSP is not able to send the SEDA message regarding the cancellation of the mandate to the Beneficiary due to formal errors, it sends a negative response to the Debtor PSP (dataset – DS-SEDA 04). 5. The Creditor files the dematerialised information received. 6. The Creditor transmits the SEDA results message to the Alignment PSP within five business days of receipt of the request only if, following the verifications performed, it is found that the mandate does not exist in its archive (dataset – DS-SEDA 04). 7. The Alignment PSP sends the Debtor PSP the SEDA results message received (dataset – DS-SEDA 04). The mandate is deemed cancelled and therefore no longer active beginning on the business day subsequent to the date on which the notice is sent by the Debtor PSP.

6.3 Management of SEPA debit requests The process of collecting a SEPA Direct Debit is initiated by the Creditor. If the direct debit collections report a Creditor Identifier referring to a Creditor that participates in the SEDA service, the receiving Debtor PSP carries out the specific controls described below.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 22/41

ABI

Italian Banking Association

Figure 7 - Definition of controls for SEPA Direct Debit collections

1. The Creditor sends the SEPA Direct Debit collection to the Creditor PSP. 2. The Creditor PSP sends the SEPA Direct Debit collection to the Debtor PSP. 3. At the reception of the SEPA Direct Debit collection, the Debtor PSP checks for the presence of the Creditor Identifier (attribute AT-02), including the Business Code, in the master data of SEDA service participants (CRI000). If the Creditor Identifier (AT-02), including the Business Code, is included in the master data of SEDA service participants (CRI000), the Debtor PSP uses the unique mandate key indicated in the direct debit collection to access the archive and find the corresponding entry. If the Debtor PSP does not find a corresponding active mandate in its archives, it rejects the direct debit collection; if, on the other hand, the PSP finds the corresponding active mandate, it carries out at least the following controls:  verification that no notice of amendment (attribute AT-24) of the mandate data is indicated in the direct debit collection. If that indication is present, it does not make any change and rejects the direct debit collection24 (any mandate amendments must be reported by the Creditors participating in SEDA using the message “Request to amend mandate data initiated by the Creditor” referred to in the Operating Rules paragraph);  verification that the business code indicated in the direct debit collection coincides with the code recorded in the mandate. If the control has a negative result, it rejects the direct debit collection;  verification that the scheme code indicated in AT-20 (Core, B2B, other Schemes) is compliant with the debit account classification. If the control has a negative result, it rejects the direct debit collection. In the SEDA context the values “First” and “Recurrent” in the attribute AT-21 “The

As an exception to this general principle, in the first SEPA direct debit collection associated with a RID mandate to be converted to a SEPA mandate, it is possible to assign a value to the attribute AT-24 “The reason for amendment of the Mandate” to amend only the mandate identification code (AT-01 “The unique Mandate reference”). 24

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 23/41

ABI

Italian Banking Association

Transaction Type” are considered equivalent25. It follows that in case of errors regarding the usage of the values “First” and “Recurrent”, the Debtor PSP must not reject the direct debit collection26. If all of the above controls have a positive result, the Debtor PSP performs the debit on the IBAN associated with the mandate recorded in the archive.

25

In compliance with the SDD Core and B2B Scheme Rulebooks, the usage rules for the values “Last” and “Oneoff” are unchanged. 26 This approach is based on the fact that in SEDA any additional checks carried out by the Debtor PSP when acquiring a “First” direct debit collection are performed in advance during the alignment phase. Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 24/41

ABI

Italian Banking Association

6.4 SEDA data set 6.4.1 DS-01: The mandate Description: indicates the information present in the mandate signed by the Debtor and sent to the Creditor. The attributes listed correspond to those provided in the SDD Rulebooks; attribute AT-S1 has been introduced in relation to the particular functionalities of SEDA. These attributes are mandatory unless otherwise indicated. Attributes AT-01 The unique Mandate reference AT-14 The name of the Debtor AT-09 The address of the Debtor (Optional) AT-27 Debtor identification code (Optional) AT-15 The name of the Debtor Reference Party (Optional) AT-37 The identification code of the Debtor Reference Party (Optional) AT-07 The account number (IBAN) of the account of the Debtor to be debited AT-08 The identifier of the underlying contract AT-13 The BIC code of the Debtor Bank (Optional)27 AT-02 The identifier of the Creditor AT-03 The name of the Creditor AT-38 The name of the Creditor Reference Party (Optional) AT-39 The identification code of the Creditor Reference Party (Optional) AT-05 The address of the Creditor AT-25 The date of signing of the mandate AT-21 The Transaction Type28 AT-S1 The identification code of the subscriber29. AT-27 corresponds to the “Identification code of the Debtor” of the hard-copy mandate if the Debtor is not the party that signed the mandate. AT-S1 corresponds to the “Identification code of the Debtor” of the hard-copy mandate if the Debtor is the party that signed the mandate. AT-S1 corresponds to the “Identification code of the subscriber” of the hard-copy mandate if the Debtor is not the party that signed the mandate.

After 1 February 2014 for domestic payments and after 1 February 2016 for cross-border payments, PSPs do not ask the USPs to indicate the BIC of the debtor PSP or of the creditor PSP (art. 5, paragraph 7 of EU Regulation no. 260/2012). 28 The values “Recurrent” and “One-off” are indicated. 29 The situation of accounts requiring joint signatures, for which it may be necessary to ask the EPC and the ISO to supplement the messaging standard, shall be analysed in further detail. 27

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 25/41

ABI

Italian Banking Association

6.4.2 DS-02: The dematerialised mandate Description: indicates the business information that must be dematerialised by the Creditor or, in the “Advanced” module, by the Debtor PSP on behalf of the Creditor, in order to use the SEDA functionalities for domiciliation of a new mandate. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service); attribute AT-S1 has been introduced in relation to the particular functionalities of SEDA. These attributes are mandatory unless otherwise indicated. Attributes AT-01 The unique Mandate reference AT-14 The name of the Debtor AT-09 The address of the Debtor (if present in DS-01) AT-27 Debtor identification code (if present in DS-01) AT-15 The name of the Debtor Reference Party (if present in DS-01) AT-37 The identification code of the Debtor Reference Party (if present in DS-01) AT-07 The account number (IBAN) of the account of the Debtor to be debited AT-08 The identifier of the underlying contract AT-13 The BIC code of the Debtor Bank (if present in DS-01) AT-02 The identifier of the Creditor AT-03 The name of the Creditor AT-38 The name of the Creditor Reference Party (if present in DS-01) AT-39 The identification code of the Creditor Reference Party (if present in DS-01) AT-05 The address of the Creditor AT-25 The date of signing of the mandate AT-16 The placeholder for the electronic signature data (if applicable) AT-21 The Transaction Type30 AT-S1 The identification code of the subscriber31.

The values “Recurrent” and “One-off” are indicated. The situation of accounts requiring joint signatures, for which it may be necessary to ask the ISO to supplement the messaging standard in order to make it possible to indicate multiple occurrences of this attribute, is currently under analysis. 30 31

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 26/41

ABI

Italian Banking Association

6.4.3 DS-SEDA-01: Request for a new Direct Debit mandate signed by the Debtor Description: indicates the business information that, for the “Basic” SEDA module, is transmitted in SEDA messages in the Creditor-Alignment PSP and Alignment PSP-Debtor PSP transfers to request for a new Direct Debit mandate; the same information is transmitted in the “Advanced” SEDA module to request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP, in SEDA messages from the Debtor PSP to the Alignment PSP and from the Alignment PSP to and the Creditor. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service); attribute AT-S1 has been introduced in relation to the particular functionalities of SEDA. These attributes are mandatory unless otherwise indicated. Attributes AT-01 The unique Mandate reference AT-02 The identifier of the Creditor AT-03 The name of the Creditor AT-05 The address of the Creditor (Optional) AT-07 The account number (IBAN) of the account of the Debtor to be debited AT-08 The identifier of the underlying contract (Optional) AT-09 The address of the Debtor (Optional) AT-12 The BIC code of the Alignment Bank AT-13 The BIC code of the Debtor Bank (Optional in the Creditor-Alignment PSP transfer) AT-14 The name of the Debtor AT-15 The name of the Debtor Reference Party (Optional) AT-17 The type of Mandate (hard copy, electronic) (Optional) AT-20 The identification code of the Scheme (Core, B2B, other schemes) AT-21 The Transaction Type32 AT-25 The date of signing of the mandate AT-27 Debtor identification code (Optional) AT-37 The identification code of the Debtor Reference Party (Optional) AT-38 The name of the Creditor Reference Party (Optional) AT-39 The identification code of the Creditor Reference Party (Optional) AT-60 The Alignment Bank‟s reference to the message (Optional) AT-61 The Creditor‟s reference to the message AT-R5 The Debtor Bank‟s reference to the message AT-S1 The identification code of the subscriber.

32

The values “Recurrent” and “One-off” are indicated.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 27/41

ABI

Italian Banking Association

6.4.4 DS-SEDA-02: Request to amend mandate data initiated by the Creditor Description: indicates the business information which, in the Creditor-Alignment PSP and Alignment PSP-Debtor PSP transfers, must be transmitted to change mandate data. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service); attribute AT-S1 has been introduced in relation to the particular functionalities of SEDA. These attributes are optional unless otherwise indicated. Attributes Copy of all information received in DS-SEDA-01 AT-24 The reason for amendment of the Mandate (mandatory) AT-S1 The identification code of the subscriber of the amendment (mandatory) AT-18 The identifier of the original Creditor who issued the mandate AT-19 The unique Mandate reference as given by the original Creditor who issued the Mandate (mandatory) AT-60 The Alignment Bank‟s reference to the message AT-61 The Creditor‟s reference to the message.

6.4.5 DS-SEDA-03: Request to cancel the mandate initiated by the Creditor Description: indicates the business information which, in the Creditor-Alignment PSP and Alignment PSP-Debtor PSP transfers, must be transmitted to report the cancellation of the mandate. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service); attribute AT-S2 has been introduced in relation to the particular functionalities of SEDA. These attributes are mandatory unless otherwise indicated. Attributes AT-S2 The cancellation reason code AT-01 The unique Mandate reference AT-20 The identification code of the Scheme (Core, B2B, other schemes) AT-02 The identifier of the Creditor AT-03 The name of the Creditor AT-14 The name of the Debtor AT-07 The account number (IBAN) of the account of the Debtor to be debited AT-60 The Alignment Bank‟s reference to the message (optional) AT-12 The BIC code of the Alignment Bank AT-13 The BIC code of the Debtor Bank AT-17 The type of mandate (hard copy, electronic) (Optional) AT-21 The Transaction Type33 AT-25 The date of signing of the mandate.

33

The values “Recurrent” and “One-off” are indicated.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 28/41

ABI

Italian Banking Association

6.4.6 DS-SEDA-05: Communication to amend mandate data initiated by the Debtor PSP Description: indicates the business information which, in the Debtor PSP-Alignment PSP and Alignment PSP-Creditor transfers, must be transmitted to request the amendment of mandate data. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service). These attributes are optional unless otherwise indicated. Attributes: Copy of all information received in DS-SEDA-01 AT-24 The reason for amendment of the Mandate (mandatory) AT-19 The unique Mandate reference as given by the original Creditor who issued the Mandate (mandatory) AT-R5 The Debtor Bank‟s reference to the message (mandatory).

6.4.7 DS-SEDA-06: Communication to cancel the mandate initiated by the Debtor PSP Description: indicates the business information that the Debtor PSP must transmit to the Alignment PSP to request cancellation of the mandate. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service); attribute AT-S2 has been introduced in relation to the particular functionalities of SEDA. These attributes are mandatory unless otherwise indicated. Attributes: AT-S2 The cancellation reason code AT-01 The unique Mandate reference AT-20 The identification code of the Scheme (Core, B2B, other schemes) AT-02 The identifier of the Creditor AT-R5 The Debtor Bank‟s reference to the message AT-03 The name of the Creditor AT-14 The name of the Debtor AT-07 The account number (IBAN) of the account of the Debtor to be debited AT-12 The BIC code of the Alignment Bank AT-13 The BIC code of the Debtor Bank AT-17 The type of mandate (hard copy, electronic) (Optional) AT-21 The Transaction Type34 AT-25 The date of signing of the mandate. 34

The values “Recurrent” and “One-off” are indicated.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 29/41

ABI

Italian Banking Association

6.4.8 DS-SEDA-04: Responses to messages initiated by the counterparty Description: indicates the information transmitted in the Debtor PSP-Alignment PSP and Alignment PSP-Creditor transfers, to respond to SEDA messages initiated by the Creditor; the same information is transmitted in the Creditor-Alignment PSP and Alignment PSP-Debtor PSP transfers to respond to SEDA messages initiated by the Debtor PSP. The attributes listed correspond to those indicated in the SDD Rulebooks (appendices IX Advanced Mandate Information - AMI optional service); attributes that include „RX‟ and „RY‟ have been introduced in relation to the particular functionalities of SEDA. These attributes are mandatory unless otherwise indicated. Attributes: accurate copy of all attributes received in the request to which the response is addressed AT-R5 Specific reference of the Debtor Bank initiating the response AT-R9 The reason code for the answer o Negative response  Invalid file format  Incorrect IBAN  Closed account  SDD prohibited on this account for regulatory reasons  Blocked account  Missing or incorrect mandate information  No mandate  Regulatory reasons  Account blocked to SDDs by the Debtor  Specific service offered by the Debtor PSP  Refusal of the Debtor  Duplication  Inconsistency between the name of the Debtor and the account holder  Invalid bank operation code o Positive response  Acceptance AT-RX Specific reference of the Alignment Bank initiating the response AT-RY The reason code for the answer o Negative results  No mandate.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 30/41

ABI

Italian Banking Association

7 Remuneration model No uniform multilateral interbank fees are envisaged for the SEDA service. The SEDA service remuneration model envisages that the Creditor directly remunerates the PSPs for their activities in the role of Alignment PSP and Debtor PSP, respectively, based on agreements between them. In particular, the fees per mandate due by the Creditors to each Debtor PSP for offering the SEDA service are published in the “Table of participating PSPs” available on the website www.sepaitalia.eu. Any fee applied by the Alignment PSP to the Creditor is freely established by the parties. The following paragraphs provide additional details on the characteristics of the SEDA service remuneration model, which are valid for the initial service activation phase, i.e., calendar year 2014. The characteristics of the remuneration model to be adopted subsequent to the service activation phase, which may be the same as or different from those which follow, shall be subsequently announced and, in any event, described in an updated version of this document.

7.1 Determination and publication of the price Each Debtor PSP publicly discloses the maximum prices (or list prices) applied for its offer of the SEDA service in the “Table of participating PSPs” available on the website www.sepaitalia.eu. The PSPs disclose such maximum prices using the methods indicated from time to time on the website www.sepaitalia.eu. Before the SEDA service start, the prices are published in the “Table of participating PSPs” halfway through September 2013. They become effective on 1 January 2014 and remain valid for six months35. To ensure that prices are minimally comparable, during the activation phase reference will be made to the fee due on a quarterly basis for each active mandate. The maximum prices published may be differentiated by the Debtor PSP depending on whether the mandate is issued and stored at the creditor company or at the same Debtor PSP. This second case occurs either when the company adheres to the “Advanced” module or when, although the company adheres to the “Basic” module, the Debtor PSP continues to store mandates issued previously (e.g., old RID mandates). The maximum prices may be freely negotiated by the parties, in the manner most favourable to 35

For the preceding period, the service - also managed in “pilot” test mode - should be offered free of charge.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 31/41

ABI

Italian Banking Association

the creditor company. The prices for the second half of 2014 shall be published in the “Table of participating PSPs” at the beginning of May 2014 (two months before they become effective)36. Any updates to prices for the second half of 2014 shall be disclosed by the PSPs in compliance with the operating procedures available on the website www.sepaitalia.eu.

7.2 Count of active mandates and sending the “Forecast report” The Debtor PSP counts the mandates37 active for at least one day in the reference period corresponding to the calendar quarter. The count begins from the fifteenth business day subsequent to the date on which the Creditor adheres to the SEDA service38. The fee is applied for the entire quarter in which the mandate was active for at least one day. If the Creditor withdraw from the SEDA service, the Debtor PSP does not count the active mandates relating to that Creditor beginning from the quarter subsequent to the withdrawal, although it remains responsible for storing the mandates issued at the PSP. Once the total fee due from the Creditor has been calculated, the Debtor PSP sends the Alignment PSP the “Forecast report” message by the fifth business day subsequent to the end of the reference quarter39, which provides an advance notice of the amount that will subsequently be debited40. The information set forth below, contained in the “Forecast report”, is mandatory unless otherwise indicated. AT-02 The identifier of the Creditor AT- S3 The reference code AT-S4 The reference period AT-13 The BIC code of the Debtor PSP AT-12 The BIC code of the Alignment PSP AT-S5 The number of mandates issued at the Debtor PSP An exception to this is the case in which the table is updated as a result of the adherence of a new PSP or reorganisation processes amongst banks (e.g., merger of a bank which leads to the creation of a new bank, incorporation of a bank into another participating bank). In these cases, the updated prices are included in the tables on the date of adherence of the new PSP and the effective date of the reorganisation process. 37 Please note that direct debit authorisations issued in compliance with domestic schemes (RID mandates) referring to Creditors participating in the service will be considered valid for the purposes of SEDA remuneration only if the Creditor has transitioned them to the pan-European direct debit schemes based on the rules described in ABI circular - Technical Series no. 10 of 23 April 2013. 38 This is in order to enable the Creditor to send “Request to amend mandate data initiated by the Creditor” messages (according to the operating rules described in paragraph 6) to change the “Business Code” recorded in the mandates registered in the archive of certain Debtor PSPs for which it does not intend to make use of the SEDA service. 39 The timing and procedures for the Alignment PSP to send the forecast to the Creditor shall be agreed by the parties. 40 The Debtor PSP shall not send the Alignment PSP the “Forecast Report” if the prices applied are equal to zero. The Debtor PSP shall send to the Alignment PSP the “Forecast Report”, although the prices applied are not equal to zero, in case it decides not to debit the fee owed for the quarter. In this case, in the “Forecast Report” the number of SEDA Mandates shall be specifically indicated, whereas the prices and total amount due shall be equal to zero. 36

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 32/41

ABI

Italian Banking Association

AT-S6 The number of mandates issued at the Creditor AT-S7 The unit price for mandates issued at the Debtor PSP (Optional) AT-S8 The unit price for mandates issued at the Creditor (Optional) AT-S9 The total fee for mandates issued at the Debtor PSP (Optional) AT-T1 The total fee for mandates issued at the Creditor (Optional) AT-T2 The “Flat” fee for mandates issued at the Debtor PSP (Optional) AT-T3 The “Flat” fee for mandates issued at the Creditor (Optional) AT-T4 The “Flat” fee for all types of mandates issued (Optional) AT-T5 The grand total. If the “Forecast report” is not sent by the established deadlines, the Debtor PSP shall send it at the end of the following reference quarter.

7.3 Payment of fees The settlement of SEDA fees is managed by the Debtor PSP sending a SEPA Direct Debit Core collection against the IBAN associated with each Creditor Identifier registered in the CRI000 master data. That IBAN may identify an account of the Creditor at the Alignment PSP or an account of the Alignment PSP itself. The “settlement date” for debiting the SEDA fees due is set, for all participating PSPs, to the twenty-fifth calendar day of the month subsequent to the end of the reference period. If that date falls on a day which is not a banking business day then the debit date is automatically postponed to the next banking business day. If the Debtor PSP does not send the SEPA Direct Debit Core collection for settlement on the established date, it must once again send the “Forecast report” message and the associated SEPA Direct Debit Core collection for settlement at the end of the subsequent reference quarter. If the Debtor PSP has not sent the “Forecast report” message before the deadline, but in any case sends the SEPA Direct Debit Core collection for settlement, the Alignment PSP shall be entitled to cancel the debit request. To enable the Creditor to reconcile the debit with the corresponding “Forecast report”, the SEPA Direct Debit Core collection for settlement is characterised as follows: indication of the reference code of the applicable “Forecast report”; amount coinciding with the grand total field of the “Forecast report”; attribute AT-59 “The category purpose of the Collection” should be assigned the value “SEDA”; attribute AT-01 “The unique Mandate reference” conventionally filled in with the Creditor Identifier; attribute AT-02 “The identifier of the Creditor” assigned the value specific to each Debtor PSP, determined by entering the BIC of the Debtor PSP in the „Domestic identifier‟ item and the value „SED‟ in the „Business Code‟ item; attribute AT-25 “The date of signing of the mandate” filled in with the date on which the Creditor adhered to SEDA. Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 33/41

ABI

Italian Banking Association

The Creditor is entitled to refuse the debit in advance or request a refund for the debit within eight weeks starting from the date on which the account was debited, as expressly provided under the Direct Debit Core Scheme. Any refusal to the debit by the Creditor in any case has the same effect as an unpaid result. In the event the Creditor does not pay timely the fees requested from a specific Debtor PSP for the service provided due to insufficient funds or to the refusal of the Direct Debit, the Creditor can still pay what is due to the Debtor PSP throughout a SEPA Credit Transfer 41, giving evidence to the Alignment PSP of the late payment. In the event the Creditor does not pay the fees due to all the Debtor PSPs for two subsequent quarters or for two quarters within the same solar year even if not subsequent, independently from eventual late payments performed via SEPA Credit Transfer, the “Agreement for adherence to the SEDA service” is terminated. The alignment PSP gives evidence of this termination by cancelling the Creditor from the CRI000 master data.

7.4 Detailed mandate reporting The Creditor is entitled to request, through the Alignment PSP, more detailed information on the fee charged by the Debtor PSPs. In particular, it can request the “Detailed mandate report” for all active mandates or for the changes that took place since the prior reference period. The Creditor may send “Request for detailed reporting” messages” regarding only the mandates issued at the Creditor, only the mandates issued at the Debtor PSP, or both types, and they may refer to a maximum of two previous quarters. The information set forth below, contained in the “Request for detailed reporting” message, are mandatory unless otherwise indicated: AT-02 The identifier of the Creditor AT- S3 The reference code AT-T6 The type of request42 AT-S4 The reference period AT-13 The BIC code of the Debtor PSP AT-T7 The type of mandate43. When the request is received, the Debtor PSP checks: the existence of the “Forecast Report” corresponding to the Reference Code indicated; 41

The SEPA Credit Transfer has to be addressed to the IBAN of the Debtor PSP available on the “Table of participating PSPs” and on the SEPA Direct Debit sent for the payment of the SEDA fees. 42 The value “ALL” is used for “Request for details about all active mandates”, and “CHG” is used for “Request for details of changes since the prior reference period” 43 The value “DMF” is used for requests referring only to mandates issued at the Debtor PSP, and “CMF” is used for requests referring only to mandates issued at the Creditor; “ALL” is used for requests referring to both types of mandate. Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 34/41

ABI

Italian Banking Association

if at least a mandate exists corresponding to the search criteria requested (reference period, type of request, type of mandates). On the basis of the outcome of these checks, the Debtor PSP sends a feedback message back to the Creditor through the Alignment PSP within 5 business days from the reception of the request. In case of positive outcome the Debtor PSP sends the “Detailed mandate report” containing the detailed information on the fee charged. The content of the “Detailed mandate report” provided varies based on the type of request sent by the Creditor: if a “Request for details about all active mandates” is sent, the Debtor PSP shall send details relating to all mandates which have been active for at least one day in the specified reference period (with the date of cancellation if the mandate was cancelled during the specified period); if the “Request for details of changes since the prior reference period” is sent, the Debtor PSP shall send details of mandates that were activated during the reference quarter as well as details of the mandates that were cancelled during the quarter prior to the quarter specified in the request. The information set forth below, contained in the “Detailed mandates report”, are mandatory unless otherwise indicated. AT-01 The unique Mandate reference AT-02 The identifier of the Creditor AT-20 The identification code of the Scheme (Core, B2B, other schemes) AT- S3 The reference code AT-T6 The type of request44 AT-S4 The reference period AT-T7 The type of mandate45 AT-T8 The Mandate activation date AT-T9 The Mandate cancellation date (Optional). In case of negative outcome of the checks the Debtor Bank sends a message of “Negative Response to the Request for Detailed Reporting” containing the specific reject reason:  

Identification of the Forecast Report not found; No mandate found.

The value “ALL” is used for “Request for details about all active mandates”, and “CHG” is used for “Request for details of changes since the prior reference period” 45 Two values may be used: “DMF” when the mandate subject to reporting was issued at the Debtor PSP or “CMF” when the mandate subject to reporting was issued at the Creditor. 44

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 35/41

ABI

Italian Banking Association

8 Obligations and responsibilities 8.1 Obligations of the Alignment PSP The Alignment PSPs commit to complying with all provisions set forth in this Interbank Agreement, namely: they offer the SEDA service to a Creditor if they also act in the role of Creditor PSP for that Creditor and have adhered to the SEDA service; they propose the SEDA service adherence agreement to Creditors by using “Agreement for adherence to the SEDA service”. By signing the agreement, the Alignment PSPs commit to: 1. registering the Creditors in the CRI000 master data based on the methods set forth in the “Participation by Creditors” paragraph and in compliance with the instructions provided by the Creditor regarding: the Creditor Identifier code(s) with which it will operate in SEDA; “Basic” or “Advanced” operating module for each Creditor Identifier; the information of the account (identified by the IBAN) which Debtor PSPs can debit for the fees due for their provision of the SEDA service for each Creditor Identifier; 2. sending any changes in the Creditor‟s participation in order to update the CRI000 master data based on the methods described in the paragraph “Amending and updating the Table of participating PSPs and master data”; 3. sending the Debtor PSP the following SEDA messages after they are acquired from the Creditor (by the deadlines agreed with the Creditor) and in compliance with the “Operating rules” paragraph: “Request for a new Direct Debit mandate signed by the Debtor and given to the Creditor”; “Request to amend mandate data initiated by the Creditor”; “Request to cancel the mandate initiated by the Creditor”; negative feedback messages in response to requests/notices received, initiated by the Debtor PSPs; 4. sending Creditors the following SEDA messages once they are received from the Debtor PSPs and in compliance with the “Operating rules” paragraph: “Request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP” (only for Creditors and Debtor PSPs which both participate in the “Advanced” module); “Communication to amend mandate data initiated by the Debtor PSP”; “Communication to cancel the mandate initiated by the Debtor PSP”; feedback messages in response to requests/communications sent at the initiative of the Creditor; 5. providing Creditors with “Forecast report” messages received from the Debtor PSPs in compliance with the terms and procedures agreed upon with the Creditors; 6. debiting the account(s) of the Creditor indicated by the Creditor in the agreement, in relation to SEPA Direct Debit Core collections received from the Debtor PSPs to pay for the SEDA service, for which they have also previously received the corresponding “Forecast report” message; Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 36/41

ABI

Italian Banking Association

7. sending Debtor PSPs any “Requests for detailed mandate report” received from the Creditors with regard to a maximum of two previous calendar quarters; 8. providing Creditors with “Detailed mandate report” and “Negative Response to the Request for Detailed Reporting” messages received from the Debtor PSPs in compliance with the terms and procedures agreed upon with the Creditors; 9. upon request, following any unpaid result of the SEPA Direct Debit Core collection ordered by a Debtor PSP in relation to the Creditor, notifying the Creditor of the IBAN information relating to such Debtor PSPs (as set forth in the outstanding debit request) to enable the Creditor to order a SEPA Credit Transfer pursuant to the provisions of the “Payment of fees” paragraph. 10. proceeding, in case of withdrawal of the Creditor from the service or in any case of termination of the “Agreement for adherence to the SEDA service”, to the cancellation of the Creditor from the CRI000 master data according to the based on the methods described in the paragraph “Amending and updating the Table of Partecipating PSPs and Master Data”.

8.2 Obligations of the Debtor PSP The participating Debtor PSPs comply with all provisions set forth in this Interbank Agreement; namely, they commit to: 1. providing the SEDA service to all Creditors identified by specific Creditor Identifier code(s) as registered in the CRI000 master data, with regard to the service module (“Basic” or “Advanced”) chosen by the Creditors. 2. managing SEDA messages in compliance with the operating rules defined in the “Operating rules” paragraph. Specifically, they commit to: a. recording in their archives the mandates for which the Creditor sent a SEPA debit request in compliance with the rules for migration from domestic to pan-European debit schemes, or for which they received a “Request for a new Direct Debit mandate signed by the Debtor and given to the Creditor” message; b. amending the mandates recorded in their archive in line with the Creditor‟s request set forth in the “Request to amend mandate data initiated by the Creditor” message; c. cancelling mandates upon receipt of the “Request to cancel the mandate initiated by the Creditor” message from the Creditor; d. notifying Creditors - through the Alignment PSP - of amendments made to mandates recorded in its archive by sending the “Communication to amend mandate data initiated by the Debtor PSP” message; e. notifying Creditors - through the Alignment PSP - of the cancellation of the mandate at their own initiative or at the request of the Debtor, by sending the “Communication to cancel the mandate initiated by the Debtor PSP” message; f. if participating in the “Advanced” module: i. acquiring, on behalf of Creditors also adhering to the “Advanced” module, the mandates signed by their own Debtor clients and sending the Creditors - through the Alignment PSP - the “Request for a new Direct Debit mandate signed by the Debtor and given to the Debtor PSP”; ii. storing, on behalf of the Creditor, the mandates signed by the Debtor at its offices for 10 years subsequent to the cancellation of the mandate and exhibiting them on behalf of the Creditor in any disputes by the Debtor relating to the Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 37/41

ABI 3.

4.

5.

6. 7.

8.

Italian Banking Association

validity of the mandate or to the relative SDD debits made; using the combination of the following information as the unique identification key for the mandates entered in their archives: “The unique Mandate reference” (attribute AT01), “The identifier of the Creditor” (attribute AT-02) excluding the “Business Code”, “The identification code of the Scheme” (attribute AT-20); performing, at the reception of a SEPA Direct Debit collection consistency checks between the information present in the debit request and the information recorded in the archive for the mandate identified by the unique key specified in the collection request and to debit the account (IBAN) of the Debtor indicate in the mandate information even if different from the one indicated by the Creditor in the SEPA Direct Debit collection; obtaining a confirmation from the Debtor, with regard to the SEPA Direct Debit B2B Scheme, of the validity of the information received from the Creditor in response to the “Request for a new Direct Debit mandate signed by the Debtor and given to the Creditor” or “Request to amend mandate data initiated by the Creditor”; reporting any changes in adherence methods and the prices applied in line with the paragraphs “Amending and updating the Table of participating PSPs and master data” and “Remuneration model”; sending a “Communication to amend mandate data initiated by the Debtor PSP” in order to inform the Creditor of the eventual changes occurred to the IBAN of the Debtor debit account resulting from reorganization processes such as mergers, acquisitions, demergers, sale of branches (etc.) within five days from the effective date of the reorganization itself as resulting from the “Table of participating PSPs; in order to apply the fee to each Creditor, carrying out the following activities: a. on a quarterly basis, counting the number of mandates active for at least one day in the reference quarter; b. calculating the quarterly fee due from each Creditor, taking into account the price that is valid at the time, or in compliance with any other agreements made directly with the Creditor; c. sending their CM the “Forecast report” message by the fifth business day subsequent to the reference calendar quarter, indicating the unique reference used to reconcile that message with the corresponding SEPA Direct Debit Core collection; d. sending the Creditor, at the account it indicates at the Alignment PSP, a SEPA Direct Debit Core collection with due date set to the twenty-fifth day of the month subsequent to the reference calendar quarter, in an amount equal to the fee due by the Creditor as indicated in the “Forecast report” message; e. if the “Forecast report” message is not sent by the fifth business day, sending the same message and the relative SEPA Direct Debit Core collection at the end of the subsequent invoicing quarter; f. sending the Creditor (through the Alignment PSP) the “Detailed mandate reporting” and “Negative Response to the Request for Detailed Reporting” message within five days of receipt of the Creditor‟s request.

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 38/41

ABI

Italian Banking Association

Appendix I: SEPA DIRECT DEBIT CORE mandate form

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 39/41

ABI

Document: SEDA AOS Interbank Agreement

Italian Banking Association

Release 3.0A

Date 30/04/2014

Page 40/41

ABI

Italian Banking Association

Appendix II: SEPA DIRECT DEBIT B2B mandate form

Document: SEDA AOS Interbank Agreement

Release 3.0A

Date 30/04/2014

Page 41/41

ABI

Document: SEDA AOS Interbank Agreement

Italian Banking Association

Release 3.0A

Date 30/04/2014

Page 42/41