Changes to "Pull" Transfers and DEBIN

On September 14, 2023, the Argentine Central Bank (BCRA) issued Communique "A" 7841, adjusting certain points of the National Payment System regulations regarding immediate debit (DEBIN) and transfers.

The Communique established that before December 1, 2023, participants of immediate transfer system using recurrent DEBIN to enable clients to fund their accounts with funds from their own accounts held with other providers must  use the "pull" immediate transfer service. In other words, the BCRA established that the only flow that financial institutions and payment service providers that offer payment accounts (PSPCPs) must provide to their clients for funding their accounts when there is withdrawal of funds from other accounts—bank or payment—is the immediate "pull" transfer system.

To this end, the Communique establishes that before September 29, entities subject to this requirement must submit before the BCRA an adaptation plan detailing how they will migrate 100% of the users using the recurrent DEBIN for this.

“Pull" transfers (immediate transfers which, unlike "push" transfers, involve a request for funds) were created and established through Communique "A" 7514, which had determined that financial institutions and PSPCPs should implement them by September 30, 2022. The authorization for these fund withdrawals could be given only once for accounts of the same holder, which implied the "enrollment" of accounts—sight or payment accounts—in digital wallets. However, and for reasons related to the way in which the consent to accept the enrollment of the account is expressed, implementing this function took almost a year. The first phase was finally implemented in August 2023.

Now, the BCRA has decided that pull transfers must replace the recurrent DEBIN system for cash-ins from own accounts. To complement this measure, the BCRA also:

• Required Compensadora Electrónica SA (COELSA), the administrator of the DEBIN system, to disable recurrent DEBIN for funding accounts of the same holder as of December 1, 2023.

• Established that PSPCPs not registered in the "Interoperable Digital Wallets Registry" (created through Communique "A" 7462) will not be able to participate in the immediate pull transfer service regulated in Communique "A" 7514. Therefore, the scope of the immediate "pull" transfer service is limited to interoperable digital wallets, (i.e., those offering QR code payment service and already interconnected through the standardized payment interface (IEP) under the 3.0 Transfer System).

The BCRA also established that "pull" transfers (i) will have a daily limit of 2,500 purchasing value units (UVA) and (ii) that this type of transfers will not be available for certain accounts defined in the rules on "Savings deposits, salary and special accounts", which have a more limited nature (e.g. demand account for judicial use, savings accounts for authorized minors, special accounts to credit export financing, tourist savings accounts, etc.).

Further, the BCRA made changes regarding the operation of recurrent DEBINs to prevent fraud. Thus, as from December 1, 2023, recurrent DEBINs—which, in turn, may be issued only by those who are not users of financial services—must require the express authorization of the receiving client to debit his/her account only at the time of the first transaction. To this end, the notification of the first recurrent DEBIN must include a statement indicating the effects that accepting such transaction will have (that funds will be periodically withdrawn from the account that accepts this first DEBIN and, therefore, will be adhered to the operation).

Finally, the Communique updated the interchange fee that entities receiving recurrent DEBIN may charge to the originating financial institutions, establishing a cap of 0.12 UVA.