Payment Transactions Under the EU Payment Services Directive: A U.S. Comparative Perspective

This article endeavours to analyse the provisions of Title IV governing rights and obligations in relation to the provision and use of payment services. Analysis is particularly from a US comparative perspective. Attention will be given to Uniform Commercial Code ( UCC ) Article 4A, which governs U.S. wire and other credit transfers as well as federal laws governing consumer retail payment systems. A broader but related objective of the article is the assessment of the contribution of Title IV to the harmonization of funds transfer and payment law, not only by comparison to the U.S., but also by reference to a few aspects of a national law of an EU Member State. Scope does not allow a comprehensive treatment to either aspect, particularly the latter; yet, salient issues will be addressed. The ultimate conclusion is that the Directive is a positive but inadequate step towards global and European harmonization