Requirement for loan agents to register as payment service providers under EU's Second Payment Services Directive 2015/2366 ("PSD2").

I would like some clarification on Directive 2015/2366/EU (PSD2) Article 4 paragraphh 22 - Money remittance.  If a firm performs administrative services (including but not limited to the calculation of interest/fees and principal owing between lenders and a borrower) and as part of this service is required to regularly transfer money between lenders and a borrower (no fee involved), does this qualify as money remittance? No fees are charged for the transfer of money.

This transfer of money is a small part of the services provided by a loan agent to a borrower. The movement of money is ancillary to the other parts of the loan administration business but it is a regular part of the functions. Loan agents are required as part of a triparty loan agreement to receive and forward on monies from lenders and borrowers as a third party. The independence of this third party is a key element to the transaction.  In the UK for instance, the FCA's guidance in its Perimeter Guidance Manual ("PERG"). PERG 15.22 (Question 9) explains that simply because a firm provides payment services as part of its business does not mean it requires authorisation or registration. Instead, firms have to be providing payment services, themselves, as a regular occupation or business to fall within the scope of the PSRs. The FCA goes on to state that this means that the services must be provided as a regular occupation or business activity in their own right and not merely as ancillary to another business activity.  Are you able to point me towards the position of national regulators on this matter so i can get a full picture of where a loan agent may operate with or without a license from a national regulator?