Wow - this is worrying; it shows one of two things, either that the regulator misunderstands the payments industry completely and can't afford, or do not wish to find the right advisors to teach them the basics (I'd be happy to help!!!), OR that Apple have completely misled us on what they are doing.

Frankly, I believe more in Apple understanding what they are doing than any regulator.

SIMPLE: Apple are not collecting any deposit. Apple are not providing any finances. Apple are just the suppliers of some technology to allow banks and retailers to communicate better in making payments. And that is it.

Apple WOULD need an e-money licence or a banking licence if it was taking deposits or lending money, or if it was creating money or a wallet (i.e. like bit coins or like Paypal respectively). But it is not doing so.

In the Apple Pay case, the customers are making payments from their card accounts directly to the retailers, using the MasterCard and Visa and CUP etc., networks exactly the same way that they always have done. BUT (and here is the key....) instead of entering card details across an insecure internet and storing them at an unsafe retailer with insecure messaging etc; Apple have introduced a NEW method of storing card details that cannot be accessed, are using secure EMV encryption, secure communications NFC - protecting the cardholder with fingerprint, geolocation and device profile technology, and keeping the card details away from the retailers (i.e. people like Target and Home Depot).

I do worry about regulators who do not understand anything - or even just the basics of banking. We have them in every country and jurisdiction around the world.