For my Bank friends – Inventory of Payment Decisions

28 Mar 2015

(a partial inventory for Issuers)

Payments are normally a very sleepy business which changes at a glacial pace. Rule of thumb has been it takes 20 years for anything truly new to develop (Debit Cards, ATM, NFC, …).  All this has changed … as identity, authentication, trust, acceptance, value, regulation, infrastructure, cost of issuance, speed of issuance, consumer mobile preferences, consortiums, standards, bitcoin ..  ALL are shifting rapidly. I covered much of this in my January blog Structural Changes in Payments and 4 years ago in Banks Will Win in Payments! … But Which Ones?. With the top 5 structural changes:

  1. Risk and Identity (Authentication and Authorization)
  2. Data/Commerce Value
  3. Consumer Behavior/Trust/Acceptance
  4. Issuance/Customer Acquisition/HCE
  5. Regulatory/Rates/Rules (Fees)
  6. Mobile/Payment in the OS

payment-value

It’s not just payments that are changing, bank branch footprint and the core deposit account are under threat. Not just pre-paid… companies like TMobile, Wirecard, Vodafone, and even Google are thinking of offering direct deposit and bill pay (See this week’s Recode and Future of Retail Banking: Prepaid?, T-Mobile – Great Move into Banking,  )

branch visits

Before we get into an arcane list of initiatives, let me tell you a few stories on just how bad the situation is.

12 months ago, Chase shows up at Amazon to present their new secret creation: ChaseWallet. The Amazon guys didn’t know before hand what JPM wanted to talk about…. On hearing the opening of the JPM pitch Amazon thinks its some kind of joke (…. listening for the punch line). But Chase was serious..!! the Amazon team is almost rolling in laughter/pity. As opposed to telling them how silly the idea is (Amazon has a little One Click button with 400M+ consumers registered) they ask how this is different than the initiative that Chase Payment Tech is leading to enroll merchants in One Click.. The Chase Senior Exec (consumer side) is silent.. “I’m not aware of that”. Can you believe that largest bank, shows up at the largest online merchant to pitch an idea for a wallet to the company that invented it!? Sorry Chase, but you deserved that… What was once the nation’s leading payment team is now a bit of a joke in the valley. (Chase went to Google with same idea following week).

Jamie Dimon was quoted saying that Google, Apple, … all want to “eat our lunch” in this metaphor I guess consumers are on the menu. As much as I respect Jamie as the best banker on the planet, he continues to miss the consumer view… we are not owned, we migrate to where value is provided. Rather than working to specialize in delivering value to consumer, Consumer Banks tend to work to build higher walls and create rules which work against the specialization. These walls will become their own jail if they fail to focus on value, knowing your customer and specialized risk management.

A flip side story.. ApplePay was a closely held secret (other than my blog). Apple only allowed 9 companies into the tent: 5 Banks, FirstData (and Star), Visa, MA, Amex. Within those companies employees had to sign a strict confidentiality agreement and only 5-15 employees could be made aware (within issuers).  I was with 20 of the bank fraud heads 20 days after launch of ApplePay, the guys were telling me how bad the binding process (enrollment fraud) was going to be. Apple wouldn’t respond to banks, networks or anyone.. not by phone, mail. It was a take it or leave it.  Thank goodness for Money2020.. helped get bank fraud guys together with Apple Product.. but the path for collaboration was just abysmal (Apple’s fault)

Inventory of Payment Decisions (Bank Issuer)

  • Bank/IssuerDebit Card
    • Credit Card
    • Debit Card
    • ATM
    • EMV
      • Creditpayments pyramid
      • Debit
      • ATM
    • Tokens
    • Token Vaulting
    • PIN
    • ACH/Wire
    • Check
    • Cash
    • Private Label
    • Pre-paid
    • Private Label
    • Bit Coin
    • Networks
      • Credit
      • Debit
      • ATM/PIN Debit
      • ACH
      • FED
      • SWIFT
      • FRB
      • CHIPS
    • Network Services
      • Tokens
      • Cross Border
      • Pricing
      • Money Transfer
      • Rules/Rule Changes
      • CNP Liability Shift
      • Virtual Card
      • Digital Wallets
      • Alerts
      • Debit Processing
      • Offers
      • Loyalty
      • Redemption
    • Digital Wallets
      • Card Provisioning
      • Partners
      • Apple
      • Google
      • Samsung
    • Infrastructure
      • Card Issuance
      • Measurement
      • Fraud
      • Authorization
      • AuthenticationPayments Council
      • Billing
      • Call Center
    • Partners/Vendors
      • Processing
      • Loyalty
      • Networks
    • Consortiums
      • ClearxChange
      • Early Warning
      • The Clearing House
      • NACHA
      • ABA
      • FSTC
      • ??
    • Regulatory
      • Fed
      • OCC
      • DOJ
      • FTC
      • Policy
      • Fincen
    • New Initiatives
      • Data
      • Offers
      • Fed Faster Payments
      • NACHA
      • Clearxchange
      • Tokenization
    • Standards
      • emvco
      • ISO
      • Open/Android
      • …etc
    • Structure and Organizational

What is a Bank to do?

How do you Prioritize or Organize in this Chaos?

Step 1 – Admit you have a problem!  Then find people that know about it. Look around your organization and find the 5 people that can give an informed view of 50% of the above.  If you don’t have them.. you should go get them.

Step 2 – Create Structure. Where Bank enterprise payment strategy is discussed, with a senior exec champion.  You need some young payment techies and some old hands in the mix. My blog Need for Bank Payment Counsils provided an overview of the structure and objectives of such an org.  CEO should be involved to show importance.

Step 3 – Assess your situation

1) Where is your Revenue today?

2) How do you deliver value in top 5?

3) What are your core Assets? How competitive?

4) What revenue is most at risk?

5) Is there a clear path to win or uncertain future?

Step 4 – Prioritize and create a plan of Action

Step 5 – Assess Partnerships and Assess Impacts. Payments is a networked business. No one can go it alone for long (message to JPM).

Step 6 – Act Quickly. Both Strategically and Opportunistically.

Step 7 – Measure and Adjust. We are moving from 20 year cycles to 12 months. Banks have not run this way before. They must find a way of adapting to the environment.

Structural Changes in Payments

2 January 2015

Today’s blog is focused on discussing the structural changes influencing consumer retail payments in the US. For those interested in looking at a broader global view of all payments, I highly recommend reading the Cap Gemini World Payments Report (https://www.worldpaymentsreport.com/) .

Payment Value - highlighted

Payments have been a focus of mine for 20 or so years… it is perhaps the MOST interesting of all network businesses. Payment is a critical part of commerce and a product of it. It is the event in which almost every commercial contract is based upon. Payments can be simple (cash), complex (bitcoin), and political (interchange, rules). Payment efficacy, reliability and data are important to: consumers, merchants, banks, governments and economies.

Globally, electronic payments are still in their infancy, which makes investing in it so much more exciting. For example, over 90% of the global electronic transactions occur in the top 10 markets (representing less than 10% of the world’s population).  This would seem to point to a future where electronic payments (and the banking/commerce they represent) are poised to grow geometrically as the number of nodes grow. There is a chicken and egg argument here.. are payments the result of strong economic environments or are they the enabler? Perhaps a bit of both, but finding markets where they are growing (ie Brazil, Peru, Philippines, Kenya, … ) are worth exploring (Democratizing Access to Capital – see blog).

Not only are payments poised for exciting growth, there are also tremendous forces driving change within existing systems and networks. Investors must consider these structural changes impacting existing players across the entire value chain.

In its simplest form, payments are a brokering business which manages value exchange between two entities engaged in commerce. Logically, a broker must be removed from the transaction to maintain the trust of both parties, and deliver value through managing the financial risk associated with the transaction. My view is that Card issuing banks, have lost the neutrality of their “brokering” role by creating a card rewards system that incents card use (paid by the merchant). However, this ideal “neutral” world is NOT the nirvana that we should seek, as no one would invest and we would be stuck with cash (and SEPA in the EU .. see blog).

Complexity in payments is driven by the quest for control and margin of the various participants, not by necessity. This is what makes understanding payments so hard…. most of the changes are not logical, but political. The friction (inefficiencies and illogical design) in payments is what makes them work. As I’ve stated before, no engineer would design a payment system to operate the way we do today (see Push Payments). Thus there is beauty in this chaos! The V/MA model created incentives for 1000s of banks to invest in payments, and I doubt if we will ever see any other companies that could repeat this feat (thus my V/MA personal investments).

What changes are likely to impact the world’s oldest profession in the next 10 years? My list (in order of impact)

  1. Risk and Identity
  2. Data/Commerce Value
  3. Consumer Behavior/Trust/Acceptance
  4. Issuance/Customer Acquisition/HCE
  5. Regulatory/Rates/Rules (Fees)
  6. Mobile/Payment in the OS

#1 Risk and Identity: Authentication and Authorization

How would you authenticate someone’s identity? Best practice is to validate a combination of what you are (biometric, image, DNA), with something you have (mobile, token, OTP FOB, …) and something you know (shared secret). Apple’s new iPhone 6 is the first major consumer device that can manage all 3 securely. It is truly revolutionary.  The ability to authenticate a consumer eliminates fraud risk, and thus impacts both Account Opening and Transaction Authorization.  Both of these services in turn impact the “core” banking relationship (see Future of Retail Banking).. How do consumers choose a bank? A credit card? What is the value proposition?PIN Fraud Rate 2013 Value

Before there is payment there must be an account in which to pay from. The key to opening an account is identity (Regulatory KYC or Know Your Customer). Account Opening has been automated (and online) for over 10 years. In 2004, my team at Wachovia was the first in the world to introduce instant account opening (online) for deposit accounts (Credit Cards were just 2 years ahead of us..). 10 years ago I used products like Equifax accountChex or EWS AOA (Validating questions based on prior financial history and credit bureau data), today could I use Apple!?

Identity and authentication is changing rapidly, and if the first two paragraphs were not already enough to ponder on this topic, we must mention Bitcoin. As opposed to authenticating the person to give access to funds and services, bitcoin authenticates itself enabling the holder to be anonymous. It is a self authenticating instrument.. imagine a dollar bill that can tell you it is genuine with 100% accuracy.  Self authenticating instruments exist independently of the holder and are a store of value (ie, Gold, Bitcoin, …etc). Normally there was physical presence required to exchange self authenticating instruments (exchanging gold), bitcoin changed all of that. A virtual self authenticating instrument that can be exchanged remotely and cannot be tracked (easily). Whereas payments are instructions move money (value) from one bank (store of value) to another, a bitcoin exchange is value exchange (not instructions). bitcoinhow-100032615-orig

The power of bitcoin to disrupt payments, companies, government, economies, .. cannot be understated.  How could any central bank manage money supply in this model? How can you tax something that cannot be tracked? The growth challenge for bitcoin is in “connecting” to other payment networks and regulated entities (ie cash out).  Unfortunately the entities which benefit the most from bitcoin are those that seek anonymity… which of course impacts the willingness of mainstream (regulated) institutions to accept it.

Fraud and Risk

As you can see from picture above “risk” in payments has several components: credit risk, settlement risk, fraud risk, regulatory/AML risk, … etc. Fraud risk is the area in the most flux, both WHO owns the risk and HOW it is managed. In the US Card Not Present transactions follow the pattern of ACH and Checks in that the originator of the transaction bears the risk of loss. In a retail transaction, that is the merchant. applepayinapps

Risk and fraud management were historically the key areas where banks excelled and differentiated (big banks have multi billion dollar investments), but the merchants and platforms have now passed banks in their ability to manage it. This mobile authentication advancement had rendered the multi billion dollar bank risk investments moot (for mobile initiated payments).  Proof is in the picture above (see Federal Reserve 2013 Payment Study), all fraud has fallen tremendously! Both for Card Present, Card Not Present and even for Checks. Why? As the former EVP of a Kleiner Perkins backed Fraud Prevention company I’m not going to give you all the details, but suffice to say that identity plays a key role. Paypal, Amazon, Google, Apple all have fraud rates under 8bps, some have the around 3bps.  These numbers will get better for Apple and Google as mcommerce starts to take an ever larger share of eCommerce (see my previous blog) and they bake in biometrics into mobile payments.

A key point that investors must understand here is that the large CNP merchants have gotten so good at managing fraud, that they could care less about a liability shift. What they want is a rate reduction (risk based pricing).  After all, if you could manage fraud at a rate of 3-8bps.. what work is the bank doing to justify taking 240 for payments? The Paypal investors read this and say “ahh.. Apple and Google want to become Paypal”.. No they don’t! while Apple/Google COULD assume all the functions of Paypal, their role as commerce orchestrators is of FAR greater value. In this role you must not force a consumer to a merchant, a good, or a payment instrument. “Let the consumer decide” is the common mantra across the Google, Apple, Amazon.

The investor impact is complex. Large merchants have proven ability to manage fraud and risk, and want the consumer to choose the payment instrument of their choice. Banks ability to differentiate in managing risk is greatly reduced, and the cost of issuance/acquisition is dropping to 0. Banks have proven incompetent at creating a Visa/MA replacement. What are the levers in negotiation? How will merchants negotiate a lower rate?

The path in Europe, Australia and the US (Durbin/Debit) has been driven by regulation. No one likes having regulators define the rules, but my investment hypothesis is that there will be a very large TILT of Visa/MA toward the merchant. This will address the both regulatory pressure, and open up new revenue streams surrounding data (below). This tilt means moving rates in the direction that retailers want, creating new rate tiers where risk and identity can be managed by the merchant/platform. Remember Apple is getting 25 bps for their service, the next logical move would be make this same “discount” available to anyone that can drive down risk. Personal-Data-Ecosystem-Diagram-from-FTC-Roundtable

From an identity perspective, Google and Apple have authentication as the CORE feature of their mobile platforms.. it is key to everything they do in mobile. See my blogs on Brokering Identity Authentication in Value Nets, and Authentication – Key Battle for Monetizing Mobile for more here.

#2 Data and Commerce Value

The comments below are largely taken from my blog Banks, Non-Banks and Commerce Networks. As a side note, this is the focus of my new Company: CommerceSignals. We are working with the Fortune 50 to serve as the neutral broker, one layer above the network, supporting companies working together offline and in mobile.

Today, every issuer and card network is chasing after American Express and Alliance Data Systems. Both ADS and Amex have made SUBSTANTIAL progress in working with merchants to deliver new value to consumers. AMEX and ADS have the benefit of working in a 3 party model where they own both the merchant and the consumer relationship.  As I’ve stated before, I believe these 2 companies are 3-5 years ahead of everyone else. Is this data stuff delivering any revenue? Market Size AdvertisingFor ADS the answer is a resounding yes, for Amex the benefits seem to be less direct and more on customer loyalty/spend/engagement. See my blog on Amex Innovation Leader for more details.

Think about the battle in connecting networks, as each of us have limited resources we can connect only to a finite set of “hubs” (unless there is some larger orchestrator). Examples are Wikipedia and Google… these serve as the directories of information. It is almost IMPOSSIBLE to displace an efficient hub. This is why I love Visa, MA and Amex. If they can shake the issuer “tilt”.. and add a few merchant friendly services, they could leverage their networks in many new ways. The revenue opportunity? Payments in the US is roughly a $200B business (issuers, acquires, processors, networks), whereas marketing is $750B (in US).Infographic_Showrooming-lg

Payments work well, but so did the Sony Walkman. The bets that Google, Apple, Amazon, Facebook and others are making is on value orchestration. Does this involve payment? Not really.. at least not as a primary focus.. Payment is there.. but orchestration is about commerce; payment is just one of many important processes (See blog Payment in the OS).  Don’t look at payments as something in isolation, payments are the “connections” made in commerce; they are made for a purpose. Visa and MA also have the potential to expand their “traditional network”, but this must involve a separate agreement with separate rules.

Payments = Network

Here is my network view. Payments are the connections of the GDP. If we were to map payment flows, we would unlock a map of the global GDP at the micro level, from employment to shopping, behavior and preferences, to demand and supply. Free information flow on the internet is enabled through openness and a single primary protocol, whereas payments operate within 100s of proprietary networks with a complex series of clusters and “switches” (there is effort in connecting, authenticating and managing risk). Just as it would be nearly impossible to change the protocol for the internet, it would be difficult to bring fundamental change in payments (see Rewiring commerce).  Now think about the value of payment data. Connecting business is much different than connecting information (the core of CommerceSignals.. but I digress).

From a network strategy perspective, the business opportunity of changing “payments” pales in comparison to the opportunity to influence connections in commerce, banking and manufacturing. Payments support business and consumer needs; they do not alter their path. This insight is the downfall of bank payment strategies around “control”, and their inability to “tilt” toward merchant friendly value propositions.

A top 5 retailer provided my favorite commerce quote

“I think of Commerce as a highway, the payment networks are like a toll bridge. I don’t mind paying them $0.25 to cross the bridge, but they want to see what is in my truck and take 2-3% of what is inside. Hence I’m looking for another bridge… “

ADS, Amex, Google, Amazon, Facebook, Alibaba, V, MA all understand this. Rather than charging toll for crossing their bridge, these networks are beginning to execute against plans to grow the size of the goods in the merchant’s truck.

Existing networks have an existing value proposition, and many don’t like to have their services leveraged by competitors, thus there is a much more highly “regulated” flow of information. Intelligent use of data increases the effectiveness of networks in a way that also benefits consumers. Tilting more toward merchants and consumers.. means tilting away from banks. This is VERY hard for a bank to initiate. It is a change worth making however, as assisting merchants (or consumers) is what brokering is about. My firm belief is that both V and MA have the opportunity to grow Revenue 4x+ in the next 5-10 years. Their principal challenge is to “tilt” their models away from Banks and toward the 2 parties that matter most in commerce: Merchants and Consumers.

#3 Consumer Behavior/Trust/Acceptance

Perhaps nothing matters more in business than consumer behavior (see Consumer Behavior: Discerning and Capturing Value). In payments we learn over and over again that behavior changes slowly in 20 year cycles (Checks, Debit Cards, ATMs, Mobile). Any investor looking for payment innovation should run away unless there is some underlyibranch visitsng commerce value proposition. Payments work REALLY well its everything else that is broken (in OECD 20 countries)…. Among Payment innovators/founders there is a common saying.. you only start ONE payment company.

It is easiest to find the hotspots in payment by looking first for the changes in consumer behavior. For example, the tremendous change in how consumer’s are using their phones, as I outlined earlier this week in eCommerce/mCommerce Convergence.  The banking relationship is also changing, as customers visit branches less than 3 times per year, and the billions spent on huge buildings, huge vaults, sports sponsorships and brand names gives way to value.

Brand reputations for 2014 just came out last week (see Venture Beat), with Amazon, Apple, Google topping the list. How did these companies earn this reputation? Through consbank likabilityistent daily interaction delivering value in every interaction. Value delivery and interaction are my key metrics for assessing investment and focus; both are key measures of consumer behavior and trust. There are many strategies: whereas Google engages with the average consumer 10-50 times per day (winning in frequency and insight), Amazon has a lower interaction but a much greater impact on transaction (value delivery), Apple’s interaction is more holistic within a much more affluent base, Facebook’s is more social.

If I were to outline one KEY point to my bank friends it is this: you can’t reach consumers where you want them to be.. you must reach them where they are. This is the essence of why most bank strategies to engage are failing. Consumers choose to go to Google, Apple, Amazon because of the value and service. As the charts above show, most banks are challenged to deliver value within the core banking products they already delivery, why would any customer want to use a new service in this environment. Thus Bank’s efforts are ill suited to drive a deliver products outside of their core, and outside of existing consumer behavior, banks play a role in SUPPORTING commerce.. not leading it (see Card Linked Offers).Measure Data

Apple is the greatest company in the world in delivering value, experience and changing consumer behavior (see blog Apple and Physical Commerce, and Consumer Behavior). Apple’s reputation is well deserved and earned “the hard way” by remaking: phones, music, mice, computers, apps, …etc.  Through consistent delivery of value within fantastic hardware delivering great (and fun) consumer experiences they earned trust for their products and brand. The greatest NEW opportunity for Apple to influence consumers beyond the individual (music/contacts/calendar) and eCommerce (browser, apps) to the real world: Commerce.

Unfortunately Apple is inept at partnerships, even within its own supply chain. While apple has the talent to accomplish this, their commerce, payment and ad teams are buried within a hardware culture. They will only succeed if they are spun off into a separate division, thus my view is that there is a very low probability of Apple acting in an orchestration role across 1000s of Banks, millions of retailers and billions of consumers. If they did move, it my recommendation (and guess) is that it would be a consumer centric orchestration role as I outlined in Brokering Identity.

One technology (and behavior) I’m keeping an eye on is Beacons and mobile use in store (engagement). Qualcomm Retail Systems spun off the IP around Beacons to Gimbal with Qualcom and Apple both rumored to have 30-40% of the equity. Today Retailers are the entity best positioned to change consumer instore activity for 2 reasons: they alone know consumer product preferences, and they physically touch the consumer (trust, value, presence). See Retailers as Publishers , and Apple iBeacon Experience for more detail.greendot

#4 Issuance/Customer Acquisition/HCE

Now this is a mixed bag of topics. What is fundamentally changing in card issuance? Most of you know I ran remote channels at both Citi (06-07) and Wachovia (02-06). Today, most new customer bank accounts are originated online as branch visits go down and direct mail (the old way) even directs the consumer to this “instant” channel.

Historically I had to spend about $150 in marketing for every new card customer, and around $80 for every new deposit customer. Banks still incur roughly these same costs, but prepaid cards have an acquiring cost of less than a tenth of this cost (See Future of Retail Banking: Prepaid). In this pre-paid model banking products sit on a shelf in a retailer and compete for customers just like shampoo and candy bars.

I would challenge all card participants to think about the credit card product… what delivers value? what about it is unique? how do consumers view it? how is it part of a great consumer experience? When you leave Disney World do you think wow.. buying the ticket with my card was just fantastic? How are new customers acquired? Who benefits when cost of issuance is $0? Is charging the average consumer 12-16% on a card, paying them 0.2% on their savings charging merchant 2% a great model?  Do you think that there is room for improvement? Where do retailers win (ADS, Private Label, Co-Brand, )?

What prohibits you from having 20 retailer cards in your wallet today? Bank card issuers will roll their eyes, but you can not understate the influence that trusted retailers have in consumer decisions. Take this trust together with direct sales force and frequent consumer interaction and you have Private Label and industry whose cards outnumber everyone else’s by a factor of 2. As this week’s Morningstar article on Private Label shows, private label (the largest card segment) is making a tremendous comeback.Private label market share

Citi, GE (now Sychrony), ADS, HSBC are leaders in this space, with ADS advancing most in use of technology. Retailers like Nordstrom, Macy’s, Sears and Kohls are fanatical on their private label program, as their most valuable customers use this product. All new customer experience must first address this base, which you can see is one reason why we don’t see ApplePay being pushed here at all. As I described in Retail 101 (and What do Retailers want in Mobile), most retailers don’t know who their customers are today. Private label and Loyalty programs solve this problem.

Let me throw in a little tech now. I’m on the board of advisors of SimplyTapp, the company that created HCE. Instant issuance is key to everyone in the card space, why wouldn’t every retailer want to enable a private label card if card issuance cost is $0!? Credit worth customers can get store credit, sub-prime get decoupled debit (see Target Red Card) and everyone else gets a loyalty only? I believe we will see this happen, not only within MCX but within platforms like Google, with PL managers like ADS and Citi. This is the strategy focus of the top retailers… (focusing on their top customers).Private Label Profitability

My bet on the future of Google wallet is that it will be very merchant and consumer friendly, enabling them to uniquely integrate to 100s of merchant platforms to create great consumer experiences. This linking of PL, Loyalty, in store, maps, mobile, advertising is value orchestration.. but it all starts with consumer opt in. The opt in is both to merchant (private label/loyalty) and to Google. See blog Host Card Emulation for more background.  Google made the right technical move in HCE, but it dropped the ball in enabling merchants through last mile.. not a technical limitation .. an educational / awareness one.

Do I believe that the world will go private label!? No, it will be at the margins. My view of Visa and Mastercard have changed over the last 2 years. Before I was much keener on the development of a new scheme, but no more. Why? How many networks can you list where millions of participants have invested billions of dollars to make it work? Visa has 1.7B cards and 36M merchants.. how could anyone compete with this? This network works REALLY well, with the only issues with their network are in their control (merchant costs and rules).

#5 Regulatory

From a regulatory perspective, the US retail payment system has been impacted by the Durbin Amendment and the EU to an even greater extent by SEPA and PSD (see my blog).  Most of you have also read my token blogs outlining how the US banks were planning to build a new payment network to compete with V/MA (Now dead).  If someone has a info-graph picture of global acceptance rates I’ll put it in here.. but suffice to say that airline ticket pricing has NOTHING on the complexity of payment pricing.

Visa and Mastercard are largely insulated from the regulatory driven pricing changes, as the issuers continue to bare most of the impact. The EU has created a payment nightmare environment with “cross border” Credit card merchant interchange (MIF) at 30bps starting in later this week Jan 1, 2015 (see article and Visa’s response). The EU can not mandate change within country (domestic transactions), but there will be a race to the bottom in fees.

EU competition commissioner Margrethe Vestager claimed that interchange fees are a form of tax levied on retailers by banks and said that the new legislation would reduce those costs and “lead to lower prices and visibility of costs for consumers”.

Ms Vestager may be correct from a transparency perspective, but SEPA and the PSD put governments into the brokering role with no incentives for intermediaries to invest.. making payments a nearly free infrastructure service (with agreement of consumers and merchants). Network work best when there are shared incentives, and minimal regulation.  I believe Visa and Mastercard will work with new vigor to build relationships with merchants and deliver value, to head off the regulatory driven approach. Unfortunately Europe is already too far gone for this to work.

A prediction (next week’s blog) will be merchants providing greater influence in V/MA rules.

#6 Payments in the OS

My blog from this week: Payment in the OS

card-financial-compete view

Comments appreciated.

Token Acceleration

20 Feb 2014

Let me state up front this blog is far too short, and I’m leaving far too much out. Token strategies are moving at light speed… never in the history of man has a new card present scheme developed so quickly (4-6 MONTHS, see announcement yesterday). As I tweeted yesterday, the payment industry is seldomly driven by logic, and much more by politics. Given many of my friends (you) make investments in this industry, and EVERY BUSINESS conducts commerce and payments, movements here have very broad implications. The objective of this blog is to give insight into these moves so we can all make best use of our time (and money). I was flattered at Money 2020 when a number of you came up and told me that this blog was the best “inside baseball” view on payments. Perhaps the only thing that makes our Starpoint Team unique is that we have a view on payments from multiple perspectives: Bank, Network, Merchant, Online, Wallet, MSB, Processor, … etc.

It’s hard to believe I’ve already written 12 blogs on tokens… more than one per month in last year. As I outlined in December there are (at least) 10 different token initiatives (see blog).  Why all the energy around tokens? Perhaps my first blog on Tokens answered this best… a battle for the Consumer Directory. It is the battle to place a number in the phone/cloud that ties a customer to content and services (and Cards). The DIRECTORY is the Key service of ANY network strategy (see Network Strategy and Openness). For example, with TCH Tokens Banks were hoping to circumvent V/MA… (see blog). The problem with this Bank led scheme (see blog): NO VALUE to consumer, wallet provider or merchant. It was all about bank control.  The optimal TCH test dummy was almost certainly Google, and the “benefit pitched” was that Regulators were going to MANDATE tokens, so come on board now and you can be the first.Token schemes

Obviously this did NOT happen (perhaps because of my token blog – LOL), but the prospect of a regulatory push was the reason for my energy in responding to the Feds call for comments on payments. In addition to the failure of a regulatory push, the networks all got together to say no Tokens on my Rails (see blog). Obviously without network rail allowance, a new token scheme would have to tackle acquiring, at least for every bank but JPM/CPT (see blog).   Paul Gallant spent 3 yrs pushing this scheme uphill and had no choice but to look for greener pastures as the CEO of Verifone (Congrats Paul).

In the background of this token effort is EMV. I’m fortunate to work at the CEO level in many of the top banks and can tell you with certainty that US Banks were not in support of Visa’s EMV announcement last year. One CEO told me “Tom I found out about EMV the way you did, in a PRESS RELEASE, and I’m their [Top 5] largest issuer in the world”. Banks were, and still are, FUMING. US Banks had planned to “skip” EMV (see blog EMV impacts Mobile Payments). The networks are public companies now, and large issuers are not in control of rules (at least in ways they were before). Another point… in the US EMV IS NOT A REQUIREMENT A MANDATE OR A REGULATORY INITIATIVE. It is a change in terms between: Networks and Issuers, and Networks and Acquirers, and Acquirers and Merchants (with carrots and sticks).

In addition to all of this, there were also tracks on NFC/ISIS (which all banks have walked away from in the US), Google Wallet (See Don’t wrap me),  MCX, Durbin, and the implosion of US Retail Banking.

You can see why payment strategy is so dynamic and this area is sooooo hard to keep track of. Seemingly Obvious ideas like the COIN card, are brilliant in their simplicity and ability to deliver value in a network/regulatory muck. This MUCK is precisely why retailers are working

Payment Value

to form their own payment network (MCX), retailers and MNOs are taking roles in Retail banking, and why Amex has so much more flexibility (and potential growth).

Key Message for Today.

With respect to Tokens, HCE moves are not the end. While Networks have jumped on this wagon because of HCE’s amazing potential to increase their network CONTROL, Banks now have the opportunity to work DIRECTLY with holders of CARDS on File to tokenize INDEPENDENT of the Networks.

Example, if JPM told PayPal or Apple we will give you:

  • an x% interchange reduction
  • Treat as Card Present, and own fraud (can not certify unless acquirer)
  • Access to DATA as permissioned by consumer
  • Share fraudulent account/closed account activity with you to sync

If you:

  • Tokenize (dynamically) every one of our JPM cards on file
  • Pass authentication information
  • Collaborate on Fraud

This is MUCH stronger business case for participation than V/MA can create (Visa can not discount interchange, or give access to data).

This means that smaller banks will go into the V/MA HCE schemes and larger banks, private label cards, … will DIY Tokens, or work with SimplyTapp in direct relationship with key COF holders.

Sorry for the short blog. Hope it was useful

Call to Action – Submit Response to Fed

1 Dec 2013

As most of you know, the Federal Reserve published a paper entitled Payment System Improvement and opened it for comments http://fedpaymentsimprovement.org/. Responses are due 13 days from Today. My response can be viewed here.

After witnessing the mess that Regulators and Central Banks can create (FFIEC 2 Factor Auth, UK Faster Payments, SEPA, …), you should take time to submit something for your organizations.  We all need a flexible regulatory environment which provides a fertile field for Innovation and technology evolution (of payments and banking).  How should the US payment system evolve? What is Broken? What is working? Who should lead (Government or Industry)? This is the context behind the survey which covers: tokens, real time payments, fraud systems, mobile payments, and approach.

Summary View

  • The Payment System works today for 95% of needs. Let’s NOT force everything to be real time. Just as we have Rail and Ship transport today… some consumers still demand next day air delivery (a business need that consumers will pay extra for).
  • The problem with the payment system is NOT speed, it is control. The American Banker article How Big Banks Killed a Plan to Speed Up Money Transfers speaks to the uneven playing field faced by small banks, MSBs and other service providers.  Why are big banks blocking this real time effort? Because the top 4 are formulating plans to restrict use of bank owned settlement infrastructure and create new semi-open REAL TIME settlement networks (ie ClearxChange) which will only work for the largest institutions (see New ACH Payment System for background on this initiative). The second paragraph of the Fed’s paper

    Industry adoption of new payment services and technology in this country has been driven mostly by market forces rather than government direction

    is incorrect. Industry adoption of CORE payment services is driven COMPLETELY by the top 5 banks. Top 5 Banks created and hold veto power over: Visa, MA, TCH, NACHA, … and most industry infrastructure.

  • There are only 2 regulatory changes I would request: #1 mandate transparency in rule making for both government controlled (FedWire) and private Payment Entities. No more anonymous voting on common infrastructure, the NACHA and TCH voting procedures are a mess.  The WSJ article above demonstrates the obfuscation.. and the subsequent success of this blog. #2 Allow non banks to assume risk and decrease compliance requirements (for banks) surrounding this service. (more on that later)
  • Over 40% of US consumers are no longer well suited for traditional banks and are migrating to new products (pre-paid/GPR cards) that are offered by new intermediaries. Payments are not only critical to the top of the pyramid but to the bottom. Non banks and the unbanked must be able to participate in the payment system. Again the issue is NOT real time payments, but ACCESS (control).
  • The core technical challenges in Payments are #1 Consumer Authentication, and #2 Risk Management. Non banks are best positioned to Authenticate a Consumer, and may also be best suited to manage risk (as Paypal does in Card Not Present). Banks bear the weight of KYC/AML requirements today and therefore look to control the entire process. If we want consumer centered investment, Non Banks must be able to participate, and bear risk. If the central bank commits to technology of yesterday  we will not be able to leverage new capabilities and consumer experiences will be highly fragmented. (ex a new Apple device which would enable real time, irrefutable transaction signing).
  • The core business challenges in payments today are around value. Banks do not want to invest in networks that benefit merchants (ie Debit, DDA) and Merchants don’t want to invest in networks that benefit banks (ie Credit, Contactless). Payments are just the last (easiest) phase of a long Commerce process. No one should force banks to invest in merchant friendly mechanisms, but banks should not be in a position to BLOCK success here.
  • There will be NO INVESTMENT, if there is NO RISK. Payment profitability is driven by risk management (including fraud, authentication, credit risk, …).  We must allow entities that can bear risk to participate and invest.
  • Network efficiencies MUST IMPROVE (see Thomas Phillippon below). The GOAL of payments should be to provide LEAST COST ROUTING to support consumer preferences of where and how they want to pay and authenicate (ex Apple, Google, …). Expanding an existing utility (ie Fed Wire) may provide a faster path to new capability, and develop a higher quality of service, as competition develops among private networks (analogy is Darpanet ).

MCI Interconnect in Financial Services?

The metaphor for change in the payment system may be the 80s MCI interconnect battle (see Wikipedia), combined with a new regulatory regime which would allow non-bank participation in an OPEN settlement network (Connection + Settlement). See my blog How to Deregulate Payments like Telecom. To understand the current state of industry quantitatively,  NYU’s Thomas Philippon published jaw dropping research detailing how Payments and Banking are one of the few network businesses in the HISTORY OF MAN to grow less efficient (rail, telecom, energy, …). Obviously Regulatory Capture is an issue as regulators protect Bank margins and discourage rate competition. The fundemantal flaw to the Fed survey is an underlying assumption that change will be made to existing utilities and existing players. I’d rather take the MCI approach where the government provides for open interconnect and allows other parties to assume risk. This is why Telecom, Airlines, Stock Exchanges, and the Internet work today. There will be no change, or new investment, unless Regulatory Capture and Big bank control over common utilities is broken.

In another example, from my blog Tokens – Merchant Options obviously there is a need to tokenize a direct draft ACH/DDA to hide the consumer’s account number. This is what the TCH upick system (bespoke TCH token system) was developed around. However banks have NO incentive to deliver innovation around DDA tokens as it would decrease risk and increase consumer adoption in a model where they can not charge ANY interchange. Thus innovation is directed toward revenue (a logical imperative), and conversely merchant avoidance is based upon cost/value (hence no adoption of card POS tokens).

The EU’s ELMI model is perhaps the best developed regulatory standard. Perhaps the US pursues something similar which would serve as a federally chartered MSB. Or provide for existing MSBs to operate (and assume risk) on a settlement network (like Fed wire).  This is my core recommendation, rather than taking a 5 year approach, the Fed should create an open settlement service, in which private utilities (ACH, Visa, …) must compete with. Australia (EFTPOS) and Canada (Interac) have both successfully consolidated debit infrastructure as a result of regulatory mandates (and these remain bank owned networks). Today Fedwire competes with TCH in settling payments, but garners much less than 1% of settment (see FedWire Volumes).

The Fed should consider consumer requirements and preferences, after all it is the consumer’s money. Similar to the MCI telecom case, regulators should consider the minimum consumer servicing requirements. If a consumer wants to pay through an intermediary (like PayPal, Amazon, Google, MCX, … ), or have money stored with an intermediary, or want to remain anonymous to the merchant in a transaction, they should be able to do so. As the Visa model evolves, Consumers should be able to INITIATE the payment request with the Bank (as opposed to the Visa/MA model of merchant requesting payment based upon consumer credentials).

Today, ODFIs are responsible for all risk (in ACH and Card Present). The Regulatory burden they face is substantial (Fed, OCC, CPFB, …etc.).  There are very big plans by the banks to gain tighter control over the payment network (see Tokens and Consumer Authentication).  Fundamentally, if we want change, we must improve transparency and allow risk to be assumed by non banks (and consumers).  Consumers should have the choice to take the slow railroad (with guaranteed delivery) or an instant transfer that cannot be reversed.

The FED should be very mindful that their direction does not just impact Innovation at the top end of the consumer pyramid: over 40% of US consumers are unprofitable to US Banks (see Prepaid – Future of Banking?). The Amex/WMT Bluebird product is proving to be an attractive alternative “banking lite” product with ability to direct deposit. The story of MPESA in Kenya may be useful here, as a non-bank was granted an exception which enabled the service to grow from 0 to 10% of the GDP in 3 yrs. Regulators and the Central bank do NOT look favorably on this development, as 10% of the GDP flows out of M1 into a single non-interest bearing settlement account which cannot be leveraged by banks to offset loans (ie liquidity ratio). But consumers love the service…

Key Topics which I believe need to be addressed:

#1 Bank Ownership and Control of the Payment Rails

  • Cost Transparency/Reporting
  • Speed Transparency/Reporting
  • Transparency of Rule Making and Voting in Infrastructure
  • Non Bank Ability to Connect
  • Non Bank Ability to Take Risk
  • Non Bank Participation in Settlement (ex Federally chartered MSB, or non-bank access to FedWire)
  • Consumer Authentication Standards, and Ability for non-banks to assume role (see KYC)
  • Common Reporting/Alert Interface in Transaction Origination and Settlement

#2 Issuance and Value Storage (from How to Deregulate Payments like Telecom)

We need to look no further than BitCoin to see the need for new regulations surrounding issuance. Transfer of funds between entities is covered above, and my view is that non-bank participants should be licensed and agree to abide by current money transfer  regs (ie. Fincen/AML, ..). Issuance of “credentials” and storage of funds is another matter. Long term storage of funds is a banking function, and should be regulated, settlement funds face state escheatment issues (but largely unregulated unless interest is paid), while storage of “Value” is completely unregulated (ie Coupons – a form of legal tender, Pre paid offers, bitcoins)?

From above, if we allow non-banks to participate in real time funds transfer, third parties (ie Sofort) would act as agents (on behalf of consumer, merchant or bank) to direct the funds and assume risk on behalf of consumer. If a good/service is purchased immediately (commerce) then there is no regulation, however if the value is “held” for future use it is generally regulated (hence MSB, eGold, bitcoin issues). Thus the rules under which third party senders operate (as agents), are different from the entities at the end of the transactions (banks, merchants, consumers). See ACH Origination Risk.

As in the MPESA example above, there is an obvious CONSUMER need for issuance to more closely resemble cash in its ease of exchange, verification, anonymity and storage.

Our current need is for simplified laws surrounding account under a given value amount (say $2000). Providers of service should be lightly regulated through self reporting, “transparency”, and the need to keep settlement funds with the Fed. In this proposed model, a bitcoin exchange must ensure that no single individual has processed more than the threshold in a given time period. Hence the need for KYC of exchange participants (when converting to cash).

Summary – new HUB vs evolving existing networks

The current ACH system will never go away (related blog). There were $33.91 TRILLION moved over the network in 2011, compared to total debit and credit volume of around $4.5 Trillion. What path should regulators take?

#1 Improve ACH (primarily speed and fraud management). The highest priority will be around third party senders (TPS), the lowest priority will be regular customer directed debits and payments to billers.

Third party senders (TPS) are a subclass of Third Party Service Providers (TPSP) which originate ACH transactions based on a direct consumer relationship.  Alternatively TPSP are also known as “processors” whose customers are banks (primarily) and have no direct consumer relationship. Banks are not happy with the “free riders” on their network (see  blog). Most bankers view companies like PayPal and Xoom as riding on their rails for free. One of their biggest issues is that they do not have visibility into the actual beneficiary as the settlement account hides where the payment is going to. This impacts their ability to perform risk management and authorization. Take these issues together with the increased regulatory focus on AML and we have a fertile environment for change (HSBC’s See Deferred Prosecution Agreement, and business overview of HSBC’s issues from Reuters). Note that AML concerns are much more relevant to International ACH Transactions (IAT). This blog is not focused on IAT.Token

Banks must therefore architect a solution to evolve ACH while the ship is moving. This is a much better approach than that taken by the UK of mandating faster payments… (one bank was losing 30M GBP a WEEK from fraud when launched). The consensus approach seems to be one surrounding tokens and directory (my blog from last year Directory Battle Phase 1).

#2 Build a new competing network (around Fedwire) which would allow for non-banks to assume risk

 

Sorry for abrupt end.. I’m sounding repetitive.. .so I’m stopping