14 MAR 2013
Short blog today.. patent law changes tomorrow and need to get something filed.
Efforts to “control” have unintended consequences.. like holding onto your Jello by squeezing it..
The networks are now in the midst of defining new rules to ensure they can “control” wallets. I wrote about this a few months ago in Don’t Wrap Me – October 2012 and Battle of the Cloud – Part 2. The threat to banks from “plastic aggregation” at POS from solutions like Amex/Serve, PayPal/Discover, Square/Visa, MCX, Google is real. Make no mistake, Banks have legitimate concerns surrounding ability support consumers and adjust their risk models. But the real business driver here is to “influence” mobile payment solutions that do not align to their business objectives. Key areas for bank concerns:
- #1 CUSTOMER DATA
- Top of wallet card (how does card become default payment instrument)
- Credit card ability to deliver other services (like offers, alerts, …)
- Ability for issuer to strike unique pricing agreements w/ key merchants
Each network is in midst of creating rules which will ensure it has control and can see merchant/consumer transaction.
The buzz this week is surrounding Mastercard’s new Staged Digital Wallet Operator Annual Network Access Fee (MA detail reference not avail).
- What is it? Well since I don’t have the Dec 20 rule in front of me I have to go off my notes.
- Applies to wallets that facilitate POS commerce between merchants and consumer (not ecommerce)
- Who is responsible? It is largely a new processor responsibility. They are responsible for identifying wallet transactions
- New transactions sets? Yes. Currently aggregators can be the merchant of record, but new rules require the MID of purchase and a new WID (WALLET ID) to be transmitted.
- New fees? Yep.. looks like around 35bps on LAST YEARS volume
- Timing? Goes live June 2013. Processor technology complete by April 2013
This is a brilliant move by Mastercard… but there may be some unintended consequences as issuers will have control over how it is applied. MA’s objective? “influence” PayPal/Discover, Amex/Serve and Square/Visa, MCX… NOTE eCommerce is NOT the focus (Apple/Amazon). However MA seems to be tying themselves in knots trying to differentiate a ecommerce aggregator (Amazon) from plastic aggregator (ex. PayPal/Discover).
These changes are already having “material” consequences. In eBay’s 2013 10k Page 19
MasterCard has recently announced a new Staged Digital Wallet Operator Annual Network Access Fee which would apply to many of PayPal’s transactions if the buyer uses a MasterCard to fund their payment, and will be collected starting in June 2013. PayPal’s payment card processors have the right to pass any increases in interchange fees and assessments on to PayPal as well as increase their own fees for processing. Changes in interchange fees and assessments could increase PayPal’s operating costs and reduce its profit margins.
Also see the long discussion by Amex’s Dan Shulman
UNIDENTIFIED AUDIENCE MEMBER: Thanks. I have a question for Dan Schulman. MasterCard recently revealed that they’re introducing this digital wallet that I’ll read it’s called the staged digital wallet operator annual network access fee. It’s one of his famous acronyms. I was going to ask has Amex contemplated a digital wallet fee as well? And generally do you think the optics of digital support merchant discount rates, are they going higher or lower in a card not present world?
DAN SCHULMAN : So I think you’re seeing a lot of different players whether it be traditional or non-traditional start to think through the digital wallet strategy. And we’ve said this and it’s still absolutely true, this is the very early innings of this play out with digital wallets right now. We’re beginning to get some very nice traction in the back half of the year. It’s kind of on our digital platform right now. We have looked very hard at the different fee structures that are out there. We’ve looked at the embedded infrastructure that we have. As Ken mentioned we have a kind of fixed infrastructure that we can leverage. We have a lot of assets that we can leverage that are very different than other players out there right now.
So I wouldn’t expect that fee structures are necessarily going to mimic each other because each of us come to the market with different assets and different profiles. If you look at some of the kind of newer players that have come into reloadable prepaid, they’ve got very different infrastructures and therefore have to have very different fee structures if you look at a NetSpend or a Green Dot they charge on their, kind of what they are beginning to try and call wallets, they’re charging monthly fees that can be $4.95
A new WID has multiple uses. It enables MA issuers to enhance their risk models and “decline” both individual transactions from a wallet, as well as decline wallet providers that are not “certified”. Amex already has similar rules in place, their summary view seems to be that Serve can wrap everyone else’s card… but no one can wrap theirs (for physical commerce).
Banks love the original NFC model where cards had to be “provisioned” into a wallet. Banks were in complete control of which wallets to “authorize” and completely hid the card number (purchase data) from the wallet provider. This perfect world broke down quickly as the first NFC wallets had space for only one card emulation application (see Forces against NFC) so there were 2 options: allow only one card type, or enable a single card to represent multiple cards (See Blog). Now that NFC in payment is dead just about everywhere (except Asia), banks are looking to enable this “provisioning” control within the network level. MA is just the first visible instance, as I outlined in NEW ACH SYSTEM the Banks are also doing the equivalent to ACH debit through tokens probably 18mo- 2 yrs away.
And we wonder why mobile payments aren’t taking off.
Retailers look at this change and see complete imbalance… Networks which will change rules in weeks to satisfy banks. V/MA you may want to consider a new transaction set which would force issuers to define price of a specific card for that specific merchant (interchange), and acquirers their fees (MDR)… then share that information with other retailers. Then allow retailers to decline based on price… (as opposed to accept all cards). That would certainly level things out…
I do think there are many ways to get around this.. but I will not be putting them in this blog ($$). All surround who owns the customer… and 5 “LAWS OF Commerce”:
- Commerce will always find the path of least resistance
- Consumers are NOT owned, but rather migrate where there is value
- Value can be delivered by price, product and also through great consumer experience
- Most Retailers face life selling commodity goods at a higher price… experience is all they have left
- Banks have never held a sustained role in controlling commerce, they influence and support it.
In all of this bank control.. where is there value? What does a JPM Sapphire Card actually do that is differently than a platinum Amex or a sub-prime Capital One? Brand, points, loyalty… these are qualitative attributes.. but what if there were REAL value differences? Where is the customer relationship. Note that Retail Banking is going through many FUNDAMENTAL changes (see blog)
Tim Geithner visited a friend of mine prior to his departure. My input question to him was what if core “Bank accounts” morphed from Net Interest Margin (NIM) profitability to “Trust Accounts” where the key to profitability was consumer data? (See blog Payment Enabled CRM)
With respect to squeezing Jello… as the banks angle for control EVERYONE else is looking toward least cost routing (see Blog). The payments system is not a set of 5 pipes.. Just as the internet backbone is not run on a single piece of fiber. Changing all of the rules for everyone and stopping the leaks is hard work…
.. back to my patent app .. oh and corporate taxes due tomorrow too. Yuck.