Risk – Carving it up in Payments

27 Feb 2014

I was reading this Wharton paper on Risk Management in Financial Institutions and the lead paragraph struck me

Financial institutions exist to improve the efficiency of the financial markets. If savers and investors, buyers and sellers, could locate each other efficiently, purchase any and all assets costlessly, and make their decisions with freely available perfect information, then financial institutions would have little scope for replacing or mediating direct transactions. However, this is not the real world. In actual economies, market participants seek the services of financial institutions because of the latter’s ability to provide market knowledge, transaction efficiency, and contract enforcement.

How would I adapt this to cover a Financial Institution’s role in Commerce and Payments? Let me share a few background points to provide context:

  1. Risk Based Pricing (of Consumer Transactions). This is perhaps the #1 “ask” by the big retailers I work with. For example, Amazon, Apple, Paypal, Visa/Cybersource, Google all do a fantastic job managing eCommerce risk. Their fraud numbers are below 20bps. Why do they still get hit with CNP pricing? We know the answer here of course… Each issuer gets to set pricing and there is no network scheme to price based upon demonstrated fraud/risk performance.
  2. Selective Settlement Risk (SSR – my term… I just made this up). In the POS world, my local Kroger would be quite comfortable taking the settlement risk on my grocery transaction, after all they have seen me purchase about the same amount or groceries for 20 years (using the same debit card). At the POS, Retailers want to be able to leverage their data to take risk on certain transactions, and shift it to other intermediaries when they do not want the risk (big screen TV). This is the central challenge for Target Red Card (and perhaps MCX) in a decoupled Debit model. For those thinking about check fraud, make sure you take a look at the Fed’s 2013 payment study “Checks had the lowest fraud rate by number (0.45 basis points) and a fraud rate by value of 0.39 basis point”. Thats right, checks have a lower rate of fraud than credit and debit cards (not PIN debit in isolation).
  3. Instant Credit for Commerce Transactions. PayPal’s billmelater , and Macy’s, Nordstroms, Kohls and other leading Private Label Card (with Citibank leading the sector) to a fantastic job of taking credit worthy customers off of Open Loop bank cards.  The successful programs are unbelievably profitable for the retailers. With the card held by highest spending, most loyal customers.. and 1500bps on ANR. It wasn’t that long ago that most retailers had their own in store credit (see blog on Private Label), they also accepted checks.
  4. Authentication. As I outlined in Authentication – Core Battle for Monetizing Mobile, and Apple in Commerce, and Who do you Trust, Authentication is core to the platform (Google, Apple, ..) role in Commerce. With respect to Payments, how does a Bank PAY GOOGLE and APPLE for performing the authentication role (example using handset biometric features)?  In this model they are mitigating transaction risk. This is shaping up to be one of the key issues with HCE and Tokens as the new token spec has fields for authentication. I’m not speaking of the technical issues here, but rather the business issues.. how do payment providers compensate an authentication service for reducing fraud? As a side note, for US readers, there is no better service in the market than what Payfone has right now.. with access to both Telecom network integration and Bank ID/Acct verification information.

payment-value

What makes modern financial markets unbeatable? The ability for many parties to identify and segment risk, specialize and a market which allows all of these specialists to interact with transparency. Consumer Finance in general, and Payments specifically must take on some of these features.

Yesterday Jamie Dimon was quoted saying that Google, Apple, … all want to “eat our lunch” in this metaphor I guess consumers like me 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 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 and specialized risk management. Today, it would be almost impossible for 4 party networks to adopt to a flexible “risk based pricing” model. My view is that Paypal, Amex, and Discover have the infrastructure to support this today.

Surprised? 30 years ago most retailers began to abandon roles in transaction risk… only to be taken to the cleaners. Hence we see investment to reassert their roles (ie MCX, Private Label, …).  Retailers have no choice but to build consumer financial networks which allow for the (selective) assumption of risk (settlement, fraud, credit, Authentication…)? This taken together trends of branch closures, prepaid, mass market retail profitability make for a very chaotic environment.. (which is ripe for a new leader that can deliver value).

Thoughts appreciated

Payments Winners/Losers?

If you are a BANK… you can do anything you want to on a PIN DEBIT network (you control).. For example, First Data owns STAR.. they are leveraging the Star network with Cardspring to transfer non payment information (offers/incentives). This is a great example of how to construct a solution within the constraints of existing networks

21 Aug 2013

Of course I can’t answer this question.. but it is THE question most frequently asked by investors. I certainly don’t see anything US Debit WSJthat would significantly dent Visa, MA or Amex’s growth internationally. The concentration of electronic payments is tremendous, fully 92% of all electronic transactions occurred in the top 10 OECD 20 markets. Internationally, as markets mature, banked consumers increase, market facilities like credit bureaus improve coverage, credit starts to flow…  I went to work for Ajay Banga at Citi after listening to his fantastic interview w/ Mike Mayo (then of prudential), Ajay talked about 600-800M new people gaining access to financial services globally. V and MA will be prime benefactors of this global growth.

Domestically? Well that is another story. OECD 20 countries have begun to price debit transactions at cost of ACH. EU (SEPA CF), Canada (Interac), Australia (EFTPOS)… now the US is following with a Durbin rate likely to be $0.07-$0.12/transaction (12c is the fee in Australia).  This rate change impacts $5-7B of bank fee revenue (see Reuters). Of course banks are not in the business of loosing money, and must find a way to make that up.. capgem1 noncash pmt

This brings me to the obvious loser in next 5 yrs: Retail banking in the US. Prior to this latest Durbin change, fully 40% of mass market retail bank customers were unprofitable.  This latest change to debit fees will accelerate bank moves to reduce cost to serve (Branch Infrastructure to Online channels).. Retail banks must either find something new to sell consumers (ex Amex/WFC), or charge them more. (see Blog Future of Retail Banking: Prepaid?), many are seriously considering what BAC did 2 yrs ago .. adding a fee.. (see CNN/Money Article).. remember the reaction back then?

This retail bank pricing pressure comes at a time when retailers are offering banking lite products (WMT/Bluebird) AND new bank aggregators are forming which would allow ANY company to deliver banking services. Best example here is Wirecard in Germany.. as a payments specialist and bank which enables MNOs to offer banking services.In the US we see early stage examples of this same model, OTC: IEBS Independence Bancshares (nD Bancshares) has been recapitalized w/ Bob Willumstad (former AIG CEO) as Chairman.

What is Credit? Debit? Charge? Pre-paid? How are they different? With debit costs moving toward $0.. consumers (and start-ups) have access to “real time” settlement at ACH “like” pricing..  This is the heart of Bank’s concern.. and their subsequent efforts to establish rule changes on “wrapping”.  Banks don’t want Paypal, Google, or anyone else using debit this way.

top reasons for selecting

As I stated in Controlling Wallets: efforts to “control” have unintended consequences.. like holding onto your Jello by squeezing it..  PIN Debit may be the first “break” where you can have your cake (Visa Bug) and eat it too (enhanced data w/ merchant).

PIN DEBIT.. the Dumb Pipe Switch

If you are a BANK… you can do anything you want to on a PIN DEBIT network (you control)..  For example, First Data owns STAR.. they are leveraging the Star network with Cardspring to transfer non payment information (offers/incentives). This is a great example of how to construct a solution within the constraints of existing networks and rules…. And KEEP your Visa logo.PIN Volume2

Unfortunately there are few PIN debit cards that are not also signature debit cards.. When the Visa logo is on the card.. it is the customer that decides. Merchants LOVE PIN.. as pricing was different. Now (in the US) PIN and Signature debit pricing is is the same (for banks over $50B in assets).. Offsetting this confusing PIN/Signature furball is the requirement that both signature and PIN debit must have at least 2 options (each) for routing AND several PIN networks are not owned by issuers (Pulse, NYCE, Star, …). This gives FIRST DATA, FIS, Discover opportunity to deliver services that SWITCH debit for the benefit of the MERCHANT (ex Cardspring).

Is “PIN debit” the baseline product for retail network consortium? It is how I would construct it.   Target’s Redcard is the model, but it is closed loop. Expanding a Target Redcard through a PIN debit network would provide for Open loop (multiple merchants participating). Operating in a PIN debit network also gives the PIN network control over rules on acceptance. Although there would be no real interchange cost savings here.. there would be a real advantage to retaining customer data.

The other advantage of processors which also own a PIN network.. is that they “see” all transactions for their merchants.  If McDonald’s processes a debit card transaction.. their processor (ex FirstData, FIS, CMS, …) has flexibility in choosing whether to process as PIN or signature.  PIN is not routed through Visa, Signature is..  First data could see if card is registered for any loyalty/incentive programs.  This is what what JPMC has done (partially) w/ the Visa deal.. without acquiring a PIN network. Allowing them to use signature debit and credit as rails for non-financial data and routing which will not go through Visa.

Credit Cards

Beyond Retail banking, the traditional Credit Card Product seems ripe for change. Why would consumers with good credit accept 18% rate on a credit card when the bank is paying them 0.1% interest? The top issuers know they must improve the merchant and consumer value propositions.. but are largely failing. Its hard to turn around large portfolios and create new value propositions that don’t cannibalize your core business.redcard

This brings me to Winners.

  1. Companies that can help retailers become better publishers and marketers (see blog)
  2. Company that can construct a better customer experience (Square, Apple, Payfone)
  3. Companies that and orchestrate COMMERCE, not manage payments (Google, Amazon, Facebook)
  4. Companies that can enable anyone to ADD ON banking services (Wirecard, GDOT, IEBS, )
  5. Companies that can CONTROL the mobile phone (Google, Apple, Samsung, ??MNOs)

Sorry for typos.. I publish these things before I proof them.. any corrections appreciated

See my disclaimer above. I have equity in GDOT, Wirecard, Goog, AAPL, AMZN

Wells gets A+: New Amex Partnership

WFC is brilliant here. By leveraging their primary asset (customer relationships) they have jumped to the top of the line in a new ability to deliver services, and capture unregulated payment revenue. Think they need to work quickly to ensure retailers see an upside to expanded Amex transaction volume (see payment enabled CRM).

7 August

Press today on WFC/Amex plans for WFC to Issue Amex Cards (also see WSJ Blog, CNBC Clip with WFC Exec on deal overview). Key items:

  1.  WFC to issue credit cards accepted on Amex Network
  2. New and existing WFC customers
  3. New loyalty platform

Why is this big new for INVESTORS? 2015 will see reissue of EMV compliant cards (blog). Issuers are therefore assessing what brand/plastic to reissue. Top analyst question for Amex/WFC is will WFC reissue on Amex plastic/brand? If WFC moves this direction, will other banks as well? Is Visa’s golden goose on the menu? Will EU regulatory developments (suggested 30bp rate for credit supported last week in US by Dick Durbin) prompt additional banks to move to 3 party network?

Deal History/Drivers

There is tremendous history around this transaction, as well as the business drivers for it. Amex has been seeking mass market opportunity for almost 15 yrs. For example, within Amex, few know that back in 2002, American Express was contemplating an acquisition of Wachovia, then the #3 US retail bank, now part of WFC.

transaction-volume-2006-2010

Within the large retail banks, there is broad recognition that:

  • #1 three party networks have substantial advantages (blog),
  • Durbin has killed the profitability of a vast segment of mass market retail (40%). Durbin’s impact was on Debit, and the PR on the WFC/Amex deal focuses on credit… so view this as attempt to generate fee revenue from mass market (only 30% of WFC retail consumers have credit card). See Barron’s article on latest Durbin bank EPS Impact
  • Pre-paid cards are proving to be real option, and banks face prospect of loosing core relationships (Blog, and Future of Banking)
  • Three Party networks (Amex/DFS) have no Durbin or EU constraints
  • Future of “payments” is about data, and enabling value added orchestration, Amex is the clear innovation, and business model, leader,
  • Chase has constructed unique Visa deal in attempt to create 3 party,
  • Visa and Mastercard are ineffective at “change” and have alienated both Retailers AND Banks.  I asked one CEO about EMV and he said he found out about it same way I did, in a press release (and he was top 3 issuer)…  Gives you idea of partnership “health”.
  • Retailers are working to establish their own payment network (see Battle of Cloud, MCX Blog)
  • Apple, Google and others are investing billions in this space

Top banks are working on a new token scheme to build a new “Visa” from within (see Tokenization). It now seems, BAC, WFC and JPM have separate plans from this centrally led TCH initiative… but all are consistent with disintermediating V/MA

WFC is brilliant here. By leveraging their primary asset (customer relationships) they have jumped to the top of the line in a new ability to deliver services, and capture unregulated payment revenue. Think they need to work quickly to ensure retailers see an upside to expanded Amex transaction volume (see payment enabled CRM).

I also believe this is a tremendous win for Amex, not only in their efforts to grow transactions riding on their rails, gain broader acceptance, grow in mass market but primarily as a way to unlock new value in mass consumer payment “data”. This is yet another “Cluster”…

Network Clusters

The street should watch for M&A activity around DFS…. The only subscale 3 party network left standing.

Take a look at new Amex service, working as a back door to get line item detail from retailers.

https://www.americanexpress.com/us/small-business/openhome/receiptmatch

American Express: Innovation Leader

Happy New Year! Football is on my plate today so this blog will be short.

American Express is cranking out innovation at a tremendous pace. I’m very impressed at what Ken and Dan have done here in last 3 years. For example I just received a note in the mail yesterday that all of my Amex transaction receipts will be in my Apple passbook (don’t know why they used the USPS to tell me). Here are a few other innovations

Retailers don’t like the costs of Amex… but they love Amex customers. Amex has a very heavy bias toward business and T&E spend. Although Amex has only 12% of global card payment volume, each Amex customer spends more than 4x the amount of a typical V/MA holder. In full disclosure I own Amex stock, and I’m an Amex points junkie.

Amex is working to expand its consumer base (into mass) through Bluebird and Serve, but I won’t go into that here.. What I’m most impressed with is that they are the first card network that is beginning to deliver value to advertisers and retailers…. Yes, through its massive trove of consumer insight, Amex is beginning to show signs that it can deliver value to retailers.

Following on from my Nov Blog: Retail CRM Enabled by Payments, Amex’s recent loyalty partners acquisition is showing signs of success in coupling merchant transaction data with its DataInsights business. Through this, merchants have new mechanisms to identify customers, incent loyalty and market specific products.

In my view, Amex is at least 5 years ahead of any other issuer/network. Of course they have the benefit of operating as a 3 party network and regulated bank. This allows them to own: the consumer, the merchant and the rules of the network. As such they have many “innovation” advantages over the V/MA networks and issuers; Amex’s network is much more pliable, where the 4 party networks are very hard to change.

This same dynamic is why Discover is the “dance partner” of choice for anyone working to do something unique at the POS. It is also why I see a 3 party network as the winner of MCX (?a NEW 3 party network?).  As I stated previously, innovations at the POS will be less about payments and more about data and re-orchestrating commerce to create new experiences. There are 3-4 entities that each have unique data, none of which have shown interest in pulling it together: retailers, bank, advertiser, telecom.

Amex is the first to start breaking down this data “log jam” with willing participation from retailers. Although their consumer segment is very narrow, margins are tremendous in this top tier.. which means Amex could be in a position to further accelerate its affluent value proposition without mainline retailer participation (ex focus on T&E).

Random thoughts for Investors

  • Data business revenue, enough to move the needle?
  • Affluent card – Net new customers
  • New 3 party network for MCX. Will it kill 40-60% of Visa’s debit revenue (in 10 yrs)
  • Why did Amex buy Serve again? It seems it can justify higher margins through data…
  • Bluebird growth. Can Amex manage value proposition for affluent and a lower mass segment?

Sorry for typos and short blog

Future of Retail Banking: Prepaid?

Today’s pre-paid dynamics may be the tipping point by which 3 party networks begin to overtake V/MA in growth. A trend that will accelerate when other business models require “control”. This next phase will be centered around merchant/consumer transaction data, which will begin to unlock the advertising revenue pool, which is almost 4 times larger than that of payments.

Payments and core banking will become a “dumb pipe” business unless Banks create value and assume a larger orchestration role. POS Payments are the central feature of a transaction account, if banks loose this relationship they will be in a poor position to orchestrate. 4 party networks are very, very hard to change.

Nov 7 2012 (updated for typos)

Warning.. long monotonous blog. Sorry for the lack of connectedness, written over 7 days and my editor is rather slammed. You have been warned, so don’t complain….

Summary

  1. The competitive dynamics surrounding a “transaction account” (ie DDA) are shifting. For example, Retailer banking/prepaid products (Wal-Mart, Tesco, ..) offer significant fee advantages to most lower mass customers. Three party networks like Amex and Discover have unique advantages when combined with Retailers distribution/service capabilities. This means prepaid has become a disruption: a new good enough product…
  2. Net interest income is 64% of total US retail bank revenues, yet the bottom four deciles of mass market customers are no longer profitable. Given that the transactional account is the #1 factor for retail bank profitability, what are implications if banks loose it?
  3. There is a high probability for disruptive value propositions in Payments, as advertising replaces merchant borne interchange.  Payments and core banking will become a “dumb pipe” business unless Banks create value and assume a larger orchestration role. POS Payments are the central feature of a transaction account, if banks loose this relationship they will be in a poor position to orchestrate.

Does anyone else have trouble keeping up with state of the art? Who is doing what? My method of keeping up with change is to immerse myself in a given area for a day or two. It also gives me a reason to call my friends and colleagues.  This week the theme is retail banking. I’ve spent too much time thinking about payments and how it relates to mobile, advertising, …etc.   I thought I would dust off my banking hat and think in terms of a banker.

Retail Banking

I’m struck by how odd retail banking is. Why are banking services not more simple? Why do I have a separate savings, checking and card account? Why not one account? if the account runs in a arrears I pay interest and if it runs in credit the bank pays me interest? Why does a bank take 3-5 days to move money? How on earth do the banks afford all of those stand alone branches when I visit them perhaps once or twice a year?  Why all of the regulation? What does my bank do for me? What problems do retail banks solve? Can someone else solve these problems more efficiently?

There is certainly no single answer. Retail banking serves many demographics, from the college student to the billionaire. Historically retail bank relationships were very important relationships, as banks only lent money to people they “knew”, based on the deposits they had. Younger consumers need to borrow, older consumers …  savings. Banks focused on things like college student accounts to lock in that relationship as early as possible. Today’s modern financial markets provide for the securitization of loans, thereby spreading risk among various investors willing to assume it. Does a banking relationship matter anymore? to Consumers? to Banks?

I’m struck by how little change has occurred (in the US) on the liabilities side of the banking business? Quite frankly US consumers are treated like idiots who sacrifice “protection of capital” over risk. We now have an entire agency working to protect US consumers from banks.. (BTW what is predatory lending?). Other markets let consumers take on risk.. and hence have many more choices, and innovation, in savings. For example, I’m very fortunate to have worked with so many fantastic people over the years. The great thing about running Citi’s channels globally is that each and every country had a somewhat unique competitive and regulatory environment. It was like running 27 different banks. There were many different strategies for deposit acquisition, for example:

  • In Spain we had a 10/2 product that paid 10% interest on deposits for the first 2 months.. then went to 1%.
  • In Japan Citi leveraged its global footprint, and the poor local consumer rate environment, to create foreign currency (FCY) accounts which allowed consumers earn higher returns by assuming currency conversion (FX) risk in uninsured accounts.
  • The UK is perhaps the most competitive retail bank environment in the world. Consumers in the UK can switch banks almost as easily as changing shoes, it was thus essential to enable consumers to switch quickly and then get them into other products quickly. Take a look at today’s UK savings rates from MoneySuperMarket (8% on a fixed $30k deposit) vs the US (1.05% bankrate.com).  Rate differences on this scale helped fuel the carry trade in Japan.

In the US, it is well known (inside the banking community) that banks are highly discouraged from competing on rates. Not that it matters, this amazing study by the Chicago Fed (Chicago Fed – Checking Accounts What Do Consumers Value – 2010) shows that US consumers are rate inelastic.. and care much more about fees. You have read this right, consumers don’t care about interest rates on their deposits.. which is certainly NOT intuitive. Perhaps rates are all so close to 0% that 5-10bps doesn’t matter. Or perhaps  because the average US consumer does not save at all, and those that do have their money in another place.

Retail Bank Profitability. Net interest income (2011, represented more than 64% of total US bank revenues) is the rate spread between borrowing short and lending long, or more broadly the differential between asset yields and funding costs. Net interest margins (defined as net interest income over average earning assets) were 3.6% at year-end 2011, just 11% higher from the 20-year low of 3.2% in the last quarter of 2006.

From DB Research

As low rates persist, loan-to-deposit spreads fall as prices adjust, and longer-term securities, held as assets, roll over to lower-yielding securities (the same holds true on the funding side, of course, helping to extend the positive impact of falling interest rates into the future). The net impact on banks’ net interest levels may be negative, though. In previous recoveries, this effect has been offset by increased loan volumes, allowing banks to return to sustainable growth levels. Furthermore, as an economy recovers, banks may quickly benefit as short-term assets roll over at higher rates

To summarize: Bank net interest income is important (64%), and falling. Banks have had a key revenue source taken away from them (Debit interchange) and are also facing another merchant led suit on credit card interchange. Bank brands and reputations are on a steady downward trend. Consumers don’t care about rates, but react strongly on fees. … A new regulatory agency to protect consumers is just now forming and looking to make its mark. What are banks to do?

Transaction Account

What is the purpose of a bank provided transactional account today? Well certainly our mattresses are a little less lumpy, and the relationship factors have largely gone away. So what is left? Transactionality?

The banks have long recognized that the transactional account is the #1 factor driving a consumer relationship. Virtually every other banking product and service hangs from this account. Most retail banks view direct deposit (internationally known as Salary Domiciliation or Sal Dom) as the key indicator of the transactional relationship. Consumers have limited “energy” to connect to more than one network (as outlined in followed my previous blog on Weak Links). 

This financial supermarket concept, authored by Sandy Weill and John Reed, has not exactly been a slam dunk success. Nonetheless every retail bank starts selling with a checking account, even if nothing else is attached. What are the key factors influencing the selection of a transactional account?

  • Why are deposits important to banks?
  • Driver of overall relationship à Customer Net Revenue
  • Liquidity ratio ->Risk ->Agency Rating -> Capital Costs
  • How do consumers select a bank?

The public compete data above is completely consistent with previous proprietary studies I’ve commissioned. Consumers tend to pick their bank based on how convenient the branch and/or ATM is.

Is there something fundamentally changing? What if consumers don’t visit a branch… or no longer use cash? Are there new value propositions? Where will consumers (and their deposits) go?

Recent market developments/Announcements

The Amex Bluebird product is revolutionary in terms of fees. It is the lowest cost reloadable card in the market today. Beyond the product, I’m even more impressed with WalMart’s business strategy here. They seem to be willing to break even on payments/banking in order to win the overall consumer relationship and increase foot traffic and loyalty in their stores. Take a look at the suite of products offered by WalMart. While banks are pushing out the bottom forty percent of mass consumers, WalMart has made a bet that it cannot only serve them, but do so profitably.

There are many different types of pre-paid cards (more below), however most are not regulated as bank accounts. In almost every geography, consumer deposits (interest bearing, insured) are regulated because they drive both bank liquidity (which drives lending and cost of capital) and profitability. Remember before capital markets existed to securitize assets (loans) retail banks could only lend to the extent of their balance sheet (deposits). Consumers put their money with banks in order to earn interest (the carrot) with the downside of fees on usage (the stick).  In the US consumers are beginning to ask themselves “is the carrot big enough”?

In emerging markets many banks have a poor reputation, additionally access to legal resources are limited, as are consumer protections. How would you feel if you showed up to your bank for a withdrawal and your bank said “sorry your money is gone” and you had no recourse? This dynamic has propelled other banking models in emerging markets. For example my friend Nick Hughes and his Vodafone/Safaricom team created MPESA in Kenya which provided enormous value to consumers. However MPESA caused an apoplectic reaction from the banking regulators as 10% of Kenya’s GDP sat in a non-interest bearing Vodafone owned settlement account. MPESA therefore impacted bank liquidity (IF the funds would have gone into a bank account as opposed to just M1/cash). Visa and MA have worked hard to try to make prepaid the underlying account for mobile money in emerging markets, to very little avail. The problem is not connecting people to the V/MA network.. and giving balances to an approved bank. The problem is first transferring money to entities currently not on any network, then paying a very small number of billers.  

Why are consumers defecting in the US? Ernst and Young just published a phenomenal global study on this subject. The result of their analysis was that consumer confidence in banks is degrading. E&Y outlined a call to action by banks: reconfigure your business models around customer needs. My hypothesis is that consumers have reached a tipping point where they view banking services as commodities… In the UK, this is already well established.

Prepaid

I haven’t spent much time thinking about prepaid cards so I thought it was time to refresh myself, particularly in light of MCX and the prospect of retailers acting as Banks.

From the US Fed

Prepaid cards offer much of the functionality of checking accounts, but that does not mean the underlying economics are the same. A typical prepaid card in the data is active for six months or less, a small fraction of the longevity seen with consumer checking accounts. As a result, account acquisition strategy and the recovery of fixed and variable costs are likely different than for checking accounts. …. prepaid cards with [direct deposit are uncommon but] remain active more than twice as long and have 10 times or more purchase and other activity than other cards in the same program category. As a result, these cards typically generate at least four times more revenue for the prepaid card issuer

Similarly Pre-paid cards also face a complex web of regulation (See Philadelphia Fed Paper 2010), across 31 different types of cards.

31 types of cards? Did anyone else realize the diversity here? Wow… For the sake of this blog, let’s focus on reloadable (GPR) open loop cards (references to prepaid below are on this card type only). It would seem that GPR pre-paid is following the general disruption pattern of serving a lower tier of the market at a more attractive price point. According to Mercator, In 2009, consumers loaded $28.6 billion onto prepaid cards. By 2015, prepaids will hold $168 billion.

Last month’s WSJ ( Prepaid Enters Mainstream) outlined this dynamic

Traditional leaders in GPR pre-paid have been Green Dot, NetSpend, . The Durbin amendment exempted most prepaid cards. This means that pre-paid is largely example from the Durbin interchange restrictions… (with several conditions). Thus the business case for pre-paid is rather strong, and Banks themselves are assessing if they can make this the new “starter” account (ex Chase Liquid). However Three Party Networks (Discover and Amex) have a significant advantage.

From Digital Transactions, March 2012

While the Federal Reserve’s rule implementing the Durbin Amendment has its greatest effect on traditional debit cards, it affects prepaid cards too, especially its provision that banks’ prepaid cards can avoid Durbin price controls only if cardholders can access the funds exclusively through the card itself. That provision thwarted banks’ efforts to make prepaid cards more like demand-deposit accounts and led them to scale back or end bill payments through prepaid card accounts.

But American Express and Discover are not subject to Durbin’s controversial provisions, Daniel and Brown noted. Both companies are so-called “three-party” payment systems that function both as merchant acquirer and card issuer. In contrast, Visa and MasterCard debit and prepaid cards are part of “four-party” systems in which the issuer and acquirer are usually different companies and rely on the Visa and MasterCard networks to route transactions among them. The Durbin Amendment exempts, or “carves out” in industry parlance, three-party networks from its provisions, including interchange regulation.

“There’s no restriction on what AmEx can pay itself” for prepaid card transactions, said Brown. Thus, AmEx and Discover have a new opportunity to grow their prepaid businesses, the attorneys said.

Clearly Discover (DFS) and American Express (Amex) have an opportunity to “Kill” prepaid cards, what are they missing? Physical distribution, service and reach in the mass market. These are the very things that retailers like WalMart can provide, and in fact economically benefit by providing them.

As you can tell, regulations are driving the business models here. Most large US retailers leverage a fantastic team of attorneys from Card Compliant that specialize exclusively in prepaid cards (run by my friend Chuck Rouse). WalMart’s move to Amex is brilliant both from a regulatory and business model perspective.  

Today’s pre-paid dynamics may be the tipping point by which 3 party networks begin to overtake V/MA in growth. A trend that will accelerate when other business models require “control”. This next phase will be centered around merchant/consumer transaction data, which will begin to unlock the advertising revenue pool, which is almost 4 times larger than that of payments.

Payments and core banking will become a “dumb pipe” business unless Banks create value and assume a larger orchestration role. POS Payments are the central feature of a transaction account, if banks loose this relationship they will be in a poor position to orchestrate. 4 party networks are very, very hard to change.

I see a battle where 3 party networks work to branch into orchestration and advertising, and existing orchestrators (ie Apple/Google) integrate legacy dumb pipes (payments and telecommunication) to deliver value to the consumer. What do consumers value today? This is the call to action for bankers… who are not always the best at creating alliances.

Here is one idea, focus on trust and helping consumers solve problems they don’t face frequently. For example,

  • Make financial planning easier and less of a sales job.
  • Help manufactures and retailers connect to target consumers.
  • Become a buyers agent?
  •     Help navigate the college application and loan process,
  •     Help  buy a new car for the lowest possible price…

I know this is not a clean finish.. but that’s all the time I have.

References

Thank you Kansas City Fed for the fabulous brief from the: CONSUMER PAYMENT INNOVATION IN THE CONNECTED AGE. Bill Keeton and Terri Bradford were nice enough to invite me, but unfortunately I couldn’t attend. In my last visit to the KC fed we spoke about future payments types, but we also spent quite a bit of time discussing where mass market consumers will go if banks view the bottom 4 deciles of retail banking as unprofitable (according to proprietary McKinsey Study).  Today I thought I would pull together a compendium of my learnings on retail deposits, MSBs and pre-paid… the “transaction account” by which payments flow.

Payfone.. Verizon’s new mCommerce phone number based credential storage and authentication service

So why do I call this service “mCommerce phone number based credential storage and authentication service”? Verizon already has one wallet (ISIS).. they don’t want to confuse the market…

MoPoNuBaCreSAS (explained at end of post)

update Aug 2013

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General architecture below is correct. Think the first deployed “use case” will be around mCommerce. An “autofill” function similar to V.me and Google Chrome. MNOs are in a much better place to deliver this as they have information on EVERY handset.. and they can AUTHENTICATE with handset information. This is my FAVORITE MNO led payment effort in the US. Online merchants should adopt this without pause.. think you will see immediate conversion impact. See overview here http://payfone.com/1-touch-checkout/

payfone

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5 August 2011

Previous Post

I ran into a Payfone exec last month.. while stuck together in an elevator…“hey you look familiar”.. “I’m Tom… “ “You’re the guy writing bad stuff about us”… “I’m never afraid of being told I’m wrong.. tell me what is wrong”…   After spending a little time with Payfone, I’ve changed my view.. If US users can be convinced to pay with their phone numbers, and merchants can be convinced to implement the Payfone mobile payment API.. this may be a very good way to go.

What did I get wrong in previous post?

  • It is not only about P2P (at least in US).. but about mCommerce. Don’t know if I got it wrong, or whether their strategy has evolved… but today their focus is on mCommerce leveraging phone number for payment.
  • Buying physical goods with their phone number.. hey in the UK payforit is big… particularly for small purchase. VZ probably wants to have this happen because they see a very rough road ahead for ISIS.. not only will it take consumers buying handset.. it will take 6 parties to align on the value prop.. AND execute.
  • Substantial advantage in risk/fraud when carrier is involved in validation of credentials. Remember, my previous post estimated that MNO KYC could be a $5B market opportunity. Will Payfone take out other SMS verification solutions like Authentify?

My picture is based upon general market G2 (.. note I did not say “intelligence” as it may infer I have some).

What did I get right? The merchant integration challenge … I don’t see how AMEX, Payfone or VZ will be able to offer a compelling merchant value proposition. Amex is not exactly a processor of choice… Ticket sales seems like a sweet spot but hardgoods?  Re: Digital Goods.. My sources tell me that the carriers are currently doing about $600M a year in old fashion digital goods (think ringtones). Apple is doing about $1.6B in App Store, and $4.8B in other Digital Goods (previous post). Given that neither legacy digital goods (ring tones) nor App Stores need this functionality what are the physical goods use cases? Best Buy? Gap? Payforit found a great sweet spot in subscriptions and paid content (read the newspaper, video), ticketing,   …. Similar services in Japan also extend into vending.

So why do I call this service “mCommerce phone number based credential storage and authentication service“? Verizon already has one wallet (ISIS).. they don’t want to confuse the market… (great.. really great attempt here.. we would never call storing payment instruments and sending them to a merchant a “wallet”..  )

Oh.. BTW.. Citi and Verizon are both working on something substantial.. I will have to think of a new acronym for it.. how do I innovate a new word for “Offers”? Digital discount delivered by an MNO with redemption verified by a large multi-national bank? …. question remains who will actually create campaigns.. so need to put those words in there too somewhere. Suggestions appreciated.

Coupon Overload?

Well, FSIs and Card networks have finally gotten in the coupon/rebate game.. well sort of. Most have implemented along the lines of what I wrote about 2 years ago (See Googlizaiton of FS). Exception is Bank of America.. they have the best bank service by far. Merchant level incentives (ex 15% off your next purchase) seem to be the focus of Visa and Amex’s new service. Cardlytics provide a generic white label service along these lines to over 50 banks today (with much better usage than Visa/Amex).

Best Bank Coupon Service? Bank of America wins hands down

FSIs and Card networks have finally gotten in the coupon/rebate game..  sort of. Most have implemented along the lines of what I wrote about 2 years ago (See Googlizaiton of FS). Exception is Bank of America.. they have the best bank service by far.  Merchant level incentives (ex 15% off your next purchase) seem to be the focus of Visa and Amex’s LevelUp service. Cardlytics provide a generic white label service along these lines to over 50 banks today (with much better usage than Visa/Amex). From my previous blog above, the general flow:

1. Customer registers for service (credit card, mobile, ..) Accepts terms that allows for delivery of x advertisements  per month

2. Card Network acts as agency, coordinating merchants, promos and marketing spend

  • Merchants pre-pay for campaign settlement account
  • Cardlytics develop target promo and bid criteria: customer location, demographic, event transaction, …
  • A campaign function sits at “Network Switch”, listens to transaction traffic
  • Card transaction events are triggered based upon card registration status
  • Event gets sent to campaign engine.  AD triggered based upon criteria (Example. Shop at EXAMPLESTORE in next 5 hours and get 20% back)

3.  Redemption/ notification – Redemption server monitors transactions at Switch or at Bank Issuer Auth server

  • If Card transaction is for registered card it is sorted
  • Redemption engine finds that it Ad was sent to it, determines if transaction at EXAMPLESTORE meets threshold
  • If it is met, Campaign engine kicks transaction to MerchantAdvert service which bills merchant for AD and debits account for 10% credit plus fee.
  • Engine issues 10% credit to customer’s card account
  • Engine debits merchant account for fee + redemption amount
  • Notification message sent to customer that their card account has been credited for purchase and 10% discount.

Good news for merchants is that they pay only for purchases. Great CPA here. But a very poor customer experience.. getting credit either directly to your card.. or in Amex’s new program to a separate pre-paid card. Other limitation is that there can be no item level discounts.

Quite frankly I like Bank of America’s service much, much better. They are light years ahead of the other banks thanks to the efforts of people like Joe Giordano. Today, Bank of America customers can click on a coupon in coupons.bankofamerica.com and when you go to the grocery store, the discount item comes right off your bill. The company behind this is Zave Networks. Just fantastic stuff. Zave was the only company in IBM’s booth at the National Retail Federation (NRF) show. Given that IBM has 19 of the world’s top 20 retailers using its POS;. it is little wonder that IBM has embedded Zave in their OS.

Having run the online channel at 2 of the top 5 banks, I have a little idea of customer behavior and preferences. Banking customers visit frequently and may be able to have uptake of incentives, card customers have terrible online usage.. (1-2 times per month).. which is why the card companies are launching mobile services in cards so aggressively: they are trying to establish a new mobile behavior (ex mobile alerts on balances). The card coupon/incentive approach seems to have substantial risk, particularly when considering the poor customer interaction (on credit card), together with the very narrow market for incentives (apparel, restaurants), the competencies of the bank teams groups (campaign management) and customer preferences for debit.

Colloquy.com estimates that Banks and travel related industry spend about $48B per year on loyalty. Banks are running coupons programs primarily out of their existing “rewards” groups… with the hope of juicing rewards, as they reduce costs. With Debit interchange going down to $0.12 you can see the importance here.. either no rewards program at all, or one that is funded by another source. With Credit, loyalty programs are the primary customer driver both for card selection and use. Bank driven loyalty programs typically focus on redemption, not on the front side of selection. In other words, banks do not touch a customer prior to a purchase, but incent them afterwards.

From a retailer’s perspective what is the value of participating in a bank run a loyalty program?  Segments like apparel may gain traffic, but do you want your bank sending you an SMS ad for 10% off a nearby retailer/resturant everytime you pump gas? Possible, but more likely you will use the offerings from Google, Apple, Microsoft integrated with maps and comparison pricing. 10% off what? What do they have that I need? Most retailers are not big fans of banks, or their “incentive” plans. There are exceptions, particularly in apparel and restaurants (note restaurants are not considered retail). Overall this is less than $5B of $750B in US Marketing spend. I give the bank led initiatives about 6 months. When Google, Apple and MSFT come in with much richer services and focused teams. How many banks do you know with an campaign management group? … exactly. Visa had a tough time expanding into eCommerce (hence the CYBS acquisition), what makes them think they can run an advertising agency?

Sorry Amex, Visa, Cardlytics, FreeMonee, … Card driven models will have a very short life span. Exception is BofA both because of the bank (deposit) driven model and because of the item level integration with a partner (Zave/IBM) that knows retail. BAC will likely continue reign as  king of debit.. and even gain momentum.

Amex: Payfone and Serve

Most of my contacts are just shaking their head at this one… Payfone? Not in the US.. no way. The carriers have complete control to shut this down. If Payfone would have just spent a little time with the MNOs they would have seen the flaw here. The only option I see for them is to give this thing to Roamware and let the carriers brand it and attempt to integrate it within their current wallet plans OR focus on merchant acquisition for billtomobile payment.

Updated 7pm Eastern (last paragraph on AML)

Amex: What are they “Serving” up? Marketing Hype

NFC Times: Amex Mobile Checkout Service

Jim McArthy, Visa’s Global Head of Product gave an excellent overview of the market in his analyst call last week (see here). His quote on Serve  “Virtual pre paid card” from Revolution money… I completely agree. Serve is a small evolution for revolution money.. and for background see previous post.

What about Payfone? Well the only unique thing about Payfone is its clearing network, most likely Roamware’s inter-carrier settlement network. Roamware, Mach, Belgacom BICs , … etc have agreements with most carriers globally to allow for roaming access, payment and clearing (aka SS7, B-ICI). I love Roamware.. a tremendous company growing at 500%+ per year with a stellar team. IPO should be happening this year. None of their growth is dependent on this Payfone thing.. but it is a good idea.. ON PAPER.

While all the technical and architecture pieces are there to make Payfone viable (example all of Roamware’s carrier agreements), NONE of the carriers are anxious to let another brand and another service ride on their rails. Remember Inter Carrier Settlement (ICS) is for phone charges.. one of the biggest carrier headaches in mobile billing is customers calling to complain that Zong put a premium SMS on their bill for some gaming top up.. of course it was actually your 12 year old that did it.. The US carriers got fed up with this and all committed to billtomobile (see related post), I just had dinner w/ Paul Kim Tuesday.. tremendous executive. The summary of this post is that Billtomobile killed the Boku/Zong models.. and created commonality across US carriers. Carriers take almost 40% of premium SMS fees.. can you imagine a physical goods merchant paying 40% interchange.. ? on a Pizza?

The picture I’m trying to paint is that carriers love digital goods, they have committed to billtomobile (in the US) and are just starting to “think” about expanding on the $25 limit and physical goods. What makes Payfone think that any carrier on earth would let them lead this? This is NOT a technical problem for the carriers.. they already have all of the capability to turn on mobile payments to any merchant. They have the wallets as well. Not only would this create mass customer confusion.. it would also impact carrier led initiatives for NFC at POS.

Most of my contacts are just shaking their head at this one… Payfone? Not in the US.. no way. The carriers have complete control to shut this down. If Payfone would have just spent a little time with the MNOs they would have seen the flaw here. The only option I see for them is to give this thing to Roamware and let the carriers brand it and attempt to integrate it within their current wallet plans OR focus on merchant acquisition for billtomobile payment.

UPDATE

ICS/SS7 has well defined transaction types (SMS, Data, voice, …). Payfone does not just “throw” a transaction on the SS7 network without either the sending carrier and the recieving carrier agreeing to the transaction. There is first an “authorization” process before any transactions are even allowed. Example: does this customer have an international plan? are they a pre-paid? what is their limit? Voice only?

Recieving carriers can deny payfone transactions. Of course a sending carrier may be successful in “masking” the transaction so that they look like a voice charge.. but this would certainly fall afoul of both regulators and the ICS agreements. Remember this is money transfer cash out, which will ALSO be covered by numerous banking/MSB regulations. As with any money transfer business, KYC is required on both sender and reciever in most jurisdictions. Who maintains regulatory responsibility for KYC? Carriers? NO WAY.. is Payfone doing a KYC on its senders? RECIEVERS? Again, this is the beauty of PayPal.. both senders and recievers have registered and accepted terms.

There are few short cuts in payments.. this solution is technically elegant, but complicated when taking into account carrier plans and regulatory issues.

US Regulations – Online Payment/Transfer

This blog takes a look at the regulatory risk today’s start ups face and gives background on how PayPal got to where it is today. For today’s “emerging” payment companies, there are 4 primary choices for operating in the US: 1) Obtain the licenses, 2) Operate as an agent of an entity with the proper licenses, 3) Sell your software to a licensed entity, 4)Exchange non-monetary forms of value (minutes, eGold, credits, …).

Lessons from PayPal

January 25, 2010

I was on the phone today with Jeff McConnell, a tremendous exec with a long history of leading innovation in money transfer (WU, Moneygram, iKobo, …). In some respects it’s hard for me to believe that 2002 is 8 years ago, and I was reminded of how challenged PayPal was in obtaining the proper licenses “after the fact” in its early business.

In his 2006 book The PayPal Wars, Eric Jackson did an excellent job laying out the challenges paypal faced in its early years.  In the early days after its inception in 1999, PayPal was moving toward becoming a bank, but the Internet startup decided that banking regulations were too cumbersome. “We just wanted to be able to facilitate a quick payment,” he said. “The question of how to classify PayPal lingered for some time….It’s a sort of modern-era Western Union.. really, all PayPal is doing is shifting money around on your behalf.” 

To see the “change” in PayPal’s regulatory approach, take a look at PayPal’s 2002 prospectus.

We believe the licensing requirements of the Office of the Comptroller of the Currency, the Federal Reserve Board or other federal or state agencies that regulate or monitor banks or other types of providers of electronic commerce services do not apply to us. One or more states may conclude that, under its or their statutes, we are engaged in an unauthorized banking business. In that event, we might be subject to monetary penalties and adverse publicity and might be required to cease doing business with residents of those states. A number of states have enacted legislation regulating check sellers, money transmitters or service providers to banks, and we have applied for, or are in the process of applying for, licenses under this legislation in particular jurisdictions. To date, we have obtained licenses in two states.

This 2002 regulatory view, by the Paypal exec team, was based on a position that PayPal was acting as a Third party payments aggregator (TPPA), not in need of a money transfer license. TPPA is a description used for merchants that are charging a credit card for a product or service that they do not own. TPPAs simply facilitate the exchange of money between two parties sometimes using a credit card as a funding source. Several fraud and AML incidents arose which got the attention of both federal and state organizations. It became clear that PayPal was being used for much more then payment for goods within the eBay marketplace.

In Feb of 2002, the Federal Deposit Insurance Corporation (FDIC) ruled that PayPal is not a bank, which accelerated efforts by states to pursue PayPal for violating money transfer laws (New York and Louisiana are most notable).  This could have been the death knell for PayPal, as they were operating without the proper licenses. PayPal’s “post facto” licensing efforts were greatly aided by the local political support from thousands of eBay’s buyers and sellers. Today, according to spokesperson Michael Oldenburg,  PayPal is licensed as a money transmitter in 43 states (not all states require a license), demonstrating that regulatory risk was far greater than what they articulated in the 2002 prospectus. For those interested in the legal/regulatory conundrum faced by regulators, I highly recommend:  Regulating Internet Payment Intermediaries, by Ronald J. Mann, University of Texas School of Law

For today’s “emerging” payment companies, there are 4 primary choices for operating in the US:

  1. Obtain the licenses
  2. Operate as an agent of an entity with the proper licenses
  3. Sell your software to a licensed entity
  4. Exchange non-monetary forms of value (minutes, eGold, credits, …).

Obtain the licenses

For those of you that read my Blog, you’re probably aware that I’m fairly negative on Obopay, however they do excel in obtaining US MTO licensing (https://www.obopay.com/corporate/stateLicenses.shtml) . Unfortunately, all of these US licensing effort seems for naught as they are pulling out of the US and focusing in emerging markets as the “sender pays” model does not work in developed countries (morphing from a failed US P2P effort to Remittance). Today, PayPal, Western Union, Travelex, Moneygram, MoneyBookers (soon to be NY licensed) also operate as licensed Money Transfer Organizations (MTOs).

Becoming an MTO is not for the faint of heart, as regulatory capital requirements in excess of settlement obligations (fiduciary assets) are a complex (state by state) maze. This creates a challenging dynamic where capital reserve requirements grow as payment volumes grow. As a start up this means you not only need to raise capital to start the business, but also the regulatory capital BEFORE you get the state licenses.

MoneyGram’s 2007  “investment issues” offer many insights into MTO challenges. MGI suffered an $860M+ plus loss as it shifted out of high yield asset backed securities (which lost their investment grade rating). To preserve liquidity it sold $630MM in preferred and received debt financing of approximately $500M, a situation which today leaves MGI common shareholders in a $870MM equity deficit.

Operating as an MNO is not your only choice. I’m amazed at how few companies there are attempting to develop a bank based model. Trolling the dust bin of failed financial institutions may provide a unique opportunity for a start up to acquire the “shell” of a licensed bank to develop a “payment” focused value proposition. The strategy behind Revolution Money’s acquisition by Amex gives Revolution the “best of both worlds”: an acquirer and a bank. If it were not for Amex’s bank charter (and associated regulatory capital), Revolution’s PIN based debit would be highly susceptible to NACHA aggregation restrictions if they are operating as a non-bank, operating as a type of decouple debit.

I know from my own personal experience that operating as a “payment bank” is not without challenges, not just Citi C2it.. (which stopped 2.5 yrs prior to my role), but Citi GTS which today provides many of the banking licenses for payment providers like WU, Vodafone, ZAIN, …  In addition to Citi GTS, one of Citi’s most profitable “global” retail bank businesses is NRI (Non Resident Indian) which serves affluent Indians (within the US, UK, …) with comprehensive services that cater to the needs of affluent clients. Citi also effectively up sells NRI clients services within its investment and commercial bank.

Operate as an agent

Pre-paid cards offer a “fast track” to operating a new payment service (Revolution money, Squareup, payoneer, iKobo, …). In this model the service relies on the licenses of the underlying bank (example Metabank). The legal precedent here is rather new as witnessed by May 30, 2007 finding by the First Circuit , which affirmed that the National Bank Act preempted New Hampshire regulation of the pre-paid product. In the “agent” model, it is therefore paramount that start ups seek a federally chartered partner. 

There is still substantial “risk” in this pre-paid agent model, as traditional banks and networks control the “rails” for this payment type. For example, Consumer accounts must be “funded” from either a card or DDA account. NACHA has developed new rules which significantly curtail the ability of a “payment aggregator” operating off of a current account (see NACHA Tightens Risk Management and aggregation rules) . Additionally, card networks and acquirers are much more attuned to the risks that these new payment intermediaries present.

My top vendor in the bank model is CashEdge (having been the banker who signed the agreement at Wachovia). CE is the “3rd party sender” for Citi, BAC, Wachovia, PNC and other top banks representing approximately 50% of US DDA accounts. You don’t hear about them much because they are a white label “bank friendly” service. They excel in risk management, with a team second only to paypal. Most of you in the US reading this already use their software.. but just don’t know it.  In the mobile space, I love the innovation at BlingNation.

Sell your software

This is rather straightforward. Within the mobile money space, companies such as Monitise, HyperWALLET, Fundamo, Paybox (now Sybase 365) all provide good platforms from which to build an offering. Issue for small companies is that the entities which have the necessary license have largely made significant bets here already. Of course some of the bets by big banks (some alliteration here) have been terrible, most notably Firethorne which has lost the accounts at Chase, Citi and Wachovia all in the last 8 months.

Exchange non-monetary forms of value

Beyond the scope for my discussion here. My advice is that this is a slippery slope and you will have trouble (as a payment company) attracting “A Class” capital. Look no further than the history of e-Gold for education on the issues.

U.S. GOVERNMENT SEIZES E-GOLD ACCOUNTS, OWNERS INDICTED

Summary

In writing this I cannot help but be struck by many similarities in the “unregulated growth” of PayPal and Vodafone’s MPesa. The growth of both companies was driven by an existing customer base and a value proposition which addressed clear gaps within the payment systems of their respective markets. In both cases, there was no clear regulatory authority to restrict them and once they were firmly established (through contagious adoption) it was too late to stop.

Within the EU, the ECB has developed ELMI regulations that are supported by other initiatives such as SEPA (See http://www.paysys.de/download/Krueger%20e-money%20regul.pdf).

Related posts

http://tomnoyes.wordpress.com/2009/12/16/cash-replacement-part-2/

http://www.banking.state.ny.us/legal/lo020603.htm

http://www.ecommercetimes.com/story/18211.html?wlc=1264432425