Card Linked Offers Update

Without POS integration AND Retail data sharing this will not work.. the customer experience is terrible, as is the campaign’s restriction on basket level discounts. The ubiquity of cards is attractive.. as is bank data on “Store preferences”…. But both work to the detriment of retailers.

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27 March 2012

We see in the press that Google/MA have gone beta with Card Linked Offers, and Bank of America is  about to go live with “BankAmeriDeals”. I last gave an overview of this space back in November in my Card Linked Offers post. For those that haven’t seen it, there is also a must read blog by Reed Hoffman in Forbes on the subject: The Card is the new App Platform.

Here is my blog from 3+ yrs ago – Googlization of Financial Services – outlining data flow. My purpose is mentioning this blog is not to show how smart I am (as an alternate view is already firmly established), but rather to highlight how much my view on the opportunity has changed over the last 3.5 years. As I tell all of the 12 start ups in the CLO space.. if Visa couldn’t get this to work what makes you think that it will be easy for anyone else.

There is a CORE business problem I didn’t realize back then.. merchants don’t like cards and are VERY reluctant to create ANY unique content (offers) where card redemption is REQUIRED.  Further constraining the “capabilities” of CLO is lack of item detail information within the purchase transaction. IBM is the POS for 80% of the worlds to 30 retailers. Take a look at the 4690 overview here, notice what incentive solution is integrated? This was a 5 yr project for Zavers…

A story to illustrate my point on retailer reluctance. As most of you know POS manufactures like IBM, Micros, NCR, Aloha are implementing POS integration solutions similar to what Zavers has done. Most of the CLO companies above are paying the POS manufactures to write an “adapter” that will work within their POS and communicate basket detail information. (ISIS is rumored to have a 200 page Spec for this POS integration as well).  There is a very big difference between having integration capability, and a RETAILERS agreeing to use it (ie share data).  There must be a business value proposition for retailers to move… and I can tell you with a great deal of certainty.. Retailers don’t like the BANK card platform.

I emphasize BANK for a reason.. I was with the CMOs of 3 large retailers a few months ago. When asked what their payment preferences where, they answered without hesitation: Store Card. This is their most profitable product used by their most loyal customers (think private label). Do you think for a moment that a Retailer would deliver “incentives” to customers that are not in this group..  Remember, these PVL loyal customers also hold a number of other bank cards, and there is not much in the way of customer matching between data sets. I think you get my point.

As I stated previously, all offers businesses are highly dependent on targeting. Targeting is dependent on customer data, relevant content, effective distribution (SMS, e-mail, an App), campaign management (A/B testing, offer type, target audience, …). Campaign management is very dependent on feedback.  There are very few companies that can effectively TARGET and DISTRIBUTE.  The current group of CLOs is partnering with the banks to solve the targeting problem (example Catera/Citi, Cardlytics/BAC, …). This is further EXASERBATING the poor Retail adoption. Why? Here is what a CMO told me:

“Tom, lets say a consumer just shops at Nordstrom.. the card network and bank see that I just completed the transaction and now market to them … the advert is “go to Macy’s and save 20% on your next purchase”… Given that they can only offer basket level incentives this is how it must work… Tom do you know what will happen? The customer will return what they just bought and go to Macy’s and get it. How is this good for Retail?”

From an Ad Targeting/Distribution perspective, Mobile Operators certainly have an eye on this ball (mobile phone). But only a few companies like Placecast can actually deliver it for them. MNOs are truly messed up in this marketing space (within the US). If you had the CEOs of Verizon, ATT and ISIS in a room and asked “who owns mobile advertising”?.. ISIS would say nothing if both of the other CEOs were in the room.. They want it.. but no one will give it to them as they can’t execute with what they have in this space.  Verizon would say “many partners”… Their preference would be to sell the platform akin to their $550M search sale to Microsoft in 2009. So VZ wants a $1B+ Ad platform sale… who would compete for that business? I digress.. but what is in place today looks much more like a rev share… Internationally there are carriers with their act together: Telefonica and SingTel (just bought Admobi).

Let me end this CLO diatribe with a customer experience view. Let’s assume I have 12 CLO players.. each partnered with a different bank/network. Also assume that all are heavily dependent on e-mail distribution. I have 6 different cards.. and will be getting at least 6 e-mails per week with basket level discounts. Now assuming that I can keep track of which offer was tied to which card.. and use the card. I’m still left at the POS with a receipt that shows none of these basket level discounts (as they are “credited” to my account after purchase).

Without POS integration AND Retail data sharing this will not work.. the customer experience is terrible, as is the campaign’s restriction on basket level discounts. The ubiquity of cards is attractive.. as is bank data on Consumer “Store preferences”…. But both work to the detriment of retailers. What consumers will see in CLO for some time is the generic 10-20% off your next purchase that will also be available in direct mail campaigns… Let’s just hope that someone can work the double redemption problem…

My read on this for Google is a little different. Google is positioning itself as a neutral platform.. it can do Retailer Friendly.. Bank Friendly… MNO Friendly.. Manufacturer Friendly…  Each will have different adoption dynamics. Google’s objectives are likely: gain insight, be the central platform for marketing spend, be the most effective distributor of content, … . This offer beta would certainly seem to be a “bone” thrown to banks.. hey… here it is … good luck trying to make it work.

Green Dot Bank: Finally Wal-Mart gets to Play

16 Jan 2012

http://www.reuters.com/finance/stocks/GDOT.N/key-developments/article/2447460

GDOT Bank – Federal Reserve Authorization

GDOT bought Bonneville Bancorp for $15.7M + $14M Capital Infusion on 8 Dec 2011. Bonneville was a Utah licensed state bank and a  Fed member (regulated by Fed). This is a very significant deal for several reasons:

  • Sets a new regulatory guidepost in the creation of “national” bank with a pre-paid focus. See Bank Talk article on how GDOT was able to get Fed Approval, specifically around CRA responsibilities.
  • Is essentially WMT’s retail bank for consumer services (WMT owns ~15% of GDOT)
  • Model for future deals in State Chartered banks (particularly for retailers)
  • Highlights need for reassessment of “pure play” banks in pre-paid space (ex. Meta)
  • NEW PRODUCT potential in interest bearing pre-paid accounts targeted to the lower mass market

This is a brilliant move by the Fed, and by GDOT. The Fed is rightly concerned about the fact that the bottom 4 deciles of customers are no longer profitable for the big banks.. and there is an exodus. How does the US financial system retain customers in the lower mass? GDOT and WMT believe it is not through the typical branch model. Just as with Tesco in the UK, Retailers are proving to be excellent distributors of banking services. Retailers do not need to make their margins on bank services alone, in fact banking services improves the overall retail value proposition, brand and loyalty. The same holds for mobile operators internationally.  Why should I pay for all of those branches and sales people if all I need are basic payment services?

I joined Citi in 2006 with the mandate to grow the retail business without growing the number of branches. Creating the ING direct competitors.. the HOOK was high yield savings. GDOT bank could be catalyst for a new retail banking model, with a HOOK associated with “payment”, retail convenience, loyalty and data use.

What are the core product innovations? Here is my list:

  1. Combining a GPR card with retailer brand and distribution (WMT). Banks normally have to seek charters that enable them to operate nationally (ex. Fed, the now defunct Thrift, …) when doing business in multiple states. Virtual GPR cards don’t have this problem as consumers are buying a banking product in another state.
  2. Stand alone consumer value proposition. GPR card that can earn interest on funds held on balance. GDOT/WMT also have a established a rate structure that is one of the best in the business.
  3. WMT’s integrated value proposition. International transfers ( WalMart owns part of MGI they are 30% of MGI’s TPV), International Banking (Mexico, Canada, GDOT, …), StraightTalk prepaid mobile, … they have all the components to deliver value. Can they bring it all together?

Banking is a network business.. the GDOT opportunity is to build the network quickly through key retailers (as physical distribution). What other innovations can they bring to market? At the top of my list would be instant credit (Paypal BillMeLater does this through a WebBank a Utah ILC). Or real time transfers to any bank (using  $0.58 Fed wire…).

Today, MSBs are restricted in both offering interest on accounts and the length of time they can hold a balance (escheatment). There will be some regulatory scrutiny by the State Regulators on how cash in/out is performed at the physical retail outlet, and what constitutes a “bank”. From the Retailer’s perspective, the GDOT card is a product which can be bought (buy $100 GDOT reload), with cash out from ATM or through a Mastercard purchase. GDOT is a licensed MSB in 39 States (according to their 10-k) with a network of 50,000 cash in/out locations. Previously GE Money was the US bank for the WMT MoneyCard. A single state licensed bank owned by an MSB network may face some state regulatory scrutiny. GDOT can probably address by keeping as separate legal entity with its own BOD and capital.

If I were thinking of starting the next PayPal… I would skip getting MSB licenses in 47 states and start looking for a Utah bank I could buy.

What to look for:

  • Retailers following this model (including ISIS, Amazon, …). Particularly retailers serving lower mass market
  • Salary d0miciliation (direct deposit) onto a card
  • Future of GE Money. GE has been looking to sell Mark Begor’s business for some time. It is subscale, and WalMart is its largest US customer. My guess is that WMT had to develop fall back plans in case GE did sell the business. I would not be surprised to see GDOT bank be the primary bank behind the MoneyCard.. but it hasn’t happened yet.
  • Pre-paid processors and platforms looking to create their own brands.. or change their relationships to retail branded banks
  • MSBs moving toward a state bank license. Issue is cash in/out. MSBs that require their own branded physical distribution will keep MSB license… those that are virtual will move to GDOT model.
  • Consumers making switch to a “new” banking model centered around payments.
  • Semi closed payment networks with integrated loyalty and incentives.
  • New Payment Banks which make money on marketing and data (not interchange). See Googlization

For those interested in a Utah Bank.. please call my favorite Utah Banker.. Crawford Cragun..

Your thoughts are appreciated. As always sorry for the typos and the brevity.

2011: Tough Start for Mobile Payments

2011 has been a rough start for mobile payments. Early bets in the space are running out of cash, and established industry players are placing $1B+ bets to compete with new MNO ecosystems.

10 January 2011

I learned my lessons on the Valley hype cycle early (from the source). In 1997, at the ripe old age of 32,  I joined GartnerGroup with the goal of participating in a great research and advisory team. Well… that lasted about 11 months. I learned that there was no research and their business model never broke away from its roots as a division of McGraw Hill. It was all about reporting, writing, buzz and sensationalism (with a very few exceptions .. Schulte/SOA).  It was great fun listening to buyers of IT talking about new products issues and then meeting with the software vendors (with more information on hand then their product heads had) to watch them watching them turn green.  But fun aside, I wanted to go run a business…. not become an industry analyst (this blog serves as an outlet for my minor competencies here).

The Gartner experience reinforced the importance of marketing in creating new products, of creating “buzz”. After all  IT periodicals and research firms must fill their pages with something every week. Of course ISVs and start ups are happy to oblige… Buyers and Investors must be able to cut through the fog and assess business viability, valuation and risk.  My data indicates that mobile payments is at the top of the hype cycle. I read the Nov 2010 Javelin report on mobile with great amusement: $7B in P2P mobile transactions in 2010!?  I would be very surprised if the number broke $100M.  Obviously the $7B number is driven by Javelin’s methodology, perhaps a mobile payment includes when I get an SMS message that my bank paid a bill….

Javelin’s methodology obviously does NOT include looking at financial statements. If it had (and the $7B number were real), we would not have seen the continued bloodshed in the space. 2011 has been a rough start for mobile payments. Early bets in the space are running out of cash, and established industry players are placing $1B+ bets to compete with new MNO ecosystems. An industry status of early movers here:

In every case above, there was complete failure in a value proposition. For Example, Obopay charging $0.50 to send money.  The key lesson learned (over and over) is: small companies cannot LEAD development of a payment network. The industry is replete with examples which substantiate this point(see list here). Payment networks are 2 sided, and compete against well entrenched competitors with deep pockets. Payment networks must start with delivering value to 2 parties (ex PayPal Consumer to EBAY). Going at consumers alone (p2p) or as a bank partner alone (Monitise) will not drive volume. As Clayton Christensen asks in Innovator’s Solution: “what problem are you solving”? Moving money through a phone does not create value.

To be clear, there is a very real potential for mobile payments (and NFC) to be the driver 100s of new companys. But their business models must deliver value today (example NFC to unlock doors), or serve  in a supporting role to new industry ecosystems. This supporting role requires a FUNDEMENTAL change in how valley firms typically operate: Start Ups must learn to work with and support multiple large companies and ecosystems. Supporting ecosystems is a B2C model.. NOT a direct to consumer model. This supporting role has new risks, as VivoTech (one of my favorite companies) has learned.  Small Companies which support emerging ecosystems are challenged to influence their overall shape and value proposition. Further, if transaction volume is low, there is minimal revenue or pricing power without a clear value proposition (see Google/Boku).

New ventures operating within NFC ecosystems have prospect of attracting  30-50% of the $6B in mobile venture capital. Investors should be wary of  hype and tag along investing as risk profiles are unique (ie NFC ecosystem play vs. consumer mobile app).  Look hard at the talent running the company (see investors guide). Social networks are much different than payment networks. Payment networks require alliances, regulatory/risk acumen, understanding of history, experience and relationships (see key skills). Banks can win in the move to electronic payments. The top 5 US banks are in a much better position to influence ecosystem development (see lessons learned) than the mid tier, however the mid tier is in a much better position to partner (ex. Barclays US in Discover).

Deal of the Week

From a valuation perspective, the latest “head scratcher” in mobile payments is Square’s $27.5M raise at a $240M Valuation. From VentureBeat:

Rabois acknowledged, but he pointed out that Square is already achieving impressive growth without paying for traditional advertising or other promotions. He said Square is processing millions of dollars in transactions every week, and that it’s signing up 30,000 to 50,000 new merchants every month. Rabois said many of those merchants were previously cash-only, but they were attracted by Square’s ease-of-use (the card-reading device plugs into iPhones, iPads, and Android phones) and low financial risk

I estimate they are doing about $20-$30M TPV per week (5k users $5k/wk) this translates into revenue run rate of $6M/yr … which would equate valuation of $240M to 40x REVENUE. Square may have 30k downloads of their iPhone app /wk, but does that translate into transactions. This valuation is NOT based upon financials, but upon the people involved in this company. Existing investors took a bigger stake.. they have every right to set the price. This makes complete sense,  particularly if they are looking for a Revolution Money kind of exit.

Citi goes live with POP MONEY

Citi just went live with Cashedge’s POP Money service. Citi is now the leader in mobile payments for both retail (this service) and card. Congrats to the Citi team for getting this done.

28 October 2010

Citi just went live with Cashedge’s POP Money service. Citi is now the leader in mobile payments for both retail (this service) and card. Congrats to the Citi team for getting this done.

You may ask why does POP Money position Citi above Chase’s QuickPay? The answer is network and integration. With Quickpay, it only works if you are a Chase customer or you go through the registration process. With POP Money, Cashedge can deliver direct to account distribution to every one of its 100+ enrolled banks, as well as manage risk in transfers to accounts at its largest retail bank customers (Citi, BofA and Wachovia all use Cashedge for external transfers). The customer experience is also integrated into online banking and the funds transfer process.

From a network perspective, PayPal is the only other company which could surpass Cashedge in number of “links” to deposit accounts (~30M, ~20M respectively). The key difference is Cashedge is a bank service provider and has much better risk controls for P2P transfers (as opposed to online purchases of goods). As a bank service provider, it is also integrated into key bank risk infrastructure (ex. Early Warning’s DepositChek).

It would seem that Bank of America and Wells are intent on following Chase down the road of building a home grown system. Quite a shame, as Cashedge is a bank friendly vendor helping to keep banks at the center of emerging payments. The bank battle is not a technology one, it is against non banks and customer mindshare. Citi clearly recognizes this, keeping control of payments and delivering value while minimizing execution risk. I hope BAC and WFC will move in same direction, doing your own thing may satisfy the NIH folks.. but creating a bank owned service which can be used by any bank customer means that you will eventually need to integrate to POP money… at some point.

CitiGold in NA – Kudos to Manuel

Manuel’s US CitiGold strategy is an excellent approach. Citi’s international retail franchise is a star globally: an affluent bank strategy with minimal branch footprint. Citi’s breadth of products and expertise was an original goal of the Sandy Weill’s supermarket. While loosing significant wealth talent and capability at the top end (with SSB’s $2.7 spin out), Citi still retains products and capabilities globally to serve the affluent segment in the US (just as it does internationally).

27 July 2010

Admittedly I’ve been critical of Citi’s recent NA efforts (Bank of the Future, Bundle, …), but I’m a big fan of Manuel and the new Citigold strategy described in the FT Article above. This blog is addressed to companies looking to partner w/ Citi (insight into the labyrinth), as it is one of the most complex organizations to understand globally. If it makes you feel any better, its hard for people inside the organization as well.

For you outsiders.. Banamex is not a poor stepsister to anyone in retail. As a proof point, in Citi’s most recent quarter (2Q10) LATAM alone provided 2x the earnings of Citi North America. The BOD (and most in Citi) consider Manuel to be a banker’s banker, and in Citi’s Banamex franchise excellence attracts excellence. Over the last 3 years retail strategy has been stunted by the churn of executives in its top ranks, the loss of Ajay Banga was a particularly hard blow. Manuel’s experience combined with that of the LATAM team (and BOD support) position him well to “turn around” Citi NA; an audacious goal that will enhance Manuel’s position as successor to Vikram.

Under Teri Dial, thousands of man hours were spent by every Citi retail (and card) executive planning for “bank of the future”. While customer servicing, touch screens and iPhone apps are important.. you first need to get the customer into the store and sold on your products (in person or remotely).  Bank of the Future was an effort that frustrated Citi’s cadre of excellent business leaders; an empty strategy that gave no near term focus to BAU.. nor a “profitability” for the “future” end state.

Citi’s international retail franchise is a star globally: an affluent bank strategy with minimal branch footprint. Citi’s breadth of products and expertise was an original goal of the Sandy Weill’s supermarket. While loosing significant wealth talent and capability at the top end (with SSB’s $2.7 spin out), Citi still retains products and capabilities globally to serve the affluent segment in the US (just as it does internationally).

Manuel’s US CitiGold strategy is an excellent approach.  Citi is already an affluent bank (as shown in 2006 Comscore data below), maintaining average balances twice that of their nearest competitor (my rule of thumb is that the average BAC customer has twice the products, and the average Citi customer has twice the balances).

Re: US CitiGold, the international team has long questioned why the US continued to push sand up hill in a mass market focus given its minimal branch footprint (#9 as stated in WSJ article above). A new affluent focus will drive marketing, product and most importantly sales.. Citi DOES have unique capability, internationally it also maintains a great brand, let’s see if it can dust itself off for a premium US debut.

This new affluent US focus will not be without challenges, from both existing banks and new start ups (like Bill Harris’ SafeCorp Financial).  However, Citi’s capabilities uniquely resonate with several high end demographics that are already customers of its other lines of business (CEOs, Investment bankers, hedge fund managers, expats/international executives, CFOs, …). Internationally CitiGold services normally started with clients of the institutional side and expanded to the expat community. My guess is that Citi’s decision management team would say that the ability to sell CitiGold in the US (absent these connections) is not well established. On the execution side we will probably see many more relationship managers (wealth lite) pop up in the branches that do exist, and focused marketing efforts outside of mass media. Affluent is about brand and service.. which does align with a few of the CitiForward initiatives.

On the innovation side the “Citi Forward” concept has been around the table for quite some time. Evolving over the last 4 years and piloting itself in Citi Australia.  This is all good stuff: integrated financial management tools, comparison and cross selling. However all of this servicing will not bring you customers if the products are not competitively priced, limited marketing and no sales team (discussed in my previous post – Citi/Bundle). Hope to see Manuel empower a strong US retail head with a focused strategy that will empower them to take the reins of all technology and innovation activity. Citi has fantastic technical capability, but the business needs to focus it (particularly after the bank of the future mess).

US Carriers Form New US Pre-Paid Venture

It seems as if AT&T has pulled together Verizon and Sprint to form a new venture to focus on pre-paid.

May 31

Previous Post http://tomnoyes.wordpress.com/2010/03/15/att-visa-prepaid/

Mobile Ad start ups… watch out… the big fish are coming …

It seems as if AT&T has pulled together Verizon and T-Mobile to form a new venture to focus on pre-paid. The large US Card Issuers are now aware (and quite suprised) of the move . It is doubtful that this new US entity (NewCo) will reach as far as Canada’s Enstream in mobile platform collaboration, but the focus of this initiative is mobile payment (NFC and P2P) and mobile advertising.

MNOs see a “Google like” future in mobile advertising, as they attempt to monetize their tremendous customer knowledge. For those that have ever purchased online advertising, we know that the biggest challenge in justifying spend is to move beyond “cost per click” to cost per customer acquisition or purchase. This Ad-Purchase disconnect is particularly true when purchase is made in the physical world. Mobile has the potential to bring together these two worlds, but a “key” is needed. MNOs and Banks see this “key” as a a common payment instrument available  to all customers. NewCo is therefore planning to control (issue or manage) a common pre-paid card which will serve as this transaction key and give MNOs the remaining tool necessary to coordinate focused mobile advertising.

Given that NewCo doesn’t yet have the CEO in place there is probably much left open (with respect to business plan and services). At a minimum I believe they will act as issuer, and create common services to address mobile advertising and payment.

Message for VCs and Start-Ups:

  • Assess risk of current path vs. supporting this new “collaborative” MNO ecosystem.
  • Investments “tied” to this new ecosystem will have different risk profile, particularly in navigating more complex environment.
  • Mobile advertising “pure plays” which do not touch financial transaction will be at a significant disadvantage. Ecosystems are forming based upon: Platform, Service (ie search), Network, Payment Instrument and bank.
  • Adapt.. A “dynamic” strategy which will keep your IP “in play” is necessary.
  • Winners will have the right talent that can navigate with the “big fish” and the right BOD that can help you evolve your strategy.
  • Think Global. Ecosystems will likely evolve differently globally, particularly in Asia.
  • Using financial information for advertising will touch privacy and regulatory issues. Regulated entities (Banks, MNOs, Payment Networks) are best positioned to deal with these. However, large MNOs and Banks have poor track records in “innovation” and moving collectively.

In short, it remains to be seen whether MNOs will be able to take on role as “orchestrator” of mobile advertising, or just a provider of location, reputation, authentication and transaction services.  How MNOs monetize these services will be driven as much by their ability to execute as investor expectations and competing models.

Citi/Mastercard beats Visa/BAC to market

Will Citi/MasterCard beat AT&T/Visa to market with a US NFC sticker rollout?… Regardless of who is first out of the gate, I think it will be a win/win for both institutions as significant marketing money is necessary to get this moving. Citi has the upper hand w/ numerous NFC pilots, established card marketing and 55M card accounts. MasterCard will likely leverage the Blaze Mobile application.

8 April 2009

Great Article

http://www.nfctimes.com/news/citi-makes-its-first-move-mobile-payment

As a friend told me this week “if you put an NFC sticker on a bicycle.. is that mobile payment?” Sure a sticker on the back of a phone is not necessarily “Mobile payment” but NFC has taken so long.. who cares? Lets just get started!

Will Citi/MasterCard beat BAC/Visa to market with a US NFC sticker rollout?… Regardless of who is first out of the gate,  I think it will be a win/win for both institutions as significant marketing money is necessary to get this moving. Citi has the upper hand w/ numerous NFC pilots, established card marketing and 55M card accounts.

[youtube=http://www.youtube.com/watch?v=8aWpzGE431k]

Although Citi is first out of the gate, Visa has put together a much more impressive array of services which will work for any card and any bank, with more thoughtful “integration” (See FirstData/Device Fidelity/Monitise).

“Let the NFC games begin”.

Note to NFC times:

This US initiative did not originate in Citi’s growth ventures, but rather with US Cards (likely led by mobile guru Kurt Weiss).

Citi “learns lessons” on Obopay

18 March 2010

American Banker 18 March 2010

Good article.. just a little “too kind”. Citi learned that 2,000 customers found Obopay to be a neat way to give kids their allowance. Of course Citi had higher hopes.. but a sender pays model has rather poor incentives in kick starting a “new network” and consumer behavior (See Citi is out of Obopay).  For those in the industry looking for lessons here, Paybox learned them the hard way in the EU. Obopay’s failure is nothing new.. changing consumer payment behavior is hard. Obopay added a few extra challenges as it attempted to execute a payments business plan with an inexperienced team.

Mobile P2P payments is firmly in the Gartner “hype cycle” stage within developed countries..  The short term future for NFC (at the POS) is quite exciting, particularly with AT&T/Visa’s pending pre-paid card. Within emerging markets, Mobile payment is a game changer for MNOs and the unbanked. The ability of any US tech companies to compete within this emerging market opportunity is TBD as NGOs and MNOs throw substantial resources at the problem.

Interesting to see Obopay start positioning as check (i.e. cash) replacement service. So would you pay $0.25+1.5% of your transaction so that you could provide convenience to a merchant? Me? I think I’ll tell the merchant to take my check.

Hey if the first business strategy doesn’t work… move on.. Jack Dorsey’s square model is focused in a good space (not too keen on his solution though). Obopay.. back to the drawing board.

Related posts

Obopay and Firethorn

Spoke to most of the top 5 US banks this week. Neither Obopay nor Firethorn will have any traction at the top US banks.

2 March 2010

Related posts

Spoke to most of the top 5 US banks this week. Interesting to note that Firethorn is out of all of them.. even in the model where Firethorn paid one of the majors $1M to take the application and integrate it. As of the latest QCOM 10-Q we can now see that total Firethorn revenue was $3M for the 2009 YEAR!  Wow.. no wonder Len lost his head for buying this thing and making it a separate division.

QCOM and Firethorn have a new product planned:  SWAGG (www.swagg.com). Good luck trying to figure out what this thing is.. could this be associated with Visa/ATT? (Youtube here). There seems to be a pre-paid debit card associated with it (from Dr. Jacobs CES presentation). Hey QCOM is one of my favorite companies… the people there are absolutely brilliant. But the Firethorn team is adopted.. and therefore the  genes do not extend here. They need a top exec to drive this thing.

On another note, Obopay showed up to at least one of the top 3 banks last month (BankX) touting its mobile payment solution. Undoubtedly with “millions” of subscribers (actual estimated at less then 20k). Always interesting to see spin here, they also reportedly told BankX that Citi’s departure was only temporary. Other banks should ask them to get specific.. very specific.. (probably not the US and there is no commitment on use).

From compete.com (Hard to spin facts..8,000 unique visits last month .. estimate only 20% use the service)

The “big secret” in mobile payments is that there aren’t any… (with very few exceptions). Those exceptions usually deliver “payments” as part of an existing value proposition (see  MNOs will rule in Emerging Markets). Banks know that changing consumer behavior is a 20 year effort. Card based payment schemes have particularly high hurdles in emerging markets due to interchange rates and rules that are ill suited for low value payments by unbanked. Toward this end countries such as India are contemplating the development of new domestic payment networks.

Thought for the day

RBIs Payments Vision 2012

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