US Payment Innovation and Regulation

A core “investment assumption” by TCH banks was that “regulators” were going to force the use of tokens in the US. As a primary means for meeting obligations under BSA/AML. The “value proposition” pitched to pilot participants was thus “regs are coming which will drive PayPal out of business.. everyone will be required to tokenize.. pilot participation means you can have a jump on everyone else.” Obviously this has not been the case..

29 Oct 2013

Short Blog.. will update next week. Sorry for Typos

Is anyone else struggling to see the logic of Bank led token initiatives? These folks are smart people.. we obviously see why they want to do it (control)… but they are smart enough to construct some kind of value proposition. It’s not as if they can MAKE every merchant and wallet service convert.

Well… this is NOT necessarily a good assumption (value proposition). I met with a few folks this week, each touched TCH SecureCloud.  A core “investment assumption” by TCH banks was that “regulators” were going to force the use of tokens in the US. As a primary means for meeting obligations under BSA/AML. The “value proposition” pitched to pilot participants was thus “regs are coming which will drive PayPal out of business.. everyone will be required to tokenize.. pilot participation means you can have a jump on everyone else.”  Obviously this has not been the case..

The Banks wanted to start with tokenizing eCommerce Cards on File (COF), as this enabled them to keep the favorable credit card mix (75%+ credit) in a new mobile world. If would have been much easier if they just pushed all of the consumers approved payment products down to Apple, Amazon, Paypal, Google… but Banks don’t really want consumers to have a choice.. they want friction and fear in debit.  This Credit on Mobile Strategy may not be a STATED goal of TCH tokens.. but it is certainly a corollary which Banks don’t care to address.

Visa/MA/Amex did an end run on Bank token plans with a proposed interoperable standard. It thus seems that the 20 odd Bank TCH token participants will give the utility to the networks, with the hope that there will be a continued credit focus. What will TCH do? Probably be a standards body of some sort, and be the token authority for things like ACH.

The ACH LOCKDOWN strategy had 3 prongs: NACHA Rules, Regulation, and an alternative. See related Post around NACHA Rules. With respect to alternative.. this is the driver of Clearxchange, a real time ACH that circumvents NACHA…

One of the Bank leaders quipped “in 5 years we hope to put Paypal out of business in the US”… implying banks could lock out non-banks in riding ACH rails. This would also have significant implications to MCX… My view is that there are ways to get around all of these grand plans IF they ever materialize (ie Bank partnerships).

All of this seems a little too smart, too complex, too dependent on regulations by a regulator that isn’t really doing much to help Banks these days.

Message to Regulators.

PLEASE DON’T FORCE TOKENS.. but rather allow risk to be owned by non-bank entities (ex MSBs) originating transactions. There are so many new ways to mitigate risk and authenticate a customer. Mandating tokens will kill innovation and keep control locked inside intuitions that innovate at the rate of glaciers.

Reminds me of a joke. Did you hear about the Bank mobile SVP that tried to commit suicide? He threw himself in front of a Glacier.

Authentication is key to unlocking billions of dollars in revenue and bringing enormous efficiency to the market… allowing for the REWIRING of Retail, Advertising, Commerce.

Regulators should not focus on payment tokens, but facilities for managing distributed TRUST and AUTHENTICATION. Allowing other entities to assume risk in payments. This may mean creating new quasi bank licenses (regulated trust authority) or a new federally approved MSB that does not hold any deposits. A first start may be to open up Fed Wire to non bank participants. With ability to take risk on settlement funds.

I actually agree with Banks in their token plans.. IF they are ultimately accountable for EVERYTHING.. they must control EVERYTHING.

 

“New” ACH System in US

The current ACH system will never go away (related blog). There were $33.91 TRILLION moved over the network in 2011, compared to total debit and credit volume of around $4.5 Trillion. However, there are several “improvements” to ACH where all could benefit, primarily speed and fraud management.

19 Feb 2013

(sorry for typos in advance)

Thought I would add a little meat to my 2013 prediction on a new token based payment scheme in the US. 60% of the thoughts below are contrived… as participants and pilot results are not in.. and things are still evolving.

Prior to describing a “new” ACH system, it may be useful to understand what banks are looking to achieve.

  • Stop the dissemination  and storage of DDA RTN and Account Numbers
  • Control the bank clearing network. Particularly third party senders and stopping the next paypal
  • Improve clearing speed (new rules, new capabilities to manage risk)
  • New pricing scheme somewhere between debit ($0.21) and credit cards
  • AML controls (per yesterday’s blog on HSBC)
  • Taking Visa and MA out of the debit game (yes this is a major story)
  • Maintain risk models (see both sides of transaction)
  • Control Retailer’s efforts to form a new payment networkTPS Definition

Overview

The current ACH system will never go away (related blog). There were $33.91 TRILLION moved over the network in 2011, compared to total debit and credit volume of around $4.5 Trillion.  However, there are several “improvements” to ACH where all could benefit, primarily speed and fraud management. Thus I believe there will be a carrot and stick approach to creating the right incentives for ACH users to move. The highest priority will be around third party senders (TPS), the lowest priority will be regular customer directed debits and payments to billers.

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

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

Scheme (updated 2/20)

  • Token will replace DDA RTN/AN. Starting with ACH Debit, Third Party Senders will be required to use token for access to top 5 banks. Consumers will not know their “token” as it is unique to the requester.
  • Third party sender (TPS/TPPA) must request token for originating consumer account from consumers bank (more on business incentives below). This establishes a “directory” role for the consumer’s bank and positions them to “approve” ACH Debits, where today the responsibility is only on the ODFI.
  • The bank owning the consumer account will be the owner of the token. Individual banks may choose to issue tokens, tokens will be synchronized with a central director, banks not wishing to issue their own tokens may depend on the central directory for issuance.
  • Once a token is issued, a third party sender will use the token to debit consumer account just as the account number is today. However tokens may be unique to each TPS/TPPA
  • Individual banks may clear payments by using their own local directory, or leveraging the central ACH service. There are no forced routing rules (learning from VisaNet).  Banks also agree to collaborate on fraud and risk (keep information fresh).
  • A token will be unique and represent a combination of both sender and beneficiary information. Focus is initially on ACH Debit. Unclear if multiple tokens will be required in MSB scenario. Banks want visibility beyond settlement account. Multiple ways to achieve.
  • Members of scheme agree not to store consumer DDA/account information after token is received (think PCI for ACH).
  • Token issuance (by the originating bank) will take into account, KYC, fraud and other factors
  • Tokens may be revoked and tokens may correlate to risk/fraud information
  • TPS may be required to include beneficiary information for ACH Debit (my guess here). This may take the form of a unique token for every originator-beneficiary combination.
  • Authorization and intra bank settlement begins to look exactly like debit card/ATM. Only piece missing are agreements which would support usage outside of V/MATPS Noyes

———- Update 20 Feb—————————————-

It seems the Directory service has credit and debit cards in scope… I haven’t fully processed this one. Why would Visa and MA want banks wrapping the card number? Talk about a scheme to cut them out of the loop. Once proxy numbers are issued they could just dump other networks immediately..  Merchant acceptance becomes the big question mark if this is the case. My guess is that banks will focus on mobile, and eCommerce.. defeating V.me, I’m sure CYBS, AMZN and eBay will all jump at the chance to help banks with their tokens

Token provider rumored to be start up Venmo

—————————————————————-

Carrots/Sticks

In the ACH world, the big banks rule.. and make the rules. My guess is that the top 5 banks will inform (and subsequently enforce) a rule on all TPS ACH debits requiring use of Tokens to access consumer accounts. Given that the big 5 have over 50% of the accounts… if they act in concert it will certainly impact the network. The focus of their action is on Third Party Senders, with mobile payments and remittance services as primary examples.

  • NACHA may issue new rules which will change existing ACH. My guess is that we will have a new transaction type (associated with TPS, and token). Note that new NACHA rules become law uniform commercial code.
  • NACHA has already begun tightening requirements on TPS/ODFI relationships (Section II, Chapter II (ODFIs), subsection B-3)
  • Banks which serve as correspondent aggregators of ACH (for MSBs/TPS) may be pressured to make immediate changes (beneficiary data, tokens). These payment aggregation banks (which frequently serve as ODFI) will likely not be part of the system design
  • To “enforce” the rule changes, the large banks will set a date where they will not accept transactions that do not conform
  • There will likely be “options” for fraud checking, and accelerated clearing cycle (Carrot?)
  • Processing Token transactions will have a different baseline fee

Implications

  • If your clearing bank is not one of the top 5, they may not even know this is going on
  • PayPal, MCX, Google Wallet, Target RedCard are all likely dependent on some form of ACH. They will likely have incremental costs associated with ACH origination as a third party sender. My guess is that it will be at least $0.21.
  • The big 5 banks will be best positioned to help any start up navigate this changing environment.
  •  It may be better for start ups to focus on obtaining consumer debit card information vs. DDA
  • Small banks that specialize as ODFIs will be squeezed
  • The cost of ACH is going up..

Need for Bank Payment Councils

Banks must reconstitute their payments councils, to drive incremental revenue and cement their role as gate keepers of customer information and payment settlement. The primary threat to them is pre-paid, decoupled debit and MNO led schemes at POS.

10 Dec 2010

Bank Innovation

Much of this post is derived from my original Feb Post “Wanted: Payments Leaders”. The original was directed to small companies operating in this payment space, this article is for banks.

As an investor and banker attempting to connect capital to innovation I see $50B in investment capital focused in payments over the next 3 years.  Most banks do not treat “payments” as a line of business outside of cards, this is a mistake. Banks typically allocate resources by product lines: Assets, Liabilities, Card, Investments with some pricing provided by segment. Payments are managed as a common service across these product lines (if managed at all).  Banks like Wachovia managed this quite well, with the CEO and all LOB heads attending a quarterly “payments council” to discuss payment strategy, investment, and initiatives (led by a super exec: Lou Anne Alexander).  From an inter bank perspective, much “payment strategy” is discussed within the bank consortiums:

  • The Clearing House (TCH) Jamie Dimon Chairman
  • Early Warning
  • BITS
  • NACHA

However “discussion” is usually focused on existing business and processes. Also note that the inter-bank POS discussions which your CEO had with Visa/MA (during the days where you owned them) are now gone. If I asked your CEO what your top 3 payment initiatives were would they know? My guess is that all 3 would be card related, as it is the only LOB (and defined P&L) focused on payments.

Banks must reconstitute their payments councils, to drive incremental revenue and cement their role as gate keepers of customer information and payment settlement. The primary threat to them is pre-paid, decoupled debit and MNO led schemes at POS. In order to coordinate collectively, they must first organize internally. The business threat is beyond interchange, as revenue from new payment models will come from advertising and behavior based incentives. There is a coming convergence of the digital and real world.. and you must create teams that span your organization to execute against it. Today the bank model that you should follow? Citibank’s new organization under Paul Gallant. 

Within the next 3 years, we may see the birth of 1 or more new bank led payment networks (yes leaving Visa/MA) as well as a bank led acquisition of Discover, or Merger of Amex and a major bank (Amex attempted merger w/ Wachovia back in 2003).  Additionally we will see $2-5B investment by groups like ISIS.

The amount of activity is tremendous, but banks have a clear advantage in resources they can dedicate in coordinating a response. There is no shortage of innovative people within your banks today, but there is a need for structure through which their excellent ideas make it to market.

Key Skills

  1. Define and evolve a core value proposition
  2. Ability to define regulatory risks and operational approaches to address
  3. Attract and retain start talent
  4. Ability to manage a P&L
  5. GLOBAL Payment Operations experience (the regulators are shutting us down)
  6. Sales skills (direct to consumer and/or business sales)
  7. Network within the Industry (what is everyone else doing)
  8. Manage a BOD
  9. Ability to listen to the customer and adapt
  10. Historical knowledge of payment initiatives
  11. Ability to drive complex technical initiatives
  12. Understanding of competing networks and value propositions
  13. Comfortable in the details and the strategy
  14. Can coach a people and build a team

Other related blog

http://tomnoyes.wordpress.com/2009/09/24/googleoff/