Firethorn gets new CEO

9 March 2010

Press Release

Previous Post “Obopay and Firethorn”

Great news for QCOM this week. Firethorn gets a new executive with payments experience… AND has tremendous start up experience. QCOM is one of the best run, most innovative companies on the planet.. they are everywhere in mobile.

Rocco has a clean slate given that Firethorn’s current customer list is rather sparse (?US Bank?). My recommendations for Rocco:

  • Dual track org: Short term quick hit and a strategic initiative
  • Short term: find some low hanging fruit and attack and forget about the banks in short term (they take too long)
  • Long term: better to “enable” 1M+ of businesses than to “own” a single product…. that is the model of QCOM. Example: Authentication. http://finventures.wordpress.com/2010/03/11/5b-mno-opportunity-kyc/
  • Leverage existing assets and relationships, listen for key opportunities
  • HR: Look at the team you have in place and shake it up… substantially. Start cross pollenating with the rocket scientists at the parent company.
  • Financial: I’m sure Rocco worked this out w/ Dr. Paul already.. but there are few path’s to revenue in 2010 unless there are some reallocation of assets.  Example, QCOM is investing in integrating NFC into chipsets. Should this be owned by firethorn? or should just the software that runs on the chipset?
  • Go global. The only alarm bell on Rocco is that he is lacks much international experience. Most of the innovation in mobile (payment) is taking place outside of the US. He needs a solid global team that can ensure that Atlanta prioritizes the global need.

– All the best Rocco

Obopay and Firethorn

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

Social Payments: Paying the Blogosphere

19 February 2010

This could be the death knell for established news organizations. Having just renewed my subscription to the online Wall Street Journal last week, I was struck at how much of my news comes from informal social networks. I received a call today from a team investigating this space… quite frankly a fabulous payment idea: Paying the blogosphere.

Take a look at Flattr’s YouTube video to get the picture. [youtube=http://www.youtube.com/watch?v=kwvExIWf_Uc]

One of the many competing w/ Flattr is Kachingle (see patent application). My uninformed opinion is that services in this category can structure themselves as commercial services and avoid MTO regulatory burdens. Kachangle’s approach (described in patent app above) seems to be “billing as a service” … in essence users are buying a service for a fixed monthly subscription at $10/mo. Others “social payment providers” contemplating entry here should be very cautious to avoid used of “tokens” which can be “redeemed” (Big US issues here… See eGold and  US DOJ Final, US DOJ Indictment). The rule of thumb for operating in the US: regular payments for a commercial value added/reseller service.. Good.. flexible payments to anonymous end parties .. Bad.

Key payment considerations

  • Where is NewCo legal entity and target customer base?
  • Where is NewCo operating from?
  • Where is NewCo’s bank account?
  • Is it a commercial service or “money transfer”? You have a regulatory requirements with either, but money transfer services are much more burdensome. If commercial service, then commercial requirements typically dictate disbursement KYC as well as tax/revenue reporting.
  • If service is money transfer, business will not only face regulatory hurdles, but also payment clearing hurdles associated with “payment aggregation”. Networks do not want intermediaries operating a payment network within their existing network as they loose their ability to manage regulatory control (ex. AML, sanctioned payments, …)
  • How does NewCo move money in? Cross border? Who will bear regulatory risk? Clearing bank? Network? NewCo?
  • Are there tokens or other stored units of value that can be exchanged?  

A great blog from a publishers perspective http://steveouting.com/2009/08/28/paycheckr-the-sharethis-for-donation-pay-options/

Customer Sat Survey Released

18 Feb 2010

ACSI just published results of the customer satisfaction survey.  Wells/Wachovia is #1.. keeping them in the spot for last 5 years (job well done guys).

Wells Fargo has emerged from its acquisition of Wachovia stronger in terms of customer service, rising slightly by 1% to an ACSI score of 73, which is the top score among measured banks in 2009. Wells Fargo seems to have benefitted from Wachovia’s legacy of strong customer satisfaction; for many years, Wachovia was the industry leader. By contrast, JPMorgan Chase has not performed nearly as well following its acquisition of Washington Mutual. The subsequent reorganization has been slow, and many Washington Mutual branches were still not rebranded as of the fourth quarter of 2009. Customer satisfaction with the new, larger JPMorgan Chase dropped sharply by 7% to an ACSI score of 68. To some extent, the story is the same for Bank of America. Its acquisition of Merrill Lynch made it the world’s largest financial services company, but massive losses have led to layoffs and substantial cost-cutting. Bank of America’s ACSI score dropped even further than JPMorgan Chase, tumbling 8% to an industry low of 67.

In addition to ACSI’s overall customer satisfaction report (all bank services) Change Sciences also released a new report this week ranking online banks by “online experience”, in this report Ally bank is ranked #1. The sites usability is just fantastic.. and sets a new bar for the big guys to follow.  Ally (was GMAC) is based in Charlotte and run by the former BAC internet management team. They were able to take the best and brightest from both BAC and Wachovia and have assembled a “dream team” of designers that have taken their game to a new level..  Congrats guys!

PayPal Shut Down in India

11 February 2010

NYTimes article from last night

India’s Central Bank Stops Some PayPal Services‎ – 

Simply put.. paypal has no license (See RBI list ) for Operating a Payment System in India under India’s Payment and Settlement Systems Act, 2007. The RBI published Annex I circular on November 27, 2009 (RBI/2009-01/ 236).

It Appears that RBI’s central issue is with PayPal’s role as an “unlicensed” Money Transfer Service. This issue is certainly not new to PayPal (see US Regulations – Online Payment/Transfer). As highlighted in the circular above:

All cross-border inward remittances under MTSS must be accompanied by accurate and meaningful remitter information (name, address and unique identification number of each remittance like, MTCN) on funds transfer and related messages that are sent and the information should remain with the transfer or related message through the payment chain. A unique reference number, as prevalent in the country concerned, must be included.”

Further, Paypal’s “agents must”:

Indian Agents should have effective risk-based procedures in place to identify cross-border inward remittances lacking complete remitter information. The lack of complete remitter information may be considered as a factor in assessing whether a cross-border inward remittance or related transactions are suspicious and whether they should be reported to the FIU-IND. The Indian Agent should also take up the matter with the Overseas Principal if a remittance is not accompanied by detailed information of the fund remitter.

Issue for PayPal is that its “agent” in this case is its commercial bank that initiaties the domestic ACH. My guess is that they are also in a bit of hot water for allowing this connectivity in light of the Nov 2009 circular (and subsequent inaction).

In order to resolve RBI’s issues, PayPal must:

  1. Obtain an MTS License (or a Payment System License)
  2. Renegotiate terms and services with its clearing bank(s) so that they will comply with “Indian agent” responsibilities above, namely PayPal must provide detailed information on remittance (above) to clearing bank and hold information in country so that bank can perform both AML sanction screening and other SAR reporting
  3. Put the detailed technology plan in place capture and send information to bank
  4. Review Plan with regulator
  5. Obtain regulatory approval on end state plan and request exception process for operating until final (end state) is in place

India’s regulators are some of the toughest on the planet. They expect that organizations read their guidelines.. “Better to ask forgiveness than permission” is a regulatory approach that probably works best before you are public company.

Note that PayPal’s “merchant” transactions (where an eBay buyer is paid) are not covered within the MTS regs above, unfortunately for PayPal it is difficult to screen these commercial transactions from other payments,  hence the broader impact in clearing both commercial “merchant” ebay payments and P2P/Remittances. 

My related Post

Cash Replacement

NACHA on Aggregation

SEC AML/Patriot Overview Regs

NFC Tea Leaves

9 February 2010 

Previous Post http://tomnoyes.wordpress.com/2009/12/23/visa-att-mobile/

In the last week of December I made an “informed” prediction on a major NFC announcement…. the predicted time has now past.. and… no announcement. This seems to be common place in this space.. NFC presents the best chance for development of a new ecosystem and a new “boom” for small companies… Unfortunately the keys to the “ignition switch” are held by multiple established (read entrenched) overlapping and competing networks (bank, mobile, card, …). Apologize for getting hopes up.. it does look like more of a slow burn than “break out”..

Visa’s mobile apps at CES 2010

[youtube=http://www.youtube.com/watch?v=c3Ff6uYXBD0]

VivoTech

[youtube=http://www.youtube.com/watch?v=Kzyy6ZLbDZk]

All of the activity listed in the previous post has been validated:

– FirstData is acting as a TSM (in vein of Germany’s Giesecke & Devrient)

– Visa does have €200MM planned for NFC (See here)

– Top 3 US bank is planning a major mobile initiative w/ Visa to roll out in early 2Q

– AT&T has TBD initiatives into pre-paid card and pre-paid plans, I do have conflicting information on whether this will be led by AT&T or Apple and time period has extended significantly.

 

 

http://www.youtube.com/watch?v=330RZpwrmAg

http://www.youtube.com/watch?v=z0BwYz1P0BE

 

 

US Regulations – Online Payment/Transfer

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

SEPA: Chicken or the Egg?

4 January 2010

I was reading an update on SEPA : New Alliances Required to Tip the Market. The report gave me new perspective on how challenging it is to change a networked business. This challenge is exacerbated by the ‘well intended’ EU political compromises in SEPA (specifically) and EU regulation of retail finance (more broadly). Clearly “payment networks” can benefit from innovation, but as Juergen correctly states “In a network industry, cost reductions and/or additional revenues that can be realized by applying the new standards have to exceed the network effects currently realized with the old standard”.

SEPA is struggling to resolve issues in cost/benefit allocation given the slow growth and adoption for SDD and SCT. The greater growth in SEPA Cards Framework can be attributed to the “control” and investment from Visa/MA as they manage compliance (and marketing) or the new SCF brand. An excerpt from the report above:

Key strategic decisions have to be made almost simultaneously in organisations that are in competition with each other, follow different strategies and have different abilities to innovate or prepare for an industry change. Only if consensus on a new business model can be reached – among stakeholders who represent significant market shares and hold key positions in the industry– will it be possible to generate the synergies promised by SEPA. As already described, the cross-border business within SEPA represents only a small share of the payments market. The dominant national standards, which all would have to be replaced by the new SEPA standards, are built around national market requirements.

International banks (for example, Deutsche Bank) have separate organisational units in several European countries that run their own national payments engines. They maintain different payment infrastructures in Europe. Modifications in response to new compliance requirements (for example, money laundering or new requirements of the PSD) create several similar projects [for this single bank]..

The costs for SEPA (estimated at €10B) fall heavily on the banks, and the benefits (ex. e-invoicing, cross border competition in payment products, …etc) are expected to be realized by the consumers of bank payment services (with and estimate €7B revenue hit to banks). Fortunately for the Banks, in 2002 the approach decided on by the EPC was to create SEPA in a market-driven and self regulated process.

The over arching goal of SEPA is to make the EU a single market on “payment” par with the U.S. Perhaps the best way to start is not by incenting changes to “payments”, but to open the EU retail banking market. (Think of the US banks operating under a Fed charter).  “All banking is local” can be the mantra ascribed to the EU today, with each country maintaining tight regulatory control over domestic financial institutions (i.e. M&A and Liquidity). Significant market forces could be unleashed when local banks can operate throughout the EU, and a German consumer can seek the best rate and apply for an account at a “Spanish” bank.  Today the regulatory hurdles for this retail competition are significant.

The EU, ECB and the EPC started with payment standards and “infrastructure” as it did not alienate any of the existing participants (market driven.. .not mandatory). What we have is the fruit of this compromise, standards for payments across the EU without the ability for companies to compete for business across the EU domain. The unrealized value of the “SEPA Innovations” are thereby constrained by the market in which banking operates. Perhaps integrating EU retail financial markets would be a better first step. This “openness” would certainly provide an attractive carrot for bank led investment in common payments. Which comes first? The Chicken or the Egg?

See data here

CapCo Analysis

NFC Break Out – VISA/FirstData/AT&T

23 December 2009

Previous post http://tomnoyes.wordpress.com/2009/11/25/visamobpay/

Get set for a major announcement in next 4 weeks from Visa, AT&T and FirstData that will combine an AT&T pre-paid card account, managed by FirstData, and with services from several Visa led start up companies  (both mobile advertising,  couponing and NFC). Consumers will be issued NFC stickers for existing phones and can fund the account with existing card and deposit accounts. AT&T will also have an integrated reward system to reward payment activity with coupons, airtime and special offers with participating merchants. In addition to the NFC sticker, Visa will also be trialing other “other form factors” including: plastic, handset integrated NFC (new phones) and 3rd party hardware for OTA provisioning. FirstData will begin a new role as both the processor and Trusted Service Manager (TSM).

As stated previously, the US market is ripe for a break from the 6 party political “fur ball” that is hampering mobile innovation (Card Issuers, Acquirers, Network, Merchant, MNOs, Handset Mfg). Mobile Network Operators (MNOs) are better positioned to execute in mobile payment in all markets. AT&T is no stranger to credit cards, even today the ATT Universal card is the largest affinity card within Citi’s portfolio.  The implications for card issuers are unclear, given the uncertainty of “mobile payment” consumers behavior and payment patterns. There is a storng possibility that this initiative will be a “tipping point” in both mobile commerce, unleashing a new wave of innovation for all consumers (not just iPhone any longer). It will be very interesting to see if Apple is a part of this initiative. 

More to come..  

From Previous Post

For those outside the US, US MNOs have substantial control over handset features and applications, they have been leveraging this “node control” to “influence” direction of payments. The central US MNO argument being “it is our customer, our handset, our network we should get a cut of the transaction rev”. Unfortunately existing inter-bank mobile transfers/ payments are settled through existing payment networks that provide limited flexibility in accommodating another party (beyond issuer/acquirer), with much room for improvement in authorization, authentication and consumer “control”. 

Outside the US, the situation is much different, as consumers have great flexibility in switching MNOs, have ownership of their handsets, and are largely on pre-paid plans. The MNO challenge for payments in this environment is largely regulatory.  Many countries (EU, HK, Korea, Japan, SG) have open well defined rules for MNOs role in payments (example: ECB ELMI framework within the EU), while other countries are highly restrictive and are in the midst of developing their legal and regulatory framework.  Even in the countries where MNOs participation is defined, they have largely benefited from the complimentary role that the service plays with pre-paid plans (not in interchange at POS).

Globally, MNOs are looking for a payment platform where they can benefit from interaction between consumer and merchant, with flexibility to deal with a heterogeneous regulatory environment. The competitive pressures on Visa/MC are much different then they were 5 years ago (when both were bank owned). The network fee structures and rules were written with banks and mature markets in mind. Emerging markets present a much different set of opportunities, as MNOs lead banks in brand and consumer penetration within every geography.

All of this leads to the case for a new “Mobile Payments Settlement” network, a network which will alienate many banks.  I expect to see Visa roll out the initial stages of this network in the next 2 months with an emphasis on NFC. Quite possibly the best kept secret I have ever seen from a public company. I’m sure many Silicon Valley CEOs are crossing their fingers (with me) on this, as a “new wave” of innovation is certainly close at hand that will drive growth (and valuations).

For those not keeping up with the 50 or so product announcements a day on NFC, handset manufacturers committed to have NFC enabled phones to consumers in mid 2009 in the GSMA 2008 congress. NFC capabilities are numerous (Vodafone YouTube Overview), and may represent a true disruptive innovation surrounding payments. There have been many very recent product announcements that will enable existing phones to use NFC, and P2P Capability. All of which will blossom in a more “fertile” mobile settlement environment.

Side note: This is not all bad news for Banks, as the structure will certainly provide for existing cards (debit/credit) and may deliver substantial revenue through cash replacement (small < $50) transactions.  More details on structure of MNO in settlement 2 weeks….

Select Product/Alliances Below:

Cash Replacement – Part 2

December 15, 2009 (PDF VERSION HERE)

Part 2 – Cash Replacement (V1)

In my previous Blog (see Investors Guide to Mobile Money) I outlined a simplified categorization of payment schemes for “first world” economies. The common win-win for both mature economies and underdeveloped appears to be Cash Replacement. Cash Replacement has been the subject of thousands of reports originating from: economists, bankers, academics, non-governmental organizations and consulting groups (a few of which are listed in references below). The objective of this blog is to provide a market basis for investors and small companies attempting to “quantify” the opportunity in cash replacement, specifically e-Money and non-card based schemes.

Global debit and pre-paid card growth have been the key instruments leading in cash replacement use within top global economies. The card infrastructure (ie “card rails”) that provided for this success was “built” on the credit card value chain over the last 35+ years Cap Gemini’s 2009 World Payment Report provides an excellent overview of key trends. Key excerpts below:

  • The worldwide volume of payments made using non-cash instruments (direct debits, credit transfers, cards and cheques) grew 8.6% to 250 billion transactions in 2007. The use of cards continues to be the single strongest driver of volume growth. Global card transactions (credit and debit) grew 14.5% in 2007.
  • The ten largest markets accounted for 92% of all non-cash payments transactions in 2007 (when they represented 84% of global GDP).
  • Unlike in the US, where cash in circulation has decreased by 7.4% in 2007, cash is still increasing in Europe, albeit at a slower rate of 7.8%.

Background

A historical review of products attempting to gain traction in cash replacement reveals a battlefield littered with the “corpses” of plastic and digital products.  (Ref 1)

  • Mondex, now owned 51% by MasterCard and national franchises owned by big banks, is after years of testing still confined to trials, often internal to banks.
  • VisaCash. See history here http://www.mondex.org/main_page.html.
  • DigiCash eCash, licensed by several big banks worldwide
  • CyberCash never rolled out a stored value system at all; after announcing a trial in September 1996 the CyberCoin system was never rolled out except on a limited scale at Barclays in the UK.
  • eGold. http://lawvibe.com/e-gold-founder-admits-e-gold-used-for-money-laundering/
  • Geldkarte in Germany
  • Paybytouch
  • Obopay

These “failures” were less to do with technology, and more to with competing against an existing payment network(s). Payment networks are inherently “sticky” with investments required by consumers, merchants, and banks for effective functioning. Payment networks also have substantial government involvement to support Commerce and Treasury functions that ensure stability, resilience and protection of parties. Innovation in payments is challenged by this network dynamic. As most small companies know, getting a bank to make a decision is tough… but nothing compared to getting 4-6 groups (issuers, acquirers, merchants, MNOs, Regulators, networks, ..) to collaborate in making coordinated change. A level of difficulty that is only superseded by the challenge new entrants face in competing directly against these existing networks.

Why read further? Although I’ve painted a very negative picture of past payment failures and the challenges of competing against the traditional networks, the payments business is undergoing tumultuous change and where there is change, there is opportunity. To understand the forces and competitive dynamics of cash replacement, it is important to understand both the local and global forces driving this change (see pdf above).

Emerging Market Regulation

As this blog is largely focused on emerging markets, it is worth noting several “unique” regulatory challenges within emerging markets as regulations surrounding MFIs and Money Transfer Services have been evolving at an astounding rate.  This regulation evolution is not taking place in a vacuum, as regulators always work with the entities they regulate.  Teams capable of local engagement and partnerships are therefore much better suited to operate in this dynamic regulatory environment. As an example, Vodafone has developed enormous competency in the payments space, extending not only its “product” success in MPESA, but developing talent which can be leveraged to seed other local teams (in the 40+ markets it serves).

As a generalization, there are 4 bodies of legislation that impact mobile money:

  1. Bank Regulation (particularly role of non bank agents, and payment networks)
  2. Micro Finance Institution
  3. Electronic Transaction Legislation (Consumer protection, admissibility of electronic records, prosecution of electronic crimes, …)
  4. Telecommunication Regulation

MNOs success to date has not been in isolation, given that in every instance (above) the MNO partnered with either an MFI or Bank.  2009 Mobile Money Summit in Barcelona provided several excellent presentations covering the global regulatory environment, an environment that is both complex and evolving. It is imperative that your team understand the local regulatory environment. Regulatory changes have significantly impacted many investments made to date, with the key example of Reserve Bank of India’s Aug 2009 regulation preventing non-banks from domestic money transfer (destroying Obopay’s P2P plans).

Network Effects – Stating the Obvious

For payments to flourish, a coordinated system of instructions which can be read by trusted participants is necessary. Providers of payment services must consider what network participants are providing in order to collaborate in risk management and settlement; the greater the number of consumers and businesses that participate, the greater the collaboration and interdependency. As more people adopt the payment system, its value increases, since it provides access to more people; this encourages larger networks. Not only do the benefits increase as the network expands, but the per unit cost of service falls. This behavior is the basis for what economists refer to as a “network effect”.

Once a payment system reaches a “critical mass”, economic value will be created at the ends of networks. At the core- the point most distant from users-generic, scale-intensive functions will consolidate. At the periphery-the end closest to users-highly customized connections with customers will be made. This trend pertains not only to technological networks but to networks of banks as well as small merchants and even to consumers who engage in shared tasks9. From a payment network perspective, this means that the “routing” of payments will provide much less revenue opportunity than managing the end points (e.g. the customer interaction or the products which are sold on the network).

Transportation has proven to  key opportunity for electronic money: Oyster in the UK, Octopus in HK, CashCard in SG, …etc. Success in these transportation initiatives has been “relative” because they have been challenged to generated consumer adoption beyond transportation “core”, and they have note generated an attractive margin to the network (for the economic reasons that Georgios lays out above).

The European Central Bank (ECB) has provided a new regulatory framework for electronic payments (see ECB ELMI overview by M. Krueger, and World Bank). The ELMI framework, as well as Singapore’s Electronic Legal Tender (SELT) concept, demonstrate a tremendous collaborative multi year effort between central banks, governments, financial institutions and business to provide rules, law, consumer protections and an environment which would support alternatives to cash. However, it also highlights the scale of effort needed to move a consumer behavior that has existed for millennia.

Financial Case

In general, economists and bankers agree that there is a strong macro economic case for cash replacement when accounting for the “shoe leather” costs (Ref 5). However, it remains to be seen “who” will pay for this convenience. Ref 1. Electronic Money and the Possibility of a Cashless Society by Georgios Papadopoulos provides and excellent analysis:

“…the high social cost of cash is all too general. The costs and the benefits for cash as well as for electronic money are not distributed evenly. The cost of issuing cash is paid by the state and financed by taxation. Most of the infrastructure for e-money is paid by the issuer, which in turn is charging the user for this payment instrument, even though the distribution of the costs between the consumers and the merchants is uneven. Consumers may pay a fee for the card (either directly or as a part of their checking account), while merchants have to pay a fee to the issuing bank(s) either pro transaction or as a percentage of the total value of the transactions and in addition carry the cost for the infrastructure“… from Georgios Papadopoulos

This “free nature” of cash, combined with its unique qualities (i.e. anonymity, history, physicality …etc.) further challenge new payment models and the barriers they face from existing card and bank networks. Payment networks are resilient, this is both a strength and a weakness. In 2000, the average transaction cost for credit card transactions was around US$0.70 (ref 1) and thus did not serve as a viable option for cash replacement. At the time, VISA cost studies showed that card transactions of amounts of less than about US$10 are in fact unprofitable for the Issuer bank and amounts of less than US$38 are unprofitable for the Acquirer bank. Any product attempting to take the place of cash must make low value transactions efficient and profitable to the parties providing the service.

The “debit revolution” for the card networks began with pricing and risk. For the non-bankers reading, issuing debit cards was (and still is) a highly contentious fight within banks. Large issuers did not want to forsake the high margins of credit cards (350bps + interest on ANR) for the paltry returns of linking a current account to a card (150-250 bps and no interest income). This fight was exacerbated by the fact that banks typically run the “card business” separate from the deposit “retail” business. Banks began supporting debit when they realized that Debit DID NOT displace credit cards, but rather supplemented it, providing net incremental (non-interest) revenue to the bank. After this realization, banks then began to take issue with PIN Debit vs Signature (another story).

The story of interchange rates, and how they are negotiated is complex and full of intrigue. For those of you interested, read the US Federal Reserve’s “History of Interchange”. As you can see from the table above the trend (across all products) seems to point “north east”, a trend not lost on merchants and consumers. It is important not to assume that these rates will remain static. Banks (issuers and acquirers) can respond to competition, a state which does not seem to be of an immediate threat.

The debit success led the way for pre-paid cards. Pre-paid may present the best “global” opportunity to reach unbanked customers and further impact cash (See US Federal Reserve Study on Prepaid). Pre-paid is a category with both open and closed loop models. Open loop prepaid has benefited from Visa and MasterCard’s recent independence from their bank ownership model (in 2008 and 2006 respectively). In the US Pre-paid has seen substantial participation from non-banks such as Wal*Mart (11/2009 American Banker) whose business strategy aligns well with reaching the unbanked and delivering disruptive value in bank like services.

US Federal Reserve – Interchange Fees (Cross border excluded)

In the US, Gross dollar volume (GDV) for all prepaid cards is expected to grow at a compound annual growth rate (CAGR) of 21%, approaching $250 billion by 2012. Open loop prepaid cards are likely to produce a 36% GDV CAGR and closed loop gift cards a 5% GDV CAGR between 2008 and 2012 (First Annapolis). The EU provides a much larger opportunity in pre-paid market. Research indicates that the EU prepaid market is likely to generate a turnover of €132 billion across the predicted 418 million cardholder base, with transaction volumes of 4.4 billion by 2015. Within Asia and Africa, it remains to be seen whether prepaid cards will gain traction outside of Japan, Korea, SG, HK, and AU. New payment innovations present opportunities for non banks to create local (non card) networks (ex: MPesa, ZAP, GCash, …etc. )

The network motivation for pre-paid is quite simple, just as it is with credit and debit, there is very little incremental costs to adding transactions to the network. For merchants the incentive is to decrease costs. Unfortunately merchants are limited, within their existing card agreements,  in their ability to pass on these costs directly to consumers ( surcharge on payment type). This limits merchant ability to incent consumer behavior toward the lowest cost payment channel. An excellent paper covering network effects economics and interchange is covered in Ref 7 (highly recommend).

Global Network Volume – 2009

Card products (particularly debit) are filling most of the convenience gap, as PIN Debit competes quite well with Cash at most merchants (see The Move Toward a Cashless Society: Calculating the Costs and Benefits) Debit card volume growth has exploded globally, many would argue that it is the closest competitor to cash. Consumers have shown a tremendous reluctance to bear the “direct” cost payment. In other words: would I like to wave my phone at Starbucks to pay for my next cup of joe? yep… would I pay $0.10 for it? nope… I will use cash.

The payment heads at the major banks echo this view, as consumer data and spending patterns don’t reveal significant gaps where consumers report that they are not served by current payment products. Within Europe, cash replacement in areas such as ticketing and public parking shows significant price sensitivity on part of consumer (assumption of convenience cost). SMS payment providers are heavily subsidized and largely unprofitable.

Payment Costs

The benefits of electronic payments are not without costs. Most analysis estimate the cost of payments to be 1.10% – 1.60% of GDP (EU Reference, US Federal Reserve, Journal of Network Economics, Africa, ). Most analysis point to a significant “social” savings potential in moving from cash to electronic payments. However, this data is highly skewed toward developed countries (as significant differences in infrastructure are not accounted for).

Many emerging economies which did not “ride the wave” of consumer credit access have limited consumer and merchant payment infrastructure (ie. POS terminals, credit bureaus, consumer laws, …etc). In addition to infrastructure issues “Cash is King” in many of these emerging markets because no financial company has developed business model to profitably serve the rural poor.

Banks typically have challenges pricing “down market” as concern over cannibalization prohibit price led competition of channel focused products which compete with an existing product. CGAP research (also see IAMTN) shows that MNO pricing of money transfer services is substantially lower than services available from either money transfer services or banks.

Most interviewees in Kibera say they chose M-PESA because of cost. For example, sending 1,000 Ksh (US$13.06) through M-PESA cost US$0.39, which is 27 percent cheaper than the post office’s PostaPay (US$0.52), and 68 percent cheaper than sending it via a bus company (US$1.16).

Within emerging markets, the primary distribution channel is local agents (An excellent cost analysis for agents has been done by CGAP.) Agent incentives are a very important aspect to any emerging market business case.

Just as banks have used payments as a “loss leader” to generate revenue from other products (current accounts, cards, …) MNOs and their agents have created a model where payments enhance the value proposition of their core product (communication).

e-Money

The ECB definition of e-Money is

… any amount of monetary value represented by a claim issued on a prepaid basis, stored in an electronic medium (for example, a card or computer) and accepted as a means of payment by undertakings other than the issuer, predominantly for small-value transactions (for example, the settlement of modest transactions over the Internet and of parking or telephone charges and payment for public transport services)9. In common with banknotes and coins, e-money is ‘fiduciary money’, deriving its value not from its intrinsic worth but, instead, from the bearer’s expectation that it can be exchanged for its underlying value.

Successful eMoney initiatives, in both developed and emerging markets, have typically been tied to an existing value chain. A few examples: Paypal-eBay, Oyster – UK Transit, Octopus – HK Transit, Payforit – UK MNOs, MPesa – Vodafone Kenya, GCash – Global/BPI.  In almost every case, these initiatives began as a closed system and evolved to connect to other payment networks. Once value is stored in a network, every business will seek to connect, at an investment rate proportional to the network’s size, value stored and alignment to current customer demographic.

Paypal and Vodafone have shown that there are significant revenue opportunities in e-money. As the major card networks seek payment volume, they will likely develop new rate structures to incent MNO led payment initiatives to “ride on their rails” (ex. Pre paid card).

Network Profitability – 2008 US Volume

Mobile Money – Emerging Markets

The emerging market environment is a fantastic crucible for innovation as the network effects associated with the convergence of: finance, telecommunications, consumer access and business fuel economies within emerging markets. For those outside of the mobile payments industry, there are 3 principle emerging market success stories in mobile payments: M Pesa (Vodafone/Safaricom), ZAP (Zain Group), and GCash (Globe/BPI). Understand that my list is contentious given that all three are MNO led (I’m open to feedback, but it must be quantified by data). A more detailed list can be found here

M-Pesa certainly seems to win the “award” based upon Consumer Metrics and most talked about. Prior to getting started here, I encourage readers to review 2 fantastic briefs M-Pesa: M Pesa by Tonny Omwansa , CGAP brief. My stated bias toward MNOs in emerging markets (See MNOs Will Rule) is driven by the following facts:

  • There are 3 success stories as proof points
  • MNOs have developed a business model to profitably sell and service unbanked customers SEPARATE from banking (phone)
  • Payments enhance the MNO business model in emerging markets
  • MNOs have the resources to invest

The research on mobile money for the unbanked is tremendous and I can do no justice by trying to summarize. Imagine that you run a local shop in Kenya which sells dry goods and mobile phones, you must come up with 5 reasons why one of your unbanked customers would want to give up cash and pay a fee to load her money on cell phone. A few questions come to mind:

  • Value Proposition? Cost? Convenience? Will it make my life easier?
  • Use. What can I do with it? (something I can’t do with cash today)
  • Trust. Who has my money? Do my friends use it? Brand? Government?
  • Risk. Is it safe? (consumer protections, contract, access to legal system)
  • Support. Who can I see if there is a problem?

Previously I have stated a radical hypothesis: the successes above were driven by the mobile proposition (communication), and payment supported the existing MNO value proposition. The path of evolution for MPesa and its competitors are unclear and will be heavily influence by regulation. Today, MPesa operates out of a single commercial account with the central bank. That account has a balance of almost 10% of the GDP, a fact that highlights the potential to serve the needs of the unbanked.

The emerging market evolution is not so unlike that experienced with credit cards, although the “value chain” which drove the adoption is different. US, Japan, and EU access to consumer credit drove the development of the card networks; Consumer’s did not want a “card” as much as they wanted convenient access to a revolving credit line. In emerging markets it is the demand for communication that is driving the development of the network.

Investment (Greater detail in my previous post – Investor’s guide to mobile money)

As we look a cash replacement we will find that initiatives are frequent and success is not. It remains to be seen HOW the highly regulated world will evolve.  In the long term, Capital is attracted to success and growth. What we see today is a period of enormous flux and experimentation with established players making multiple “bets” (in the form of investment capital and revenue guarantees). Investments from established companies are in the form both in-house and partner led initiatives (examples: Citi Obopay, Obopay India, Nokia Obopay).

The Silicon Valley model, where a bet is made and a (US) team is built to “figure it out”, faces many hurdles; it is particularly challenged for creating products and services targeted to emerging markets (where paradigms are different and local knowledge is key).  Valuations today are driven by either: revenue, customers or board members. MNOs will lead investment in emerging markets, small companies must find a way to either collaborate with them (or their agents). ISVs should look 2 years down the evolutionary path where value begins to exit the “closed network”. Outside of the top 10 card payment countries listed above, 80% of the world’s population lives… a population that only shops locally with cash. You will have a hard time tackling this opportunity in Silicon Valley.

http://technology.cgap.org/2009/11/11/new-business-models-in-mobile-banking/

http://technology.cgap.org/2009/11/11/new-business-models-in-mobile-banking/

References

1 Why do stored value systems fail? Andreas Furche and Graham Wrightson NETNOMICS. Volume 2, Number 1 / January, 2000

2 Electronic money institutions – current trends, regulatory issues and future prospects, by Phoebus Athanassiou and Natalia Mas-Guix, July 2008. http://www.ecb.int/pub/pdf/scplps/ecblwp7.pdf

3 ECB 2008 Annual Report http://www.ecb.int/pub/pdf/annrep/ar2008en.pdf

4 Survey of developments in electronic money and internet and mobile payments, Sept 2004. Committee on Payment and Settlement Systems. http://www.bis.org/publ/cpss62.htm

5 The Move Toward a Cashless Society: Calculating the Costs and Benefits/. DANIEL D. GARCIA-SWARTZ, ROBERT W. HAHN *, ANNE LAYNE-FARRAR. American Enterprise Institute-Brookings Joint Center for Regulatory Studies

http://ideas.repec.org/a/rne/rneart/v5y2006i2p199-228.html

6 Optimal pricing of payment services when cash is an alternative/. Cyril Monnet, William Roberds. US Federal Reserve. Oct 2007. http://www.philadelphiafed.org/research-and-data/publications/working-papers//2007/wp07-26.pdf

7 Interchange Fees and Payment Card Networks: Economics, Industry Developments, and Policy Issues. Robin A. Prager, Mark D. Manuszak, Elizabeth K. Kiser, and Ron Borzekowski. 2009.  Finance and Economics Discussion Series Divisions of Research & Statistics and Monetary Affairs Federal Reserve Board, Washington, D.C. http://www.federalreserve.gov/Pubs/feds/2009/200923/200923pap.pdf

8 Electronic money and the possibility of a cashless society 18.02.2007. Georgios Papadopoulos http://papers.ssrn.com/sol3/papers.cfm?abstract_id=982781

9 ECB’s note on regulatory framework surrounding ELMI http://www.ecb.int/pub/pdf/scplps/ecblwp7.pdf

10 Where Value Lives in a Networked World, Harvard Business Review, Jan 2001, Mohanbir Sawhney and Deval Parikh).

11 NTT DoCoMo’s Osaifu-Keitai (http://en.wikipedia.org/wiki/Osaifu-Keitai),

12    “E-Money And Payment System Risks,” JAMES J. McANDREWS, 1999.Contemporary Economic Policy, Western Economic Association International, vol. 17(3), pages 348-357, 07.

13    The Economics of Interchange Fees and Their Regulation: An Overview David S. Evans and Richard Schmalensee

14    Why do stored value systems fail? Andreas Furche1  and Graham Wrightson.

15    Prepaid Card Markets & Regulation* Mark Furletti. US Federal Reserve. February 2004. http://www.phil.frb.org/payment-cards-center/publications/discussion-papers/2004/Prepaid_022004.pdf