Coupon Overload?

Best Bank Coupon Service? Bank of America wins hands down

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

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

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

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

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

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

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

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

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

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

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

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

Visa Digital Wallet

So what does Visa plan to do that PayPal doesn’t do already?

http://venturebeat.com/2011/05/11/visa-unveils-new-digital-wallet-for-electronic-commerce/

I look at this as a non-announcement, a rebranding of what CYBS and PlaySpan already have. Too many teams are angling to create the wallet (mobile, online, …), and not enough focusing on the value of what is in it. Google, Apple, and RIM will win the mobile wallet wars. I guess I can’t blame Visa for trying.. however it would have been nice if they could have been successful at eCommerce to start with. If they had CYBS and PayPal would have never developed. I see little hope for them doing any better in mobile. They don’t own the customer and can’t really deliver any value.. but hey.. they have a tremendous number of nodes that they want to use.. too bad that the rules are so heavily driven by banks.

CYBS is a great company, in 2009 it processed one out of every 4 purchase transactions online, with over $120B in GDV. Small and mid size merchants flock to them because they are a one stop shop with great service. CYBS and PayPal both came to exist because card networks were incapable of helping either issuers or merchants manage the unique transaction risks associated with CNP transactions… as well as support for taking a card online. Visa has spent enormous sums trying to create improved authentication approaches (remember Verified by Visa?).  Their problem was not just technology and user experience, but business model. In the UK, VBV received substantial traction when merchants signed on to the liability shift. But then the issuers were left holding the bag for a broken technology with a merchants also suffering from drop off in completed purchases as customers saw a pop up ask for their PIN..

Rather than go through this terrible learning experience yet again they did the right thing and bought CYBS. Of course there were other synergies as well…  They now have an eCommerce acquirer. So the model is somewhat like DPS.. Get member banks to sign up their merchants, Visa gets a service fee, banks get a new revenue stream… ? Have you spoke to a happy Visa DPS customer?

Take a look at the banks that have signed on here. From the announcement: Barclaycard US, BB&T, Card Services for Credit Unions (CSCU), ICBA Bancard, First Financial Bank of Ohio, Nordstrom, Pentagon Federal Credit Union,  PNC Bank,  PSCU Financial Services,  Regions Bank, Royal Bank of Canada, Scotiabank, TD Bank Group (US and Canada) and US Bank.

Notice anyone missing? Top 5 issuers? Banks with significant merchant business?  What I would really like to see is the growth projections of this new service vs. what CYBS/Playspan would have done normally.

Digital Goods. Let me digress in an example. Why was Playspan so successful? Many reasons, but for one it had a substantial in store presence for gamers (with no bank account). Guess how much Playspan had to pay the card distributor? 15%. Will be interesting to see how Visa integrates a digital wallet with a cost of funds of 1500bps and then evolve to letting this same wallet be used for eCommerce. This may be why Visa is emphasizing card funding.. but guess what.. gamers (digital goods) don’t thrive on this model.

As a consumer, will I create a visa wallet to pay for goods? Why should I? What is in it for me after the bank has scaled back my loyalty programs and hit me with new fees.. ?

As a merchant will I switch to CYBS? Only if CYBS offers great service..

I just don’t see the value here.. someone please enlighten me. I do give Visa credit for dumping a VBV 3.0 strategy in favor of CYBS. What I love best is Visa taking out 2 great companies.  Now another round of start ups can develop to provide cutting edge service to retailers. The last great innovation from Visa was Debit.. well it wasn’t really from Visa.. … this does not feel like Debit.

I look forward to next 12 months when we will see 2 large issuers pull the Network brands off of their debit cards. In 5 years Visa will be left with credit only.. They do need a growth business.

ISIS: Antonym of Nimble?

ISIS – The Antonym of Nimble

Last week’s announcement that ISIS is abandoning plans for its own payment network (NFC Times) is not a surprise. This blog has covered ISIS since 2009 (before it had a name). Now we can add ISIS to the great names in mobile payments: PayBox, Obopay, Firethorne, Monitise, Enstream, …

It turns out ISIS was a Desert.. why have they failed?

  • Business Strategy based on “Control” instead of value.
  • Consortiums are not nimble, MNOs are not nimble, and a consortium formed around a poor business strategy will not be able to adapt without a very strong and experienced CEO.
  • Existing networks and ecosystems did not align with (or support) ISIS initial strategy.
  • Building a new network is an expensive undertaking.. building one without a value proposition is impossible

From my perspective the tipping point that killed ISIS was their inability to exert control over the secure element. Their entire business plan was dependent on this. When RIM announced its SE architecture 2 weeks ago, with Apple likely to follow.. it became perfectly clear that ISIS could not control and provision wallets, cards and applications that access the SE (related blog).

Mobile payments are still firmly in the hype stage. Until a real consumer value proposition develops that leverages the handset’s unique assets, consumer’s data, payment, retailer integration in a way where multiple parties can “participate” it will remain a niche. Getting excited about NFC is like getting Satellite radio in your car.. sure it’s cool and all cars will eventually have it, it may even improve your life.. but there are plenty of alternatives and many people have no need of it at all.

That said, there are many useful software products that could use this technology to deliver real consumer value. Most innovations are either targeted to either the top end (cutting edge performance) or to the bottom end (lower cost) of requirements. NFC adoption will take place within multiple solutions targeting the “top end”, each of which has a strong network effect component. Solutions will succeed either by delivering the most value point-point or through network scale. Payments are but one core service that NFC must deliver on.

From my previous Blog

Globally, MNOs are looking for a platform where Operators 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. …

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).

Why Visa, Apple and Chase are Square

Visa formalizes mobile swipe security.. ” Visa’s guidelines lay out some of the more important security measures that should be taken, including encrypting all account data at the card-reader level and in transmission between the acceptance device and the processor.” just like the Verifone CEO said.. 

Why did they do this on same day as announcing Square investment. All of these non-compliant doggles. What is Square’s Plan?

http://www.visaeurope.com/en/newsroom/news/articles/2011/visa_europe_releases_mobile_ac.aspx

http://www.businessinsider.com/visa-square-investment-2011-4 

Why is Visa, Chase and Apple all aligning on Square?

1)       Apple does not have NFC in iPhone 5

2)       Chase is taking a portfolio approach. This one is a bet against NFC..  They also have plenty of bets in NFC

3)       Visa knows it cannot control NFC and is taking a 3 pronged card focused approach to mobile marketing independent of NFC. Too much to say in this short Blog

Amex: Payfone and Serve

Updated 7pm Eastern (last paragraph on AML)

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

NFC Times: Amex Mobile Checkout Service

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

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

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

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

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

UPDATE

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

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

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

eBay/GSI Acquisition

Yes I am behind on the blogging….  I started putting this one together 2 weeks ago and it seems like ancient history.

PayPal + GSI Commerce

31 March 2011

Business Week Article: Why eBay wants GSI

GSI Commerce – Investor Presentation – Business Overview

eBay Presentation on Acquisition

This week has seen quite a few major announcements, with eBay’s $2.4B GSI (NASDAQ:GSIC) acquisition leading the pack. M&A activity in payments, advertising and Commerce (both online and mobile) is really heating up. I’m seeing substantial deal activity and active shopping.

Independent of price paid, I like eBay’s move here. GSI is a fantastic company providing turn key services to bring key brands online. GSI was the largest retail customer of my old company 41st Parameter. As you can see from footprint slide below, their capabilities are much advanced from Cybersource.. from hosting your site to selling and shipping your goods. Brands like NFL.com depend on GSI for everything and they solid customer satisfaction.

 

From eBay’s presentation:

  • Extends eBay Inc.’s reach with large brands/retailers …
  • Brings together complementary capabilities in a manner which strengthens GSI and helps our existing core businesses
  • Extends our open commerce platform capabilities

With this move I see a three (and a half) horse race for global eCommerce “turn key”: Amazon, eBay and Rakutan (buy.com).  Visa is the other half horse with the CYBS acquisition (primarily focused on payment). Amazon is far ahead in hosting (EC2), distribution, product selection, merchant services (large merchants), digital goods (books, music, apps, ..), consumer share of wallet, … etc.  eBay/PayPal has a few advantages in payment and small merchant services.

http://tomnoyes.wordpress.com/2011/03/10/paypal-to-drive-growth-at-pos/

Did anyone read John Donahoe’s Harvard Business Review Interview? He did a great job providing an overview of their strategy. GSI is increasing services to existing customers, and enabling faster expansion of fixed price goods. The POS initiative is an attempt to expand scope beyond the virtual world into the highly competitive merchant acquisition business. In 2010, US ecommerce was roughly $165B w/ 12% CAGR, while POS represents about $4.2Trillion.

Reaching the Unbanked: Thoughts from Pakistan

23 March 2011

(sorry for the typos in advance)

I’m up early in Dubai.. meeting with the UBL/Omni Pakistan team on their mobile money initiatives. I love visiting emerging markets to learn about successful projects. Pakistan is well on its way to becoming a leader in reaching the unbanked through mobile solutions, perhaps surpassing the Philippines, Brazil and Kenya. Beyond having a fantastic regulator, they also have 2 excellent teams:

#1 Abrar Mir of UBL/Omni and

#2 Nadeem Hussain, CEO of Tameer Bank, (ex Citi executive) Telenor/Tameer.

Make no mistake, their success to date has been 100% domestic.

In the US, we frequently get caught in a rather narrow “US centric” view of everything. Keeping a connection open to emerging markets is a great way to keep a fresh perspective and question “foundational” paradigms. New ventures in emerging markets are frequently challenged in attracting capital, even in high growth “BRIC” economies. Although many countries have worked hard to replicate the US venture model, few have succeeded. US/EU venture money normally focuses on investments which are geographically close to provide active management and reduce legal complexity (ex. control, investment, share holder rights, liability, intellectual property, …). Emerging market innovators are left with a much reduced set of options: “local” venture firms, banks, private investors and a small number of specialist US venture teams (Elevar, Omidyar, …etc).

Although Starpoint is 80% focused in OECD 20 countries, our emerging market activities are invaluable. My personal reasons for involvement are both philanthropic and aspirational. The opportunity to provide financial services for 600-800 million people over the next 6-10 years could be THE KEY event which drives global GDP growth (and hence poverty alleviation). Make no mistake the entire pyramid of consumers (affluent at top, poor at the base) will grow, but it is the base of the pyramid which will dominate the numbers.

For those of you that have followed my blog, I have been tracking several Indian projects over the last 2 years. I’m so frustrated by the bureaucracy and corruption in India, that I have given up on that country. There are a number of companies (ie Bharti, Vodafone, SKS…) that could deliver, but they are stymied by a regulator that cares more about control than progress ( MNOs Rule). It’s important to understand the political dynamics of emerging markets, particularly for well meaning investors that want to take part in the growth opportunity.

The last 7 years has been a time of much experimentation. Many mobile initiatives have been spun up by MNOs, Banks, Card Networks, NGOs, MFIs, MSBs, … etc. Within the unbanked world, MPESA stands out as the “model” unbanked success. It was started in 2004 by Vodafone after receiving ~2M GBP in grants (from UK’s DFID ). I’m highly appreciative of efforts by the World Bank, CGAP, USAid, UK’s DFID, NGOs… (Aid Groups). These teams are comprised of tremendous people driven to make a difference in the world. My trip to Dubai today was my first focused interaction with the Aid/NGO community, as most of my life has been spent in the private sector.  I have several observations which may be of benefit to start ups and investors in this area.

Objectives of Mobile: NGO/WorldBank/US Aid vs Private Sector

There are not many “new” ideas in banking. It is perhaps the world’s second oldest profession. Banking in emerging markets has several challenges: laws, consumer protections, consumer identification, literacy, bank infrastructure, regulatory infrastructure, … etc. This challenge is compounded by poor market profitability and network effects associated with existing money services providers (agents, money lenders,  foreign remittance, …).

For context, let me provide a very short primer. Poverty alleviation and financial inclusion is a primary focus of the world bank and many independent aid organizations. They come together in many areas, with CGAP serving as a key organization for collaboration. Micro Finance has been a key focus for this group over a number of years. A key “model” MFI is Grameen Bank, particularly after Muhammad Yunus won the Nobel Peace Prize in 2006 for his work there. There are 2 points I want to make on MFIs: they are “sustainable” at the margin and use very little technology (predominantly paper based in much of the world). For those interested in more detail I encourage a review of these 2 articles

As a banker and VC my immediate inclination is to recoil at any business which is not profitable. Profit is a sign of health of a business, if you don’t have it.. you die. However the objective of “aid” money is not profit, but rather to maximize the “impact” that every dollar of aid has. We all know the successful Aid examples of DDT, immunizations, pre-natal vitamins, .. etc. What happens when “aid” and NGO money floods into “banking” activities? Does it accelerate banking? Suppress margins? Create sustainable businesses or infinite dependencies? What is the right thing for Aid groups to invest in? Does Capitalism work in emerging markets?

Given that the US and UK dominate the Aid organizations, you would think that the last question would have an obvious answer. However, imagine yourself working in an Aid organization for 20 years, with very little time in the private sector. Everyone is biased by their life experience and in this case it is no different. Suffice it to say that there are tremendous differences in views and experience when compared to the private sector. These differences could become strengths if there was effective interaction between sectors (ex. CGAP’s market knowledge and Citi’s G2P Payments capabilities).

In my view there is much room for improving public/private collaboration, and many current Aid based efforts are at risk of negatively impacting market growth and adoption of sustainable commercial enterprises. One of the primary negative effects is subsidization of poor ideas. There are very limited market forces driving Aid based projects. Aid/NGO subsidies (note this is not investment) in commercial activities influence both price of services/products, the entities that deliver them, and consumer adoption. While the goal of Aid is to maximize “impact” the goal of investment capital is to provide a return, and hence sustainability. At a minimum, Aid groups must ensure that they have a team with experience in the private sector.

As I stated in MNOs will Rule in Emerging Markets, mobile operators are the first commercial organization to develop a sustainable model that serves the worlds poor. MNOs are clearly not philanthropists, they are focused on profitably serving their customers. MNOs have built both a physical communications network, and an agent distribution network that has driven their explosive growth. So while banking is the world’s second oldest profession, mobile operators are perhaps the newest. What happens when the 2 get married?

There are many, many groups seeking to take advantage of both of the MNO assets above. Both of these assets are networks and, as with any network, they are aligned to deliver value along well defined value proposition(s).  In my previous blog Will RBI Disintermediate Agents, I detailed the implications of hijacking the agent network for payments. The communications network is also an asset that can to deliver other services, it is a tool for “inclusion” as well as communication.

Mobile presents 2 primary “disruptive innovations” to the world’s second oldest profession: 1) Access/Cost to Serve and 2) Acquisition. Let me emphasize, mobile does NOT present a “silver bullet” solution to banking. Bank products must still be profitable. In emerging markets, banks have a very poor reputation at the base of the pyramid. Banks are limited in their ability to develop products which can be priced and distributed at the base of the pyramid, not just in emerging markets, but here in the US as well. Mobile banking will not solve this problem, but only allow poorly suited banking products to reach more people at a slightly lower cost. Although mobile does not significantly impact existing banking models, it may allow for the development of a “new products”, one of which is payments.

As I stated in Banks will Win in Payments, retail banks historically focused investment in credit related payments and treated DDA payments as a cost to retain the deposit account. Future mobile payments plays (bank driven) would center around a simplified transactional account to allow for cash in/out, domestic remittance and bill payment. This is not a savings account, nor is it a typical DDA. The closest existing product is a pre-paid card.. and there is a bank behind every pre-paid card in the world. Bank PPC revenue is driven by net interest margin (NIM) on non-interest bearing balance as well as transaction and account fees. A cardless mobile payment product has the opportunity to bring down cost to serve by eliminating plastic issuance, customer communication and account opening (ex. KYC at Agent). The world wide explosion of pre-paid cards should correlate well to the future explosion of mobile payment accounts.

In Pakistan, UBL/Omni is pursuing a bank led approach to this opportunity while Telenor purchased Tameer Bank to pursue an MNO led approach. I’m somewhat biased here, but the reasons I like Omni: it is “open” and can support multiple MNOs, interoperates with existing bank controls, full regulatory support, path to growth into more complex account types.

Conflicting priorities

I have never met an Aid organization or NGO that likes pre-paid cards. It seems their perspective has not changed in this new mobile account type. While I don’t fully appreciate their definition of financial inclusion, a non-interest bearing payment only account does not seem to qualify. CGAP/NGO needs and priorities would be irrelevant if their grants did not invest in competing models. One of their core issues is “closed” networks: Aid organizations hate them.  But as stated previously, every network begins with delivering commercial value to at least 2 parties.

History has shown that closed networks form prior to open networks (in almost every circumstance) as closed networks are uniquely capable of managing end-end quality of service and pricing. This enables the single “network owner” to manage risk and investment. How can any company make investment in a network that does not exist, it cannot control, at a price consumers will not pay, with a group that can not make decisions or execute? Answer: Companies cannot, it is the domain of academics, governments,  NGOs and Philanthropic organizations.

The success of MPESA, GCASH, UBL/Omni, Oi Paggo, .. clearly indicates that payments is a valuable service to the base of the pyramid. These are successful networks that have developed a specific value proposition. Aid groups have “impact” objectives which do not necessarily align to profit objectives of these networks. Opening a network in order to deliver a non-commercial value proposition is not an easy task.

As stated in Cash is King, I’m a pragmatist who firmly believes that the best approach to serving the unbanked is supporting a model where at least one entity has an economic incentive to invest. This is the definition of sustainability. The alternative to economic sustainability is unprofitable zombie shells that require continued aid and investment.

As I have stated previously (see Mobile Money: MNOs will Rule in Emerging Markets and Mobile Money: Emerging Markets/Emerging Models) MNOs operating in closed systems appear to be best positioned for creating a sustainable value proposition to the unbanked in next 2-3 years. My trip to Dubai also shows that a fantastic regulator and bank team can create a new bank product as well (UBL/Omni). 

Items for CGAP/NGOs

  • Investment in commercial efforts amounts to subsidization and “picking winners”. Are you operating as a VC? Be cautious of destroying a valuable service to the poor by compressing margins for entities that do not receive your grants.
  • Stop with the “openness” requirement. Closed systems must develop first… the biggest failure will be India’s common platform initiative. Who wants to invest in that?
  • Policy advocacy and best practice are win/wins
  • Don’t force the consumers into MFI deposits through mobile money. Help with marketing.. yes.. but be careful what you advocate. There is very little market data to support unbanked demand for savings.. it would seem they would rather buy a goat.
  • Don’t belittle or begrudge commercial efforts. What you want to encourage is sustainability and investment … the elimination of grants.
  • Every now and then.. perhaps you should get at least one person on your team with a private sector background. 

Collaboration Needed

The UK’s DFID was an excellent model for Aid, channeling it through a group (Vodafone) that could deliver a “prospective” solution for MFI interoperability. What really makes this model a success is that DFID provided flexibility in “impact” and allowed a commercial organization (Safaricom) to refocus MPESA based upon market needs and adoption. Remember neither DFID nor Vodafone ever anticipated the “payments” use until after the solution was implemented and in the market. DFID acted like a VC.. chartering a COMMERCIAL team to make it work.

There are several conversations which prompted this blog, which I can’t detail as my goal is not to deride the AID groups.. but rather highlight the challenge in investing in mobile money within emerging markets. Quite frankly I was shocked at the attitude of Aid/NGO organizations with respect to commercial initiatives focusing on unbanked needs (ex. SKS Microfinance). The idea of private money creating businesses that serves the poor at a profit was an anathema. The theme of Aid groups view on SKS’s efforts was “greedy capitalists, they just don’t understand microfinance”. Knowing SKS and their investors, this view could not be further from the truth.

As an independent 3rd party the NGO/Aid view may have been driven by a lack of experience and respect for the private sector. While I greatly appreciate their service to a worthy cause, they have a very biased view of solutions, business and economics. Differences in approach are frequently driven by differences in goals: Aid groups want to maximize impact, SKS wanted to build a sustainable business. The real issue is not the divergent views, but the divergent goals and the money being spent to pursue them.

Visa and Cashedge

16 March (updated 17 March)

http://www.prnewswire.com/news-releases/cashedge-and-visa-to-expand-network-offerings-118071239.html

Visa has been chasing after any party with direct links to DDA accounts. This in an attempt to “end run” around poor OCT adoption (see previous blog).  I understand that Obopay is also set to announce support of VMT. What a change from their MasterCard approach!

Visa is getting decent traction in Asia/ME in receiving VMT, problem is that there are no send capabilities, and the majority of banks are telling Visa to “pound sand” with their OCT transaction set mandate (see previous). I was told yesterday that the OCC is looking into both the mandatory nature of Visa’s OCT and the AML controls.

It will be interesting to see how Visa explains the loss of international wire fee revenue to their member banks. Why pay $40 for an international wire when you can use CashEdge to send to Visa, then VMT to send to India/Mexico, …? As I ran Citi’s online properties I can tell you this completely overlaps with my Citi Global Transfer service and I would not be happy at all.

As a banker, I’m mad as hell at Visa. Why don’t I like this VMT?

  • Visa will keep the directory of cards, mobile numbers, and DDAs. The last 2 really really make me mad. Who says they can hold my customer information?
  • Visa runs it..Continues to build Visa brand on your ACH
  • You own the risk, Visa develops new services
  • Circumvents all of the industry controls on ACH (ex. Early Warning)
  • Unfunded Reg E research burden and consumer support reqs.
  • Confusion in online services
  • Cannibalizes existing bank products (wire transfers)
  • Customer service/research nightmare .. all unfunded
  • Visa may have a much smaller role to play in debit.. why would I want to add new services to their group?
  • it will be very, very hard to shut down once it gets moving.

Fortunately for banks, CashEdge is a bank friendly vendor. Actually, it wins the prize for  best bank vendor (I signed 2 contracts w/ them).  Visa will not do enrollment, nor will they have directory of DDA/Debit. CashEdge is providing multiple service/pricing  options t0 participating banks:
– Send to DDA
– Send to phone
– Send to e-mail
– and new option.. send to Visa Debit Card (w/ fee)

Each bank has flexibility in determining IF they want these services and how to price them. As you can tell.. I would never let the Visa option happen.. but then again I don’t run the online bank anymore.

I’m beginning to wonder if I’m just a pessimistic nag. I’m tired of being negative on things… What do I like this quarter? Google and NFC, the Chase QuikDeposit app, PayPal at the POS, .. oh and I loved (past tense) ISIS until they fell on their own sword.

No blogs next week.. will be out of pocket…

Square “Violations”

16 March 2011 (Updated 17 Mar)

My top issue w/ mobile swipe is clearly customer behavior and potential data loss.  I’ve been asked to provide a basis to decline Square transactions (debit particularly) so, rather than sending out multiple e-mail responses, I thought I would share. Issuer Top 4 reasons to decline Square

  • PABP/PCI compliance
  • Collection and use of ancillary customer information
  • Paper Signature requirement
  • Chase has all of the equity upside

Visa developed the Payment Application Best Practices (PABP) in 2005 to provide software vendors guidance in developing payment applications that help merchants and agents mitigate compromises, prevent storage of sensitive cardholder data.

http://usa.visa.com/download/merchants/validated_payment_applications.pdf

 

Phase V of PABP went into effect on July 1, 2010. This phase required all Acquirers to ensure that their merchants and agents use only PABP-compliant applications. A list of payment applications that have been validated against Visa’s PABP /PCI DSS is available at www.visa.com/pabp. Note Square is missing, how can Chase acquire for merchant/aggregator that is in clear violation?

UPDATE 17 Mar (Thanks Bob Egan) Evidently PCI has revoked certification of all mobile swipes until new rules have been created. See related post  http://storefrontbacktalk.com/securityfraud/pci-council-confirms-multiple-mobile-applications-delisted/2/

From the Visa Operating Reg, (pg 428)

While Square does not “require” mobile number or e-mail address, it is collecting it at time of transaction (plus your location). As this information is associated with the transaction, it must be managed within PCI. The business risk here is that Square will use address and location information for something else.. or Chase gets the e-mail address of all of your card customers. This is why the rules were created.. so this does not happen.

Last is Visa requirement for paper receipts. From Visa’s Transaction Acceptance Device Guide

Chase bears all of the burden here, I hope they have taken a holistic view of the fraud and data compromise risk.. not just approving their own cards… but for every card ever swiped by Square.  Advanced fraud schemes take 18mo-2 years to develop.. so it may take some time for risk to materialize.. and for them to pull back.  Chase.. these future losses will easily wipe out the 15% of Square equity that you hold.  Perhaps they are moving so aggressively here because one of their key partners (ie Apple) is falling down in NFC.  Which brings to mind the larger question: Is Chase Anti NFC? 

Remember just 4 weeks ago that all of the US banks were looking at a future where ISIS would control NFC on the handset. Perhaps this is Chase’s way of developing an alternate strategy to address NFC’s biggest weakness: infrastructure.  If this is true.. then Chase I apologize.. your strategic play here was indeed valid. As of this month, we are looking at a ISIS crash and burn and NFC control with RIM, Google and Nokia. My hope is that Chase will abandon Square once the threat, of MNO control over payments, has been eliminated. 

Recommendation for banks

  1. Educate your customers. DO NOT give your personal information out when you use your card
  2. Start to educate your customers on mobile payments in general.. how will it work?
  3. Encourage use of credit over debit.. greater consumer protection and better margin for you
  4. Set some common sense rules .. use your card with trusted vendors (Apple, Grocery, … )
  5. Educate your customer facing employees from branch to call center..
  6. Think about your small business value proposition, how can you help small businesses accept cards?
  7. Issuers, think about declining Square transactions.. particularly for debit

Google wins in NFC! No NFC for Apple’s iPhone 5

14 March 2011

From UK’s Independent

No NFC for iPhone 5. Too many architecture considerations.. (previous post iPhone Twist) So while their patents clearly indicate NFC is in their plans.. they have not been able to coordinate all of the design into their iPhone 5 program (from hardware through software and apps).

 Brian White of Ticonderoga Securities  and I have both been predicting NFC, but we are obviously wrong.  The coordination necessary to bring about this change is tremendous. Vertical integration has its advantages in quality and control, but centralized control also prohibits distributed decision making. This is where closed platforms fail (Apple).

Just take a look at the NFC patent portfolios of some of the companies aligned to Google/Andoid (previous post). The Android platform is much more loosely controlled, which provides for distributed innovation and investment.

Make no doubt that NFC will come to iPhone, it just didn’t make the iPhone 5. This is good news for device fidelity.. and great news for Google. Apple may not be able to recover from this one. The iPhone provides tremendous consumer value as a handset and media player. But NFC will be the driving force behind many new value propositions, and investments are being made today.

More to come tomorrow.