CCCA – Durbin II – Complex Politics and Consequences

CCCA (Credit Card Competition Act) has been a topic of late, with questions such as: will the bill pass? What will be the consequences? Who will win? 

Today I’m providing a brief update on where the CCCA bill stands, and my view on industry consequences in the unlikely event that it passes (previous blog July 2022).  The summary? I don’t think the bill will pass. What elected representative wants to be seen killing consumer card rewards in an election year? If CCCA does pass, it will take 6 yrs to implement and the consequences will be borne by Issuers (and consumers) with some added volatility to V/MA. V/MA win when interchange is reduced (ex EU IFR in 2015 – see blog). 

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Back from Europe

Sorry for the long quiet period. My youngest just graduated High School and as a WWII history buff, his gift was the Band of Brothers tour from Normandy to Salzberg. We came away with a new appreciation for the cost of freedom and the sacrifices made all of those in the armed forces.

European Payment Insights

Covid had put a long pause on my travel to Europe. In the 6 countries we visited I was pleasantly surprised at the broad acceptance of contactless and tap to pay. Beyond tapping with my iPhone, most restaurants first attempted to tap cards before a “dip”.  Contactless now comprises ~60% of POS transactions, a behavior 3-5 yrs more advanced than the US and certainly one of the drivers of card GDV growth in the EU. The V/MA position is Europe is perhaps stronger than in any other market, as any new scheme would also need to integrate seamlessly into this acceptance (and presentment) infrastructure.  

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Apple Launches Pay Later

https://www.apple.com/newsroom/2023/03/apple-introduces-apple-pay-later/

Apple Pay Later was announced at Apple’s WWDC on June 6, 2022  (Youtube – ~21:00 in). I covered the details last year in Apple Pay Later – What is it? 

Today it is going live in a limited rollout. Summary points

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MRC Recap – Looking up – A Retailers Perspective On Payments

I’m glad I made the decision to attend my very first Merchant Risk Council event this week. For those that don’t know, MRC Vegas is the second largest payment event in the US (after M2020) but with a VERY different focus. MRC is attended by the “hands on” payment leaders from all the top merchants and the vendors that serve them: Stripe, Adyen, PayPal, V, MA, risk, fraud,  …. Etc. Whereas M2020 is attended by FinTech, Crypto, Venture, Institutional investor, and strategy audiences, MRC is much more focused on making payments work

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Apple Launches High Yield Savings

Apple and Goldman Sachs announced the forthcoming launch of high yield deposit account focused on increasing the value of Apple Card’s Daily Cash rewards. Operating as a kind of rewards sweep account, customers that register for the new account will have “their Daily Cash [move] into a new high-yield Savings account from Goldman Sachs”. 

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Pay By Bank – Where does it work and why?

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Friday I was a tad “let down” in the Sionic/TCH/MX release of Pay-by-Bank. Per my blog on Google/TCH launch and Google P2P I was anticipating something much bigger. To be clear I firmly believe that TCH is working on an “ApplePay Competitor”, which will entail TCH tokens inside of Google’s phone, but this will be 3-6 months out.  Per the blogs above, I see neither pay-by-bank nor TCH Tokens in Google Pay as a threat to V/MA. 

Today I thought I would drill down into “pay by bank”, the dynamics of why it works in some markets, and why I see little threat to V/MA in replacing core cards in eCom or at POS.

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Durbin 2 – Short Update

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What are the new Durbin’s legislative prospects? A: Not at all likely (<10% probability)

Top retailers spent this week meeting with Bank CEOs trying to convince them to support the new Durbin legislation. Their pitch was to enable bi-lateral deals, “new products” and avoid network rules (see blog). Banks did not seem to bite, as they remembered the lessons of Durbin 1:

  • Only largest merchants benefited from dual routing
  • Consumers lost in debit rewards (ie keep the change), increased bank account fees, and no merchant pass-through of savings
  • Acquirers/processors did not pass through fee reductions to most merchants
  • Networks recovered lost revenue through merchant fees
  • Large banks lost competitive advantage as smaller “exempt” banks under $10B operated under different rules
  • See WSJ article

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Driving Vision of Durbin? Bi-Lateral Connections?

I now have 70% confidence in the forces shaping Durbin (still no threat to V/MA). 

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Durbin 2 – Impact on “Wrapping” Rules?

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A highly technical “what if” scenario involving a long-sought after change by top US card issuers. I’m fortunate to have the exec teams of just about every payment network, processor and FinTech read this blog. I have 3 main drivers for writing today:

  1. Start a community discussion
  2. Assess the potential for a much more strategic driver behind the proposed Durbin bill
  3. Most “change” in US payments is driven by 7-10 players: networks, top issuers, Google, Apple, … etc. These changes have an enormous impact on the FinTechs building around them. I’m hoping to help these small companies plan around these changes as the only advantage of a start is speed.

Note I DO NOT think this scenario is likely, but rather possible (30% probability). Historical context is key and the only reason I’m spending time on this today is that 27 bank CEOs have been discussing this for over 10 yrs.

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