Not on my Rails

We now see network resistance “Not on my rails”. Why on earth would Visa or MA want to let a Token ride on their rails? Perhaps the best example of “Rail” ownership is First Data’s refusal to support routing and processing of any Paypal/Discover BINs

In last year’s post “Don’t wrap me“, I described how issuers were responding to having their cards “wrapped” by Digital wallets and new Plastic aggregators (Serve and Paypal). Examples:

railroad_tracks414

  1. Paypal’s plastic. MA established a Staged Digital Wallet fee of 35bps, when its card brand was not used at the POS, but was the funding instrument for the transaction.  Amex and Visa also pushed back, although I don’t have details on rule changes here, they made clear that they wanted their brand at the POS.
  2. Serve. Hit by similar issues above,
  3. Google Wallet/Plastic. Visa reportedly issued a cease and desist to Google at the behest of Chase (See NFC Times)

All of these wallets (Virtual, NFC, Cloud, …) led issuers to wonder “what card is top of wallet”?.. and how does a customer select my plastic. Issuers have been (to date) the drivers of rule changes and resistance. They seem much more concerned about one physical plastic card wrapping them (ie Serve and Paypal) than a virtual wallet, but they are also very concerned about data (see blog). Letting a new intermediary see transaction data (and add offers/services on top of them). In other words “DON’T WRAP ME” (see blog Paypal at POS).

Issuers subsequently got together and developed the concept of tokens (see Business Implications of Tokens). The summary: IF issuers had the opportunity to give the customer an account number in a digital wallet. Why would it be a Mastercard, or a visa card number? They are thus working on a system for distributing 16 digit tokens which they own and control (see Secure Cloud PR from TCH).

We now see network resistance “Not on my rails”. Why on earth would Visa or MA want to let a Token ride on their rails? Perhaps the best example of “Rail” ownership is First Data’s refusal to support routing and processing of any Paypal/Discover BINs.  This means that every new “Home Depot” or “Jamba Juice” Paypal signs up must be serviced by a supporting processor (like Vantive).  Making your merchants switch processors in order to accept a more expensive payment instrument (240bps compared to debit pricing of $0.07-0.12) would seem to be a difficult sale. Quite frankly I didn’t see the weakness of Discover’s 3 party network until now.. it only acquires directly for top 100.. and is dependent on many other acquirers. Amex does not have this problem… paypal home depot

My guess is that Visa and MA will also throw up walls soon, but not sense in doing it now.. let the banks work feverishly to build a token machine.. only to find out that the tokens don’t fit in any “slots”.  The only bank globally to have worked all this out is JPMC with its new Visa deal, which bifurcates VisaNet to a new Chase version. Of course the other issuers will eventually ask for same… but these are 5 yr cycles.. All of this means V and MA will continue to rule the mainstream, and that any new competitor must have network control, issuer control and merchant control.

End Game

These rule and ownership battles make my head spin. Investing in this space is not for the faint of heart.  Perhaps the best way to really “change” payments is to first ride existing rails and establish a fantastic consumer/merchant value proposition .. THEN move that solution to a different network… or better yet enable a switch where payments are cleared on a least cost routing basis (like switching IP traffic).

Hopefully the Venture Community is aware of these pitched control battles: Network, wrapping, secure element, trust, card present, tokenization, … But information certainly does not flow well here. Just this week I learned of a start up about to launch a new P2P service built around Visa Money Transfer … allowing a user to “instantly” move money to another account.  Unfortunately they didn’t read my 2.5 yr old VMT Blog, or ensure it would work at ALL of the top 5 retail banks.

… I don’t have time to lay out the scenarios here.. but I like investment thesis that recognize DEBIT as equivalent to ACH…new rules may bring cost down from $0.21 to $0.07… Although PIN Debit and Signature debit both cost the same),  PIN debit is not routed through Visa/MA and operates under separate rules. For example, I love the way First Data and Cardspring are leveraging STAR for non payment data.. without any issuer participation. a VERY good model. Thus I see PIN debit as a ripe area for both for merchant led payment products, and for new bank products.

Issuers are just fuming over the fact that AMEX is completely untouched by Durbin and EU SEPA pricing.  Which is why I see Wells Fargo’s move to Amex as “possibly” strategic… is wells switching railroads? with a first “test” of affluent?.

Debit Round 2 – Rates $0.21 to ?$0.05?

There is a school of thought that “pricing debit” for consumers will help banks increase credit transaction volume (ie credit cards are “free” and have points, debit cards will have monthly fee). Merchants must therefore act to build incentives around debit card usage, or a decoubled debit like product (see blog). Target Redcard is clear leader in the US.

1 Aug

Yesterday’s WSJ Merchants Notch Win in Feud Over Debit-Card Fees

Dodd Frank requires the Fed to set Debit interchange at a rate that reflects actual cost of processing. What the Fed did in 2011 was actually set rates at almost exactly the rate of PIN Debit. (see my 2011 blog).

US Retailers have been pushing for $0.05.. The Fed’s own internal team was recommending 0.12, but the final 2011 rate was $0.21 + 5bps. My view is that Governments should never set rates in an effective, competitive market. Their track record is just awful. But unfortunately payments are not competitive, but a form of 3rd party payor… a market type which is even worse than a government price controlled one.  Big Retailers know enough to negotiate great rates (as in health care) and swallow the “accept all cards” requirement. Small merchants get completely taken (just as in Health Care).

Visa/MA impact.. none. Visa’s revenue is not so much in the network fee on PIN or signature debit, it is in the DPS hosting of debit processing. Bank impact.. absolutely. If Debit interchange lands at less than $0.12, the forces behind debit consolidation (see blog) will accelerate, not because of M&A, but because the margins in this business cannot possibly sustain 6+ participants.

The Banks had planned a uniform march to add fees to debit card, but unfortunately Brian Moynihan at BAC could not wait for his peers and jumped the gun.. only having to pull back from the tremendous public reaction.  Adding fees to debit is a certainty if rates drop. The bottom 4 deciles of mass consumer are already unprofitable. Banks are a private enterprise and should not be obligated to do anything “at cost”. We thus shift costs from merchants, onto banks, who will then shift back to consumer. But quite frankly this is where they should be.. where the consumer can see them.

There is a school of thought that “pricing debit” for consumers will help banks increase credit transaction volume (ie credit cards are “free” and have points, debit cards will have monthly fee).    Merchants must therefore act to build incentives around debit card usage, or a decoubled debit like product (see blog). Target Redcard is clear leader in the US.

My idea for getting around regulation (which all parties agree is a bad thing), is 2 fold: Require transparency (by all participants), and enable competition (through access to core deposit accounts).  Imagine if Walmart, or United Airlines were required to publish their lowest interchange rate with each issuer, for every product (credit/debit). I believe retailers would support it wholeheartedly, but the issuers would go nuts.  Per the second point (account access), the UK led the way here in Faster Payments back in 2008 (see blog).  Consumer banks would need to be absolved of fraud loss responsibility if initiated as a debit by 3rd party (Onus on ODFI), but it would also allow a Sofort type model (Push payments) to prosper.

From a pure debit perspective, Australia and Canada have made Debit a common nationalized infrastructure service, part of a Bank’s requirement to have a license. Fedwire is our equivalent in the US, although only used for wires. You don’t see much payment innovation in Australia or Canada, as the common infrastructure works so well.. that there are no pain points.  The EU is also getting there with SEPA, although the inability for EU mandates to make their way into local law and requirements is proving to be a significant drag…

For innovators the message is simple.. payments are becoming dumb pipes. Go visit Canada and Australia to see why new payments schemes do not take off… Most know my view that payment is only the last “simplest” phase of a very long and complex COMMERCE PROCESS.

Tokens: Merchant Options

Most retailers I’ve spoken with take the view “we just won Durbin and are in the midst of steering customers to debit.. why on earth would I want to support a new product type that is more expensive AND gives banks more control? AND further enhances merchant funded rewards? Will this improve my sales”?

26 June 2013

My last blogs on TCH tokens were rather controversial..  several of my bank friends will no longer take my calls.. while others are grateful that I’ve shown the light on a program they are scratching their heads on. I’m a reformed banker..  only partially cured of my myopia. Banks can choose to put me on the hit list or leverage this information to refocus their efforts toward delivering value (based upon feedback I’m getting on the other sides of the conversation). I can’t imagine trying to justify $200M cash burn on this business plan. Bank CEOs.. if you can’t understand the objective in 30 minutes it is not there.

Controversial points:

  • Banks are working to build a network that circumvents V/MA
  • Focus is replacing cards on file w/ token
  • Value proposition ill formed and poorly thought through (perhaps liability shift)
  • V/MA have their own token projects
  • V is contemplating using tokens to replace VBV, this would step on bank initiative (as is Masterpass)

This is the CEO level strategy war going on right now. So thought it would be good to give a summary to the retail/merchant audience.

Banks

FSIs aren’t big fans of Durbin, or of not having control over their payment rails and data. If you talk about V.me or Masterpass to a card head their face will turn red. They are very frustrated that they can’t innovate in a 4 party network and that Amex is 5+ years ahead of them. Thus they are looking to build a new retail network that they can control.. not that there was much research on what the market needs.. it really didn’t matter. They knew what they wanted: Control and an “interchange” that is better than Durbin.

A very, very big bank “secret” is that fewer than 20 percent of any major issuer’s Credit Card portfolio has consumer cards that are transaction “thick” (more than 5 per month). Most credit cards are thus used for MAJOR purchases only. Banks want to increase credit card usage, lock customers into rich merchant funded reward schemes, AND increase the revenue of debit (when used). None of these objectives aligns to merchant needs.

How are the banks going to achieve their change? They have gotten together to create a new system. Of course anytime a group of competitors get together there are potential antitrust issues, hence they chose an existing entity in which to congregate. They also selected real issues like security, integrity, fraud, interbank clearing to focus their plans, and avoid regulatory scrutiny.  These issues are bank issues, as well as the pricing/control issues above. Given these design constraints you can imagine what they developed..  a bank friendly solution that has no market context.

A core requirement for any token pilot is that it is transparent to consumer. The perfect model for token issuance is OTA card provisioning in the NFC world.  From an economic perspective, Banks want to focus tokens at the POS as this is where the transaction volume is.. but NFC has not taken off, and there is no way for them to get POS adoption in light of MCX and general merchant resistance (although they continue to try). Thus token pilots are likely to be eCommerce focused (the have no choice.. ) and this puts them squarely in conflict with a very, very capable field of competitors with established solutions.

Network War

Per my blog Clusters Form, there are some VERY VERY high stakes battles being fought in the C suite.  For example, Visa is clearly positioned to deliver eCommerce tokens (as a replacement for VBV). In this model Visa would simply redefine VBV which already has bank “acceptance”, and would subsequently reduce CNP interchange and shift liability to issuer. If they did this, it would step on the TCH token project completely. Thus the large issers are threatening mutiny (with exception of BAC?). My guess is that Visa explicitly agreed NOT to do this with JPM in context of their new agreement (analysts/institutional investors please ask question).  With issuers threatening Visa mutiny… MA is not likely to be first to market on a similar solution w/ MasterPass.Network Clusters

What options does Visa/MA have to their own token project? Once one of them redefines tokens the other will follow.. if they don’t then COFs will not be theirs any longer.. they will have lost their acceptance brand. My guess is that the banks will give up on trying to do this themselves and will attempt to accomplish within the scope of V or MA’s rules.. But this defeats their primary control objective.

TCH Tokens – Value Proposition

As I stated last week in TCH Tokens: Any Volunteers, there are few merchants  or wallet providers jumping at the chance to participate in this pilot (POS or eCommerce). They want desperately to start a POS pilot, and may be forced to partner with a QR code solution provider with little to no merchant penetration. Why the merchant resistance?

Banks are not looking to solve a merchant problem, but rather their own.  How on earth can a merchant agree to participate in a pilot where rules are not defined, banks have more control, and the cost is higher than debit. The value proposition currently goes like this:

  • Give me your PANs and Cards on File.. and I will give you a token. (see Battle of the Cloud Part 4 and Business Implications of Tokens)
  • I may be able to take liability (not firmed up)
  • Since its really hard for us to do anything new at the POS, we will probably start with mCommerce and eCommerce and we will greatly improve your conversion rate by “auto filling” our customer’s name and address with the token. Since you have that already (given you had the card in the first place), perhaps we won’t really do anything new.. but hey we think we can.
  • You will have to change your processor to CMS or Elevon to process them
  • You will also have to retrain your fraud/customer support to handle all the special rules, and your customers will have no idea that they had a token to begin with
  • We want to price this higher than debit, but will give you a break on any debit cards.. but we won’t tell you which one is which.. because the customer may decide to switch (so we can lock them into rewards)
  • We will be able to give you a great new rewards/service using your data in the future. Not quite there yet.. but understand we will be the gateway between you and your customer forever…. So we want to justify the increased fees we plan to charge you once you have a number that only we understand.
  • We really love “partnerships” where we can control data.. so if you can please also give us any other data you have we may be able to use it as well.
  • Rules/Chargebacks.. hmmm.. haven’t gotten there yet. But we want to.. can’t we wait?

Ok, I’m rather harsh here.. partly for humor, but also to show how far they have to go for anyone to take this. As I mentioned in V.me – Issuers Please Give me your Customers, there is enormous concentration in eCommerce: Cybersource, Amazon, eBay/PP/GSI and Walmart.com account for over 60%+ of eCommerce retail purchases. Would anyone use a wallet that they only used 1-2 times PER YEAR?

Think about how you buy today.. Amazon, Walmart.com, Staples, Apple itunes, Google Marketplace. How many other sites do you buy from?  Where else do you key in your name address, card number? Airlines and hotels lead the list for me. Am I going to put all of my cards in V.me, Masterpass, or something else to help me (consumer)?

Let’s look at competing initiatives, do the banks really believe they can improve sales/conversions against these?

  • #1 eCommerce Amazon – One Click, #2 eCommerce PayPal, #3 eCommerce Google Chrome (and now with Instant Buy on phone as well)
  • #1 mCommerce Experience Apple iTunes, #2 Payfone – Leverages my phone/device to autofill everything, and phone/device/location information to manage fraud
  • V.me – Autofills everything for eCom/mCom… can load any card
  • Apple (Future)? See blog
  • Existing services from CYBS/GSI

Acquisition

Assuming tokens are issued without customer action, Tokens still face a fundamental problem of acceptance. eCommerce acceptance is just as difficult as physical commerce acceptance (given the concentration of both), eCommerce/mCommerce just solves the problem of keeping tokens consumers transparency. Having a 16 digit number resolves most of the technical hurdles, however merchants must know (and agree to) the rules that surround accepting something that is not within their current processor agreement. What is the cost, who bears loss on fraud, return policy, refunds, rebates, compliance, support, …etc.   Taking a new product with new rules is not something done in the dark of night. The idea of a bank POS token pilot based upon QR code is completely laughable.. as this is yet another “token”.. and it now requires the consumer to do “something”. Once I require consumer participation, I now compete (conceptually) with NFC, Starbucks, Level up, Apple passbook and thousands of other apps.

Most retailers I’ve spoken with take the view “we just won Durbin and are in the midst of steering customers to debit.. why on earth would I want to support a new product type that is more expensive AND gives banks more control? AND further enhances merchant funded rewards? Will this improve my sales”?

Message to Merchants:

Tell them what your real problems are.. and see what they do to propose to help.   Tell them you do want to create better customer experiences both online and off line.. but when customers walk in your door they are not “Bank customers” … but yours.  200 years ago merchant banks were focused on helping merchants grow through industry insight and access to capital. How has your bank helped you grow lately?

Message to Banks

Listen, focus, find a real problem to solve for your merchant customers and consumers. Why do most product searches start on Amazon? What community have you enabled? What services do you perform for that 2% of transactions

Message to Acquirers

You have the merchant relationship and are best positioned for new data services.. you just need a consumer facing partner (Apple, Google, Amazon, …). I see great new things in your future.. particularly if you can deliver Least Cost Routing to Merchants. Perhaps the token platform should start with YOU.

Food for thought…

If you were going to redesign payments.. as an engineer… how should it work? Your money is with one institution that can communicate to any company.

Option 1

  1. Bank issues token to consumer
  2. Consumer Presents token to a merchant
  3. Merchant passes token to 3rd party that can route token to payment network
  4. Payment network routes token to bank
  5. Bank authorizes transaction
  6. Payment network sends authorization to merchant service provider
  7. Merchant receives authorization

Option 2 (Sofort, push payments, Debit Consolidation)

  1. Consumer instructs bank to send funds to merchant
  2. Merchant confirms funds are received

Tokens: Any Volunteers?

19 June 2013

I’ll be leading a panel on Tokens at Money 2020 so thought I would spend a little prep time this week.

V, MA, TCH token initiatives all share one very big problem: no volunteers. Visa is the furthest along organizationally.. they tried tokens before (2010 Token best practices), technically there was nothing wrong with Visa’s previous efforts. The primary problem was that network participants (POS, Card Reader, Gateway, Processor, Acquirer, .. ) were ill suited to transmit anything but a 16 digit PAN.  Now that we have 16 digit tokens (likely based upon ISO/IEC 7812 BIN ranges owned by individual banks), the network CAN forward them for resolution..  these tokens are not Visa, MA, or ACH numbers.. they are an identifying “key” to information (other cards).. which only the holder can determine. This is the heart of what I referred to in Directory Battle Part 1.

If you were a merchant and a vendor came to you with this proposition “give me all of your customer information, I will lock it up.. and give you one of my keys for you to access it”… would you do it? There are some possible business cases around fraud/data leakage liability…. but customer information is somewhat important to most businesses. Token value propositions are not much different.. give me all your stored cards and I’ll give you a token.  At least Visa and Mastercard have rules around PAN.. but what are the business rules around tokens? Think of the Amazon world where I select from a list of stored cards… does the customer have to consent to exchange of PAN for token? In instances where I have multiple bank accounts/cards. Will there be a token for each bank? for each card?  (Networks are prohibiting “non compliant” schemes today). How does customer select instrument (debit/credit) if multiple products are behind token.

I believe that if the consumer has given a merchant payment information, it is an asset that they should only part with if there is a significant value exchange (data, rates, …).  The idea that a merchant would willingly part with card data is just plain silly.. and hence the lack of pilot participants.

The only way I see this working is if banks “push” tokens into every wallet/retailer. Automatically enrolling them into Google, Amazon, V.me, Apple, PAYPAL, … In this model consumers are permission banks to assist with “fast checkout”. In the NFC world this is akin to “provisioning” a card.

We are very far away from seeing tokens at the POS “work” in any business sense, as there are no clear business drivers (beyond giving banks greater control of payments). Banks are not solving a consumer problem, nor are they solving a merchant problem. It is a strategy to maintain control (rules, rates, liability, speed, clearing, network, …). There is also friction within competing networks as MasterCard and Visa do not want to be wrapped by a TCH token, nor vise-versa… As stated previously, in the eCommerce world V/MA could see substantial success if they replace VBV/MSC with this token approach, shift liability to banks and give discount CNP rates. Banks would have great trouble replicating this eCommerce approach because they are in a very poor position to influence eCommerce gateway/processors.

From my view the future of any Token must be driven by customer first. This is where the best opportunities exist for MNOs, and the Banks (physical distribution). I call this federated identity management. Enabling a way for your real world ID to be associated with your virtual accounts and IDs (see my blog on Apple – http://tomnoyes.wordpress.com/2013/04/03/apple-and-nfc-part-2/).  Currently Apple, Google, Amazon and Square are leaders here… although there is a$5B opportunity for MNOs if they could put a team together with some focus.

My updated view on TCH token framework – Usage (“Wallet” transaction for JPM Visa Credit Example)

  1. Consumer presents Token (virtually or physically) held by consumer (or 3rd party)
  2. 16 digit “token” treated same as card (although not a V or MA PAN)
  3. Processor routes token to Bank Token Authority (TCH) in an ISO 8583 transaction
  4. TCH can resolve token directly (switch to network), or forward to participating bank for resolution (switch to network)
  5. JPM resolves token to Visa Credit, if on Merchant is CMS customer.. then on-us (No Visa Interchange). If non CMS, route through Visa.
  6. Authorization sent to Acquiring bank/Processor
  7. Authorization sent to both merchant payment terminal and to 3rd party wallet provider (?). Pilot prospects.. negotiate this one HARD
  8. POS settlement

Payments – Wrapping, Rules, Acquiring and Tokens

if Google had challenges pulling off POS innovation (after ~$1B in investment), rest assured you will too. Banks are well positioned to throw sand in your gears … focus on delivering value within merchant –consumer relationship.

18 June 2013 (sorry for typos)

Thought it was time for blog this week. Primary objective is to inform the venture community of changes which may impact payment related start ups. Sorry that the title isn’t a little more polished (you can tell I’m rather left brained). The exec summary of this blog: don’t ever bet your business on someone else’s rules… particularly if they themselves don’t own them.

Background

All Networks are working on unique token schemes (as I outlined in: Payment Tokenization, “New” ACH System, Visa’s Token Plans and Business Impact of Tokenization). The business drivers here are: #1 Control, #2 Mobile Payments. The US Banks have gotten together in The Clearing House (TCH Tokens) and are in the midst of piloting with 2 providers. In this TCH token initiative, the banks have logically determined that if a customer doesn’t need to see their Primary Account Number (PAN), then they will provide a number which they can uniquely resolve. For example, in mobile payments Citi could put in a unique Citi 16 digit number that is not a MasterCard, not a Visa card, not an ACH account number.. its just a Citi “token”.  Citi can decide how to resolve this number adaptively.. based upon what the customer wants, or what products they have with them.  There are MANY benefits to this approach:

  • Banks control account
  • Banks control DATA (transactional and account information)
  • Banks own network rules
  • No fees to other networks
  • Set unique (NON DURBIN) pricing for a NEW payment product.
  • No restrictions on “Routing”
  • Enables banks to “switch” providers of any payment service or network clearing
  • more detail here…etc

This is a BRILLIANT move by banks. I believe that this central bank “facility” within The Clearing House will be their centerpiece for consolidating all of Debit, in addition to the mobile play.

TCH Tokens are not the only game. Visa, Mastercard and Amex (through Serve) are also in this token game, and others like Payfone (through phone number as token at VZ/ATT), Google (through TXVIA) are also on the periphery. My view is that the BEST tokens are ones you don’t have to issue (ie Square/Voice, Apple/Biometric, Google/Facial Geometry, Payfone/Phone #…).  I outlined dynamics of the strategies in my blog last year “Directory Battle Part 1 – Battle of the Cloud”.  Its amazing that this topic is not covered more broadly in the mainstream… of course most of these efforts above are not discussed at all, and sometimes denied.

Of all the token initiatives, I believe Visa is most likely to succeed. This is not a typo… I’ve been very negative on Visa in the past.. as they have alienated everyone. But Charlie has started to change the culture, he has pulled the JPM relationship out of the toilet and has made a tremendous hire with Ryan. Why do I like Visa’s token prospects? They failed in their first initiative (non 16 digit PAN required big changes by everyone), and learned their lessons. However, most importantly, they can change the rates through rules on CNP and risk “ownership” creating a “new” version of VBV, with the best payment brand.

Wrapping

Currently the networks are at war with anyone attempting to wrap their product and add incremental value. As I outlined in Don’t Wrap Me, and Battle of the Cloud Part 3

The threat to banks from “plastic aggregation” at POS from solutions like Amex/Serve, PayPal/Discover, Square/Visa, MCX, Google is real. Make no mistake, Banks have legitimate concerns surrounding ability support consumers and adjust their risk models. But the real business driver here is to “influence” mobile payment solutions that do not align to their business objectives. Key areas for bank concerns:

  • #1 CUSTOMER DATA
  • Top of wallet card (how does card become default payment instrument)
  • Credit card ability to deliver other services (like offers, alerts, …)
  • Ability for issuer to strike unique pricing agreements w/ key merchants
  • Brand
  •  …etc

Visa, MA, Amex, DFS are in a great position to “stop” wrapping. What does this mean? They have initiated new rules, fees, cease and desists, threats of litigation …etc. Banks are thus looking to circumvent these restrictions by placing their “token” with the customer. This token is thus a new quasi acceptance “brand”.

Acceptance is therefore the new battle arena (who can convince merchants to accept their tokens, rules, rates, …). eCommerce may have slipped away from the banks and networks (PayPal), but they are determined not to let this happen in mCommerce, or at the POS.  JPM has structured its new agreement with Visa  to give them the flexibility on rules in acquiring and network routing for a new acceptance brand (Chase Merchant Services – CMS).

Retailers

Retailers are not the dumb mutts that banks assume. The MCX consortium realizes that greater bank control does NOT benefit them unless the Visa ratesservice is ubiquitous and standard so that banks can compete against each other, with no switching costs. Analogy here is internet traffic routing…They just want the payment cleared, with transparency/control in price, speed, risk.  Retailers also want the death of bank card rewards schemes, and if they can’t kill them instantly, want the ability to deny “preferred” cards. I told a major retailer yesterday that they should offer an “X Prize” to anyone that can make sense of Visa’s rate structure in a youtube video.

Many Retailer’s also have a “token” in form of a loyalty card.. with Target’s Redcard, and Starbucks demonstrating the model in which a retailer led payment scheme could work. For retailers, their loyalty program is fundamentally about selling data, and trade spend.

As a side note, the “big” secret in acquisition is that most (~60%) of profits come from the bottom third of retailers.. specifically the small independents that don’t know enough to negotiate (hence the ISO business). Companies like Walmart negotiate heavily with the top issuers to reduce rates from “standard”.. and still end up paying over $1B a year.Square fees

I see a substantial opportunity for acquirers to participate in what I would discussed within Payment Enabled CRM. This would change their profitability from one driven by small merchants to data/analytics. This is undoubtedly what JPM sees within CMS. Retailers know that they can’t further empower the big bank with their data, but rather need an independent party to run the CRM platform for them.

Summary

I’ve already spent a little more time than I was anticipating here. For start ups my message is quite simple, if Google had challenges pulling off POS innovation (after ~$1B in investment), rest assured you will too. Banks are well positioned to throw sand in your gears … focus on delivering value within merchant –consumer relationship. The Mobile-retail interaction is greenfield, and there are 1000s of different flavors.. no one company will be the centerpiece here. Avoid POS payments.. or be the “arms provider” to the big institutions as they duke it out. My view is that the key for MNOs, Apple, Amazon, Google and Samsung’s future value is

#1 Authentication (Linking the Physical and Virtual World)

#2 Orchestration (Coordinating Virtual and Physical World Processes, Data and Value Chain)

Payment News for May.. What a Month!

I’m actually starting to change my attitude on Visa. Its not just that Jim McCarthy is down the street from my in North Carolina… but rather Charlie is changing the culture there from one that alienated everyone.. back to a network that wants to add value to all.

15 May 2013

I’m in overload on information this week. Just don’t know what to comment on..

In an effort to conserve energy, let’s just say that there are MANY announcements.. but little real progress…  If you were a retailer.. would you exclusively advertise through Groupon? Through Visa? Through anyone? Of course not you have a price promotion strategy and multiple marketing programs which to accomplish objectives in each.  You would choose your channel based upon the ability to REACH the customer (ie Radio, TV, ?email…). As a retailer you also want loyalty to YOUR BRAND.. not some card, bank or start up…  Most of these entities have NO REACH.. having customers is MUCH different than being an effective CHANNEL TO INFLUENCE them.

With respect to POS.. the world needs change. Both Square, and Paypal have the merchant value proposition about right. Their respective terminals solve a short term cost/complexity issue. Square’s product is much further ahead as it also solves inventory management and marketing problems.  PayPal’s value proposition may be higher as they could manage payment costs more effectively (given consumer paypal account penetration), and many merchants already have a merchant account. Perhaps Paypal is taking my advice from 2 yrs ago.. focus on the merchant side first.. I hear that the paypal card is Don K’s pet project.. but John and Marcus may be finally tiring of the poor performance.

I’m actually starting to change my attitude on Visa. Its not just that Jim McCarthy is down the street from my in North Carolina… but rather Charlie is changing the culture there from one that alienated everyone.. back to a network that wants to add value to all. One example is emerging markets, where Hannes of Fundamo has done some REAL work in creating new VisaNet transaction sets to support emerging market solutions. Unfortunately their offers platform is stunted, as the mix of issuer “permission” and consumer experience makes this unworkable basket level program that I have already discussed many times (See CLO). Visa does not keep transaction history (with exception of debit hosted service of a few DPS banks), thus any offer targeting would be driven off a visit to a single store, or single event. This enables it to be a switching service..  Buy something at Macy’s and BOOM get a 10% back offer from Neiman Marcus. From the PR:

Most importantly, the Visa POS Offers Redemption Platform provides real time ticket reduction as part of the offer redemption during the authorization process, delivering an alternative option to the need for statement credits or paper coupons. This functionality streamlines the checkout process by enabling instant redemption of rewards and has the potential to drive incremental transaction volume. Once the reduced transaction amount has been approved by the card issuer, consumers are immediately notified of their savings via receipt printout and SMS text, or email message. (The Next Web)

Customer Experience? The Visa “POS Offers Redemption Platform” is really a “credit” that COULD be given on the receipt if the retailer’s POS interprets the message, and IF the issuer allows it. Thus the entire platform suffers from targeting, basket level redemption, consumer experience, POS integration, Issuer permission, … (need I go on)? American Express’s focus is completely different. They work with the retailer to help them gain insight into their most valuable customers and work with them to create programs to reach them. Visa can’t do this.. as they don’t own the customers.. nor does Vantive.. NO WONDER JPM wanted to opt out of VisaNet.

Google.. lets wait 2 weeks here (after I/O). I already discussed what was reported on Android Police in November. My guess is that the cost of this program was going to be pretty big… even for Google.. If it was successful. Eating 100-150bps in physical commerce ($2.4T) can be quite a big hit, even if you take only 1% of the market ($240M-$360M in US alone).

WMT’s Pre-paid success.. and impending MCX efforts are making the banks itchy. Somewhat ironic, as banks really don’t want WMT’s mass consumer customers in their branches.. while WMT loves them in their stores. Think the banks really don’t like having their “banking lite” services productized and sitting on a retail shelf to buy. They don’t want consumers to think of them as a product which can be bought.. and switched. Of course some banks have seen the light (Amex, Discover, GreenDot, BankCorp, Meta, …). Competition, transparency, and product selection are core elements of efficient markets. Of course it makes sense to ask your regulator from protection against consumer choice. But this is certainly not to benefit the consumer.

Bitcoin? where to begin.. ? Unlike most currencies, bitcoin does not rely on a central issuer, like a central bank or government. Instead, bitcoin uses atransaction log across a peer-to-peer computer network to record transactions, verify them and prevent double spending. It is a VERY INNOVATIVE mathematical crypto innovation (that is used extensively in illegal activities). Bitcoin stands in dramatic contrast to all of the data sharing, bank controlled, transparent stuff above. Its success demonstrates that there is a tremendous need for anonymity in payments.  There is no centralized authority here.. which is what alarms governments..  Thus there will be very strict controls on how coins can be converted into currency. Thus Amazon’s coins can only be used to purchase games/apps.  For those investing in this space, you should thoroughly research eGold.

Payment is still a red hot market.. expect significant M&A activity over next 12 months.

US PIN Debit Consolidation

18 April

Fed Pin Debit

Two years ago, top 5 bank CEOs met every week during Durbin to discuss response. I believe they probably had a good plan as Debit is a very very popular payment product. Unfortunately BAC’s Moynihan jumped the gun and announced a “fee” for debit.  Consumers and press went ballistic.. I wish that BAC had just waited another few months to roll out it’s card linked offers product to show the new “value”  and tie the pricing to this new “value”. As the Chinese say

If you are patient in one moment of anger, you will escape a hundred days of sorrow

There have been quite a few excellent Fed studies out on Debit since my last blog on the topic (Real Time Transfers – Feb 2011):

From the Reference 2 aboveDebit bank loss - EPC

The network exclusivity provision and the merchant routing provision of Regulation II both give merchants more control in routing transactions to preferred networks. However, most banks’ way of complying with the prohibition of network exclusivity arrangements is to enable more than one PIN network on their debit cards, but not more  than one signature network. As a result, those merchants that accept  only signature transactions generally have not gained any increased  scope to choose from among different networks.

Among merchants that accept PIN debit transactions, many have taken advantage of their new control. The routing kc fed before and after reg 2provision of Regulation II allows them to pick the PIN network they prefer from among  those enabled on a given card. Their exercise of this control has altered  PIN debit networks’ market shares. Many merchants now avoid Visa’s Interlink network, the largest PIN network prior to the regulations, and  instead choose other PIN networks whenever possible. As a result, in  terms of transaction volume, Interlink has lost significant market share  to other PIN networks such as Maestro, Pulse, and STAR (Finkle; Daly). Through their new control over routing, merchants’ emerging influence over the market shares held by different PIN networks is likely  to increase competition among PIN networks for merchants….

Consumers appear to have shifted to some extent from signature debit to PIN debit as a result of the regulations. Regulated banks now have an incentive to promote PIN debit over signature debit, though that same incentive does not apply to exempt banks…Many regulated banks stopped offering rewards to debit card users, especially to signature debit users, and they may also have eliminated the PIN fees that were assessed in the past to some consumers for each PIN debit transaction. Merchants have also taken steps to steer customers toward the use of PIN debit.

From Reference 1 – with respect to PricingKC Fed small large merchant debit fee

Merchants’ new freedom to offer discounts based on payment method, brand, and product allows them to steer customers toward the payment methods that the merchants prefer—and thus to affect the market shares held by networks. For example, if signature networks set their interchange fees for exempt banks higher than those set by PIN networks, merchants may offer greater discounts to customers who use PIN debit. To retain transaction volume, signature networks may avoid setting their interchange fees significantly higher than those of PIN networks. In this way, merchants’ new flexibility in offering discounts causes networks to compete for merchants. Most merchants, however, have not yet taken advantage of this new power. Given the many different payment methods, brands, and products that merchants accept and the complexity of the fee structures, it will take time for merchants to determine whether and how to offer discounts based on payment method. For example, Kroger,
one of the nation’s largest grocery store chains, considers payment based discounts a very powerful tool for influencing customers’ payment choices (Clifford and Strom), but has not decided how to offer the discounts.

Thus we see a world where big merchants push PIN debit, small merchants are getting taken by ISOs who don’t even know to ask for PIN capability, with competition in pricing…. With signature debit going down, PIN debit use going up.. Visa’s Interlink hemorrhaging volume. For perspective, my estimates are that somewhat Approximately 15% of Visa’s Revenue comes from US debit (just 2% from PIN Debit Interlink). Does anyone now wonder why Visa wants “Chip and Signature”?kc fed before and after reg

Banks have lost over $7.7B annually because of this change. Remember that PIN debit is just an extension of the Bank’s ATM network..  why on earth would they want to continue to use 8 different independent networks to continue here? What if there were new products they could deliver on the PIN debit networks…. ?

PIN Debit seems to be ripe for consolidation and bank control. I have a strong bet that the US banks will consolidate around a single PIN provider within the next 18 months. Why? Probably more for defensive purposes.. Its also nice to be able to control the rules on your own network..

Perhaps more on this subject in a future blog.

Controlling Wallets – Battle of the Cloud Part 3

The networks are now in the midst of defining new rules to ensure they can “influence” wallets. Banks have legitimate concerns surrounding ability support consumers and adjust their risk models. But the real business drivers here control and customer data.

#1 CUSTOMER DATA

14 MAR 2013

Short blog today.. patent law changes tomorrow and need to get something filed.

Efforts to “control” have unintended consequences.. like holding onto your Jello by squeezing it..

The networks are now in the midst of defining new rules to ensure they can “control” wallets. I wrote about this a few months ago in Don’t Wrap Me – October 2012 and Battle of the Cloud – Part 2. The threat to banks from “plastic aggregation” at POS from solutions like Amex/Serve, PayPal/Discover, Square/Visa, MCX, Google is real. Make no mistake, Banks have legitimate concerns surrounding ability support consumers and adjust their risk models. But the real business driver here is to “influence” mobile payment solutions that do not align to their business objectives. Key areas for bank concerns:

  • #1 CUSTOMER DATA
  • Top of wallet card (how does card become default payment instrument)
  • Credit card ability to deliver other services (like offers, alerts, …)
  • Ability for issuer to strike unique pricing agreements w/ key merchants
  • Brand
  •  …etc

Each network is in midst of creating rules which will ensure it has control and can see merchant/consumer transaction.

The buzz this week is surrounding Mastercard’s new Staged Digital Wallet Operator Annual Network Access Fee (MA detail reference not avail).

  • What is it? Well since I don’t have the Dec 20 rule in front of me I have to go off my notes.
  • Applies to wallets that facilitate POS commerce between merchants and consumer (not ecommerce)
  • Who is responsible? It is largely a new processor responsibility. They are responsible for identifying wallet transactions
  • New transactions sets? Yes. Currently aggregators can be the merchant of record, but new rules require the MID of purchase and a new WID (WALLET ID) to be transmitted.
  • New fees? Yep.. looks like around 35bps on LAST YEARS volume
  • Timing? Goes live June 2013. Processor technology complete by April 2013

This is a brilliant move by Mastercard… but there may be some unintended consequences as issuers will have control over how it is applied.  MA’s objective?  “influence”  PayPal/Discover, Amex/Serve and Square/Visa, MCX…  NOTE eCommerce is NOT the focus (Apple/Amazon). However MA seems to be tying themselves in knots trying to differentiate a ecommerce aggregator (Amazon) from plastic aggregator (ex. PayPal/Discover).

These changes are already having “material” consequences. In eBay’s 2013 10k Page 19

MasterCard has recently announced a new Staged Digital Wallet Operator Annual Network Access Fee which would apply to many of PayPal’s transactions if the buyer uses a MasterCard to fund their payment, and will be collected starting in June 2013. PayPal’s payment card processors have the right to pass any increases in interchange fees and assessments on to PayPal as well as increase their own fees for processing. Changes in interchange fees and assessments could increase PayPal’s operating costs and reduce its profit margins.

Also see the long discussion by Amex’s Dan Shulman

http://www.reportlinker-news.com/n061421027/American-Express-Company-SemiAnnual-Financial-Community-Meeting-Final.html

UNIDENTIFIED AUDIENCE MEMBER: Thanks. I have a question for  Dan Schulman.  MasterCard recently revealed that they’re introducing this digital wallet that I’ll read it’s called the staged digital wallet operator annual network access fee. It’s one of his famous acronyms.  I was going to ask has Amex contemplated a digital wallet fee as well? And generally do you think the optics of digital support merchant discount rates, are they going higher or lower in a card not present world?

DAN SCHULMAN : So I think you’re seeing a lot of different players whether it be traditional or non-traditional start to think through the digital wallet strategy. And we’ve said this and it’s still absolutely true, this is the very early innings of this play out with digital wallets right now. We’re beginning to get some very nice traction in the back half of the year. It’s kind of on our digital platform right now.  We have looked very hard at the different fee structures that are out there. We’ve looked at the embedded infrastructure that we have. As Ken mentioned we have a kind of fixed infrastructure that we can leverage. We have a lot of assets that we can leverage that are very different than other players out there right now.

So I wouldn’t expect that fee structures are necessarily going to mimic each other because each of us come to the market with different assets and different profiles. If you look at some of the kind of newer players that have come into reloadable prepaid, they’ve got very different infrastructures and therefore have to have very different fee structures if you look at a  NetSpend  or a  Green Dot  they charge on their, kind of what they are beginning to try and call wallets, they’re charging monthly fees that can be $4.95

A new WID  has multiple uses. It enables MA issuers to enhance their risk models and “decline” both individual transactions from a wallet, as well as decline wallet providers that are not “certified”.  Amex already has similar rules in place, their summary view seems to be that Serve can wrap everyone else’s card… but no one can wrap theirs (for physical commerce).

Banks love the original NFC model where cards had to be “provisioned” into a wallet. Banks were in complete control of which wallets to “authorize” and completely hid the card number (purchase data) from the wallet provider.  This perfect world broke down quickly as the first NFC wallets had space for only one card emulation application (see Forces against NFC) so there were 2 options: allow only one card type, or enable a single card to represent multiple cards (See Blog). Now that NFC in payment is dead just about everywhere (except Asia), banks are looking to enable this “provisioning” control within the network level. MA is just the first visible instance, as I outlined in NEW ACH SYSTEM the Banks are also doing the equivalent to ACH debit through tokens probably 18mo- 2 yrs away.

And we wonder why mobile payments aren’t taking off.

Retailers look at this change and see complete imbalance… Networks which will change rules in weeks to satisfy banks. V/MA you may want to consider a new transaction set which would force issuers to define price of a specific card for that specific merchant (interchange), and acquirers their fees (MDR)… then share that information with other retailers.  Then allow retailers to decline based on price… (as opposed to accept all cards). That would certainly level things out…

I do think there are many ways to get around this.. but  I will not be putting them in this blog ($$).  All surround who owns the customer… and 5 “LAWS OF Commerce”:

  • Commerce will always find the path of least resistance
  • Consumers are NOT owned, but rather migrate where there is value
  • Value can be delivered by price, product and also through great consumer experience
  • Most Retailers face life selling commodity goods at a higher price… experience is all they have left
  • Banks have never held a sustained role in controlling commerce, they influence and support it.

In all of this bank control.. where is there value? What does a JPM Sapphire Card actually do that is differently than a platinum Amex or a sub-prime Capital One? Brand, points, loyalty… these are qualitative attributes.. but what if there were REAL value differences? Where is the customer relationship. Note that Retail Banking is going through many FUNDAMENTAL changes (see blog)

Tim Geithner visited a friend of mine prior to his departure. My input question to him was what if core “Bank accounts” morphed from Net Interest Margin (NIM) profitability to “Trust Accounts” where the key to profitability was consumer data? (See blog Payment Enabled CRM)

With respect to squeezing Jello… as the banks angle for control EVERYONE else is looking toward least cost routing (see Blog). The payments system is not a set of 5 pipes.. Just as the internet backbone is not run on a single piece of fiber. Changing all of the rules for everyone and stopping the leaks is hard work…

payments pyramidI would love to set up a Wiki site where we could list the features differences and customers of all of these digital wallets.

.. back to my patent app .. oh and corporate taxes due tomorrow too. Yuck.

The Directory Battle PART 1 – Battle of the Cloud

Square, Visa, Google, PayPal, Apple, Banks, … have recognized the absurdity of storing your payment instruments in multiple locations. All of us understand the online implications, Amazon’s One Click makes everything so easy for us when you don’t have to enter your payment and ship to information. (V.me is centered around this online experience). Paypal does the same thing on eBay, Apple on iTunes, Rakutan , …etc. But what few understand is the implication for the physical payment world

11 May 2012

This week we had both Finnovate and CTIA going on, and behind the scenes the battle lines are being formed in a forthcoming “BATTLE OF THE CLOUD” wallet. I didn’t include wallet in the quote because Battle of the Cloud sounds so much more ominous. Perhaps I should take a page from George Lucas’ playbook and start with Chapter 4.

I’ve been talking about the directory battle for some time now (see Clearxchange post).  Who keeps the directory of consumer information? As I outlined in Digital Wallet Strategies: “ securing information AND giving Consumers the exclusive ability to control what is shared with whom is a challenge (beyond technology and trust). We thus have many limited “Wallets” that are constructed around specific purposes”.

This week we had Visa’s President tell the CTIA audience that Visa has moved beyond NFC to V.me (see my previous post on Visa Wallet). What is really going on? What is the battle of the cloud?

Square, Visa, Google, PayPal, Apple, Banks, … have recognized the absurdity of storing your payment instruments in multiple locations. All of us understand the online implications, Amazon’s One Click makes everything so easy for us when you don’t have to enter your payment and ship to information. (V.me is centered around this online experience). Paypal does the same thing on eBay, Apple on iTunes, Rakutan , …etc.   But what few understand is the implication for the physical payment world. This is what I was attempting to highlight with PayPal’s new plastic rolled out last week (see PayPal blog, and Target RedCard). If all of your payment information is stored in the cloud, then all that is needed at the POS is authentication of identity (see blog). Remember US  online commerce is $170B/yr, physical commerce is $2.37T (not including FS, Travel/Entertainment).

The implications for cloud based payment at the POS are significant because the entity which leads THE DIRECTORY will have a significant consumer advantage, and will therefore also lead the breakdown of existing networks and subsequent growth of new “specialized” entities. For example, I firmly believe new entities will develop that shift “payment” revenue from merchant borne interchange to incentives (new digital coupons).  Another example is Paypal’s ability to selectively assume settlement risk on some transactions as they route through low cost ACH, or even allow customers to use BillMeLater to selectively convert certain purchase to loans AFTER THE FACT.  In these 2 examples, traditional payments revenue will be significantly disrupted by: lower cost transactions, competitive credit terms (each purchase), and incentives tied to payment type.

But do consumers really want to store all of their information in one place? With one entity given the ability to see all of your spend? For an mCommerce transaction, there is nothing I hate more than having to type in my name, address and card number in that tiny little screen.  Most of these mCommerce solutions (like V.me) are little more than an “autofill” where the merchant checkout page leverages API integration to the cloud service to retrieve user information (see diagram here). If I’m on my phone, my carrier already knows who I am, so seems fairly logical for them to help me with the autofill. This is a reason I’m now a big fan of Payfone. I could also see why it makes sense for Apple and Google. But why Visa? Does it make any sense at all for Visa to hold my Amex card?  Oh.. let me cast a few more stones on ISIS/NFC.. that payment instrument that locked in your phone.. yeah it can’t be used for the online purchase. Perhaps someday someone will write a secure NFC mobile browser plug in to extract data from the SE.. but that opens up a whole new can of worms.

Today’s online merchants are getting a very small taste of the war as they are asked to integrate auto-fill plug ins (Paypal, V.me/CYBS, Payfone, Google, soon to be Apple). Merchants should get on board with all of them, as they do represent a tremendous improvement in customer experience, and you may be able to squeeze some free marketing/implementation money from each of them. However, the cloud battle at the physical POS is still a few years off, as existing card products have a substantial advantage in risk modeling/fraud. This is where Square is taking a lead, as it has the best consumer experience hands down. Low volume merchants really should assess whether they need a specialized POS system, as the parameters for selecting one have shifted from ISO/Processor/Cost/Acct Recon/Book Keeping to Sales, incentives and customer experience.

Battle starts in mCommerce/eCommerce

My guess on timing of V.me is driven by knowledge of Apple’s impending plans to “extend” its iTunes account to payment outside of the Apple ecosystem. Visa sees this network risk and is in an all out war to protect its network, by leveraging its CYBS asset online. The banks have worked on a directory concept for quite some time. The Clearing House (TCH) built a working system called UPICK to solve the problem of consumers giving their RTN/ACCT# out in the open.. assigning a virtual number to the account. A sort of “virtual account number” that could only be translated by TCH.  It never took off, because ACH fraud was low and banks were much more excited about having merchants accept cards as payment.

Retailers are not silent participants to this war.. their champions are Target, Tesco, Amazon, and Rakutan. I hope Amazon will finally dust the plans off of One Click expansion. Other retailers are also aligning to assess creation of shared cloud infrastructure.  Sorry I can’t comment more. Similarly MNOs are also in the cloud game, for example Payfone may be one of the best services in the market..

Who are the players in the Cloud [Payments] War?

The initial battle will be in mobile/online purchases.

  • Banks: V.me, Mastercard,
  • Platforms: Apple, Google, PayPal
  • Retailers: Amazon, Rakutan,
  • MNOs: Payfone, Boku, payforit, billtomobile, …

Most confusing is that there are few alliances.. it is many against many.

http://tomnoyes.wordpress.com/2011/10/26/apples-commerce-future-square/

Card Linked Offers Update

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

,,,,,,,,

27 March 2012

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

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

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

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

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

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

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

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

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

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

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