How to Deregulate Payments (like Telecom)

The US needs open access to a RTGS system, where any party can assume risk. Giving non-banks the opportunity to participate in Fedwire may be the quickest way to move the ball. For EU, perhaps giving open access to a common settlement service would be faster than mandating protocols/services. In other words.. build a new system for settlement which banks must participate.. and let non banks in as well. Build the Future vs. fixing the past.

23 July 2012

This will be a new blog type.. perhaps a little offbeat .. a living blog that “iterates” based upon community feedback. Idea started yesterday in a few of my informal chats. I’m no telecom expert, but fortunate to know some very good people who are. Yesterday I was having a chat on the EU’s Proposed Interchange Cap with a telecom friend and He drew several analogies to what happened in Telecom back in the 70s when AT&T was forced to open up its network.

Example: Telecom

MCI took AT&T to court to get interconnection, and that put them in a position to offer universal switched service, which they proceeded to do. When the FCC tried to stop them, the circuit court of appeals refused to sustain its order, essentially on procedural grounds. The upshot of this series of discrete decisions, which none of the responsible parties-except maybe Bill McGowan-either foresaw or intended, was the transformation of the long distance business from one of franchised monopoly to open competition. In MC/ Telecommunications Corp. v. FCC, 561 F2d 365 (D.C. Cir. 1977), the U.S. Court of Appeals authorized competing uses of microwave systems serving business and data communications markets; the court also concluded that the FCC had no general authority to insist on approval of new services without a finding of “public convenience and necessity.” In a later proceeding in the MCI case, 580 F2d 590 (D.C.Cir. 1978), the same court held that the previous decision’s mandate required AT&T and the FCC to provide interconnections to MCI. – Telecommunications Deregulation: Market Power and Cost Allocation Issues, 1990 edited by John Robert Allison, Dennis L. Thomas

Several interesting points in this story:

  1. Telecommunications regulator (FCC) was captured by AT&T and wanted to protect them from competition. The deregulation was unintended.
  2. Investment in this sector was throttled by a monopoly which controlled end-end distribution.
  3. Unlocking the monopoly allowed others to compete, take risk and invest. Consumers benefited, telecom costs  decreased, capacity and quality increased, and are now a commodity (ie dumb pipe) business. For example Jim Patterson wrote in this Sunday’s brief “Verizon has a wireline unit that, despite continued investments in fiber, cannot manage to offset its losses from legacy technologies to earn a profit.  With the exception of FiOS Internet and Video, the rest of the business is largely a victim of increased wireless substitution, VoIP (as opposed to traditional TDM voice) penetration, cable competition, and the cloud”

The EU can be credited with attempting to deregulate payments through SEPA (see SEPA – Chicken and the Egg  , Payments Innovation in Europe). As I stated in Building Networks and Openness

The network forms around a function and other entities are attracted to this network (affinity) because of the function of both the central orchestrator and the other participants. Of course we all know this as the definition of Network Effects. Obviously every network must deliver value to at least 2 participants. Existing networks resist change because of this value exchange within the current network structure, in proportion to their size and activity. Within the EU, SEPA undertook a rewrite of network rules and hoped that existing networks would go away or that a new (stronger) SEPA network would form around its core focus areas (SCT, SDD, SCF, ..). It was a “hope” because the ECB has no enforcement arm. In other words there was a political challenge associated with ECB’s (and EPC specifically) ability to force an EU level change on domestically regulated banking industry.. given that SEPA rules destroyed much value in existing bank networks, the political task was no small effort. We have seen similar attempts (and results) when governments attempt to institute major change in networks (Internet NetNeutrality v. Priority Routing, US Debit Card Interchange, …)

Managed Deregulation

Managed deregulation seems to have problems… particularly when there is an attempt to force a “product/Service” like SEPA CF or SEPA DD. While there are no technical issues w/ SEPA there are issues around incentives, local/regional policy and lawmaking, regulatory enforcement, …etc. Like ATT/MCI case above, Local Country banking regulators are “captured” by the entities which they regulate. This is not unique to Europe at all.. As I’ve stated many times with respect to India, RBI has attempted to “manage” innovation in mobile payments to ensure that banks are in control (vs. MPESA Success in Kenya success was “accidental”).

“Unmanaged” deregulation seems to have a much better track record in telecom, payments, and other areas such as “internet” services (ex UBER and the NYTLC). With respect to Payments, what is the switch that needs to be opened up? Perhaps the best example is Sofort (SOFORT Overview) and “opening” ACH/iBAN transfers.  US banks are proceeding in the opposite direction (see ACH System in US), and have generally resisted changes to improve ACH “speed” for this very reason, as any RTGS system possess a risk to them (see Real Time Funds Transfer in US). Payment Value

Although some readers will be highly offended at my suggestion that success was not guided by government directives and oversight (ie Internet – Al Gore’s invention, Glosplan, The French), it is important to note that a company with a business plan was ALWAYS behind success…  pushing for the change, against regulators who largely work to protect the industries they regulate.

Dodd-Frank V2

Dodd Frank has had tremendous repercussions for the industry (Bloomberg estimates $22B). In my view future regulation should avoid any price setting, as effective markets are the proper mechanism to align price to value. However payments is not a competitive market, and Dodd-Frank has not changed this. Lawmakers should endeavor to kick start a new wave of investment from 100s of companies in payments and commerce. Working to make payments a competitive market, just as Telecom is today.

Here is my simple framework for unlocking a new wave of competition.

#1 Settlement.

The current card schemes are insanely complex. No one in their right mind would start off with a design of a debit request to an account holders financial institution if everyone is connected (my design is in blog Push Payments). In order to maintain flexibility in risk management, the clearing mechanism must let any participating party assume risk on the transaction. Therefore my recommendation is to enable the participation of non-banks in local country RTGS systems (FedWire in the US)…. creating a certification process by which new participants (like MSBs Amazon, PayPal, Google, WMT) could establish a settlement account with the Fed just as the banks do. There is real time funds transfer here (only RT option in the US), once funds are moved there is no reversal. This puts the onus on the participating entity to manage risk and Fraud. It also keeps from having the banks do any technical work at all…

#2 Issuance and Value Storage.

We need to look no further than BitCoin to see the need for new regulations surrounding issuance. Transfer of funds between entities is covered above, and my view is that non-bank participants should be licensed and agree to abide by current money transfer  regs (ie. Fincen/AML, ..). Issuance of “credentials” and storage of funds is another matter. Long term storage of funds is a banking function, and should be regulated, settlement funds face state escheatment issues (but largely unregulated unless interest is paid), while storage of “Value” is completely unregulated (ie Coupons – a form of legal tender, Pre paid offers, bitcoins)?

From above, if we allow non-banks to participate in real time funds transfer (like Sofort), then third parties are acting as agents (on behalf of consumer, merchant or bank) to direct the funds. If a good/service is purchased immediately (commerce) then there is no regulation, however if the value is “held” for future use it is generally regulated (hence MSB, eGold, bitcoin issues). Thus the rules under which third party senders operate (as agents), are different from the entities at the end of the transactions (banks, merchants, consumers).

Most know the story of MPESA and how telecom minutes became a form of value exchange which evolved to over 10% of Kenya’s GDP. There is an obvious need for issuance to more closely resemble cash in its ease of exchange, verification, anonymity and storage.

Our current need is for simplified laws surrounding account under a given value amount (say $2000). Providers of service should be lightly regulated through self reporting, “transparency”, and the need to keep settlement funds with the Fed. In this proposed model, a bitcoin exchange must ensure that no single individual has processed more than the threshold in a given time period. Hence the need for KYC of exchange participants (when converting to cash).

#3 Authentication

Most are aware of my favorite payment quote

…If you solve authentication.. everything else is just accounting”  (Ross Anderson @ KC Fed).

Sharing and validating of identity is critical to a functioning payments system. 3rd parties which have consumer permission must be able to participate in common infrastructure (credit bureaus) and share data on bad actors with other participants without fear of repercussions. eSignatures, eVerification, remote KYC should all be defined within law.

Would love more input here.

#4 Acceptance.

No Change Necessary. Just as MCI forced its way into the switch, other providers must be able to participate in the payments “network”. For a merchant to accept a new payment type, the following must happen

  • Merchant agreement (with merchant Acquirer)
  • Network Agreement (between Payment Issuer/Network)
  • Processor Agreement
  • Acceptance device
  • Consumer Instrument
  • PCI Certification (in some cases)
  • POS Integration

The Pipes between a merchant and its processor are owned by the merchant, they can decide what flows through those pipes with one major exception: accept all cards. Dodd-Frank allowed market forces to take effect here through steering and incentives… although few merchants have acted, as they hope to keep pressure on a credit settlement. To accelerate acceptance market forces, there must be “open-ness” in the connection. I believe this is largely in place, as merchants face few challenges IF THEY WANTED to add a new payment type like PayPal. They have chosen not to because it offers no benefit (vs a debit card).

Summary

Innovating on the existing networks is hard. The core to any payments success is access to the transactional account. There are several successful approaches today:

  1. Sofort (my favorite example). Operating as agent on banks web site to initiate payments on consumer’s behalf. This can’t work in the US as there are no “wires” or direct RTGS system which correlate to IBAN in Germany.
  2. Amex/Bluebird “bank in the box” account. With direct deposit, bill pay, electronic payments, ATM, … but getting consumers to adopt a new account is not really “open”
  3. Bitcoin/eGold. Consumers buy item of value which can be exchanged
  4. Solutions which work off of PIN debit (a very cool area that is overlooked). Best examples are Acculynk, Star’s Expedited Transfer, NYCE’s A2A Money Transfer Visa’s VMT, Dwolla,

The US needs open access to a RTGS system, where any party can assume risk. Giving non-banks the opportunity to participate in Fedwire may be the quickest way to move the ball. For EU, perhaps giving open access to a common settlement service would be faster than mandating protocols/services. In other words.. build a new system for settlement  which banks must participate.. and let non banks in as well.  Build the Future vs. fixing the past.

CEO View – Battle of the Cloud Part 5

There is a payment cluster war going on right now and it is the subject in the C Suite in Banks and the Payment industry. The battle is happening at every level. I’ll be leading a panel at Money 2020 which addresses several of these items, with participation from V/MA… should be interesting. Here are a few updates.

22 July 2013

This post is a continuation/update to my post back in March Network War – Battle of the Cloud Part 4. Sorry for typos.

There is a payment war going on right now and it is the subject of C Suite strategy talks. The battle is happening at every level. I’ll be leading a panel at Money 2020 which addresses several of these items, with participation from V/MA… should be interesting. Here are a few updates.

Network Clusters

Network/Routing/Rules

  • $8B Revenue Impact. I apologize to my EU readers for my constant US focus. Let me break the mold now to emphasize the earth shaking changes going on in the EU (See today’s NYT blog, and today’s WSJ). Going from 250bps + cross border fees to 30 bps will be tremendous, and may set a precedent for the US litigation between Visa/MA and top retailers.
  • EU provides a glimpse at what a world of payment “dumb pipes”  and least cost routing looks like (see Blog Payments Innovation in Europe).  Canada and Australia also follow these lines in debit (see Blog). Also see my favorite case study in Europe  Sofort – ECB analysis, and Push Payments.
  • Networks, and their members are reacting to regulation and positioning themselves (individually) to “push” their respective vision of innovation in order to protect their brand and network (see Visa Money Transfer, and Visa Portfolio Manager). I don’t mean to limit this to just Visa and Mastercard (see picture, and blog).
  • New networks are forming (see Blog on Clusters)
  • Large issuers like JPM have successfully forced Visa to break/segment its Visa net, and run under unique JPM/CMS rules with new capabilities. Visa’s CEO comments to investors: “rules must be consistent with Visa”..  My view is that this is a major crack in Visa’s network ownership (see Golden Goose on the Menu).payments pyramid
  • From a wallet perspective the rules on “wrapping” are killing much innovation (see don’t wrap me). Top issuers are actively working to inhibit wrapping of their payment products (ex Mastercard’s staged digital wallet fee of 35bps on PREVIOUS years volume of over $50M..  which only impacts paypal).  Similarly Amex and Visa are working to ensure their cards are not wrapped.
  • Rules are being issued and ignored, from Visa Money Transfer to EMV (see below). Banks tell Visa “do you want me to write the waiver or will you send it over… as we are not going to do this”.. which is one reason JPM just created its own unique rule set. Similarly US merchants face a liability shift (on to them) if they do not accept EMV cards (chip and pin). All are playing a game of chicken as no one wants to re-issue plastic. Visa has created a new type of EMV, chip and SIGNATURE, which makes absolutely no sense at all, but helps them keep customers away from PIN (which Visa despises, but everyone else loves).
  • Cross boarder fees (see blog). As 20%-30% of network revenue moves to these fees, it is becoming a substantail pain point for global banks like Citi, HSBC, Barclays, .. A big topic I can’t fully cover here

Issuance

  • US Banks are spending 90% of their time in innovation around Credit Cards. Exception is Bank of America and to some extent my old team at Wells. In either case the banks have hit a wall, and recognize that innovation can’t happen in a 4 party network. American Express is 5 years ahead of them and they can’t catch up.. they must change.
  • The NATURE of card completion is changing in both credit and debit. Traditional Payment revenue is being REGULATED AWAY as payments become “dumb pipes”. The goal most have recognized is that the real value to be unlocked is in commerce data, particularly Payment Enabled CRM (see blog). Examples of just how focused this effort is: 22 Banks working in Secure Cloud, ~$1B in Google Wallet Investment,  ~$500M in ISIS investment,  JPM just hired Len Laufler (former CEO of Argus Data) to be the new CEO of Data in Chase.
  • Banks thus need to build a network which can accommodate both payments and “other data” which they own and control (like Amex)… hence “tokenization” (see Blog, and TCH Announcement).
  • Tokenization is currently going nowhere.. but it is “impacting” the industry and many start ups as banks and networks position themselves (see JPM/Visa Blog, Start up implications).
  •  Visa and MA also have their own secret token efforts. Merchants have a much better short term win in this approach with a liability shift and reduction in interchange, but they also know from past experience that if the issuers are not on board, there will be a much broader business impact in declines (see VBV post, and Visa’s Token Strategy).
  • Retailers are attacking from below. Bottom 40% of mass market customers are not profitable for banks (Durbin related items ranging from NSF fee changes, to debit interchange) . These customers are profitable for retailers like Walmart, Tesco, Target, .. (see Blog).
  • Telcos have a chance to own a new payments network, as they have both physical distribution, customer relationship, connectivity and device.. but they are focused on controlling a handset in a walled garden strategy. To succeed they must refocus efforts on COMMERCE, which means partnering with all participants to construct a value proposition (see blog).

Acquiring

  • The first hurdle of any “New” network is to get the merchants and acquirers on board.
    1. This is NOT going well for companies like Paypal … hence the complete failure of their DFS partnership (see blog). Specifically, there is at least one major acquirer which is refusing to route traffic on any of these new Discover/Paypal BINs, as well as at least 2 major retailers. Although Discover is a 3 party network, they only acquire directly for their top 100 merchants. Therefore Paypal must “incent” and negotiate with every single other acquirer AND merchant.
    2. Chase is working to build a new CMS acceptance brand, which will be different from Visa.
    3. Retailers are building their own network (MCX), and have hired Dekkers Davidson, a tremendous executive, to lead it.
  • Roughly 60% of acquiring profits come from bottom 30% of merchants. There are small independent merchants that are paying over 5% in acceptance fees thanks to the poor transparency within the ISO sales process. Companies like Levelup and Square are changing this (2.75% flat, or free if you commit to marketing). I’ve eaten my shoe on Square, as I never fully understood how badly the ISOs were treating small independent retailers. Their solution solves a short term pain point and also improves customer experience.
  • Acquirers are making POSITIVE headway in merchant friendly services (see blog), particularly helping merchants “merge” consumer data to gain new insights for loyalty and incentives. They are challenged to quickly ramp up this services revenue, in order to overcome the new aggregators acting on the side of small independents (ie Square).

POS Acceptance

  • Has anyone seen the graph of Verifone’s stock? Market cap of under $2B. A hardware company that could not adapt to a software world. At the bottom end they are being eaten by free Roam/Square dongles at the top end are facing integrated POS Terminals from IBM/Toshiba and Micros. Dedicated payment terminal are commodities, and thus suffer from commodity like competition. Grand hopes for re-terminalization with EMV and NFC are not happening (see blog). New dongles and mobile acceptance infrastructure is developing even in the complex EMV space (see Tedipay.com )stand
  • POS strategy centers around data as well. Google’s Zave purchase has given them opportunity to help retailers focus advertising and eliminate paper coupons independent of payment network. Other leaders like Fishbowl and Open Table in Restaurants have integrated into the POS. The BIG idea here is to integrate the POS to the cloud and Google is now 5-7 yrs ahead of everyone (2 yrs engineering, 2 yrs IBM Certification, 3 yrs to sell and test w/ retailers, +++ yrs in content/ads/targeting).
  • Square’s new Stand is an integrated payment, POS, inventory management, CRM, marketing and loyalty system.. all on an iPad.
  • Payment Terminal “software”. Verifone’s Verix architecture and equivalent schemes have failed. Idea was to allow 3rd party developers to create “apps” for a non-secure space in the payment terminal. For example, 2 years ago, Google’s first version of wallet leveraged NFC to communicate “coupons” to the payment terminal, which then relayed to the POS.  Problems are obvious..  A grocer like Safeway has 2,000 person development team around their IBM 4690 POS, guess how many engineers support the payment terminal? NONE. They don’t want apps on a PCI compliant payment terminal.. it goes beyond question of who will manage them. Also note that payment terminal interaction with the POS is simple today (payment request and authorization).  There is also significant development work to RECEIVE coupons from a PAYMENT Terminal.

Services

  • This section could fill a book, so I will make this brief. All network participants are working to deliver services. The 4 party networks cannot innovate. For example, take a look at my very first blog, topic was Googlization of FS. Visa built an offers services with Monitise and Clairmail 3-4 yrs ago, but the large issuers refused to use it, preferring to innovate themselves. Another example is V.me, a topic which makes Card CEOs red faced. These points exemplify the dynamic w/ V/MA and the large issuers.. Issuers want to dumb down the pipes and limit services, V/MA want to grow them and relationships with consumers.
  • Current state is myopia.. everyone is working as if they uniquely own the customer. Banks and Card Linked offers are top example. When you go into a bank branch, do you want to buy socks? dog food? Of course not! Banks have great data but they are in no position to run an advertising campaign. I’ve run 2 of the largest online banks in the world (Citi and Wachovia) and can tell you retail customers spend about 90 seconds with me, they log on check their balance make a payment and leave. They don’t stay around to click on coupons. Commerce, and retail, is in the midst of a fundamental restructuring as online and off line worlds converge in new ways (beyond show rooming).
  • Payments are just a small part of the overall commerce value chain, yet they have by far the highest cost. The proposed 30bps EU fee cap may occur in other markets, thus banks are working feverously to build services to replace this revenue (primarily around credit cards), with CLOs largely failing to deliver value (see blog). Yesterday we say Ally Bank discontinue Card offers, following Amex last week.

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.

Future of Retail Banking: Prepaid?

Today’s pre-paid dynamics may be the tipping point by which 3 party networks begin to overtake V/MA in growth. A trend that will accelerate when other business models require “control”. This next phase will be centered around merchant/consumer transaction data, which will begin to unlock the advertising revenue pool, which is almost 4 times larger than that of payments.

Payments and core banking will become a “dumb pipe” business unless Banks create value and assume a larger orchestration role. POS Payments are the central feature of a transaction account, if banks loose this relationship they will be in a poor position to orchestrate. 4 party networks are very, very hard to change.

Nov 7 2012 (updated for typos)

Warning.. long monotonous blog. Sorry for the lack of connectedness, written over 7 days and my editor is rather slammed. You have been warned, so don’t complain….

Summary

  1. The competitive dynamics surrounding a “transaction account” (ie DDA) are shifting. For example, Retailer banking/prepaid products (Wal-Mart, Tesco, ..) offer significant fee advantages to most lower mass customers. Three party networks like Amex and Discover have unique advantages when combined with Retailers distribution/service capabilities. This means prepaid has become a disruption: a new good enough product…
  2. Net interest income is 64% of total US retail bank revenues, yet the bottom four deciles of mass market customers are no longer profitable. Given that the transactional account is the #1 factor for retail bank profitability, what are implications if banks loose it?
  3. There is a high probability for disruptive value propositions in Payments, as advertising replaces merchant borne interchange.  Payments and core banking will become a “dumb pipe” business unless Banks create value and assume a larger orchestration role. POS Payments are the central feature of a transaction account, if banks loose this relationship they will be in a poor position to orchestrate.

Does anyone else have trouble keeping up with state of the art? Who is doing what? My method of keeping up with change is to immerse myself in a given area for a day or two. It also gives me a reason to call my friends and colleagues.  This week the theme is retail banking. I’ve spent too much time thinking about payments and how it relates to mobile, advertising, …etc.   I thought I would dust off my banking hat and think in terms of a banker.

Retail Banking

I’m struck by how odd retail banking is. Why are banking services not more simple? Why do I have a separate savings, checking and card account? Why not one account? if the account runs in a arrears I pay interest and if it runs in credit the bank pays me interest? Why does a bank take 3-5 days to move money? How on earth do the banks afford all of those stand alone branches when I visit them perhaps once or twice a year?  Why all of the regulation? What does my bank do for me? What problems do retail banks solve? Can someone else solve these problems more efficiently?

There is certainly no single answer. Retail banking serves many demographics, from the college student to the billionaire. Historically retail bank relationships were very important relationships, as banks only lent money to people they “knew”, based on the deposits they had. Younger consumers need to borrow, older consumers …  savings. Banks focused on things like college student accounts to lock in that relationship as early as possible. Today’s modern financial markets provide for the securitization of loans, thereby spreading risk among various investors willing to assume it. Does a banking relationship matter anymore? to Consumers? to Banks?

I’m struck by how little change has occurred (in the US) on the liabilities side of the banking business? Quite frankly US consumers are treated like idiots who sacrifice “protection of capital” over risk. We now have an entire agency working to protect US consumers from banks.. (BTW what is predatory lending?). Other markets let consumers take on risk.. and hence have many more choices, and innovation, in savings. For example, I’m very fortunate to have worked with so many fantastic people over the years. The great thing about running Citi’s channels globally is that each and every country had a somewhat unique competitive and regulatory environment. It was like running 27 different banks. There were many different strategies for deposit acquisition, for example:

  • In Spain we had a 10/2 product that paid 10% interest on deposits for the first 2 months.. then went to 1%.
  • In Japan Citi leveraged its global footprint, and the poor local consumer rate environment, to create foreign currency (FCY) accounts which allowed consumers earn higher returns by assuming currency conversion (FX) risk in uninsured accounts.
  • The UK is perhaps the most competitive retail bank environment in the world. Consumers in the UK can switch banks almost as easily as changing shoes, it was thus essential to enable consumers to switch quickly and then get them into other products quickly. Take a look at today’s UK savings rates from MoneySuperMarket (8% on a fixed $30k deposit) vs the US (1.05% bankrate.com).  Rate differences on this scale helped fuel the carry trade in Japan.

In the US, it is well known (inside the banking community) that banks are highly discouraged from competing on rates. Not that it matters, this amazing study by the Chicago Fed (Chicago Fed – Checking Accounts What Do Consumers Value – 2010) shows that US consumers are rate inelastic.. and care much more about fees. You have read this right, consumers don’t care about interest rates on their deposits.. which is certainly NOT intuitive. Perhaps rates are all so close to 0% that 5-10bps doesn’t matter. Or perhaps  because the average US consumer does not save at all, and those that do have their money in another place.

Retail Bank Profitability. Net interest income (2011, represented more than 64% of total US bank revenues) is the rate spread between borrowing short and lending long, or more broadly the differential between asset yields and funding costs. Net interest margins (defined as net interest income over average earning assets) were 3.6% at year-end 2011, just 11% higher from the 20-year low of 3.2% in the last quarter of 2006.

From DB Research

As low rates persist, loan-to-deposit spreads fall as prices adjust, and longer-term securities, held as assets, roll over to lower-yielding securities (the same holds true on the funding side, of course, helping to extend the positive impact of falling interest rates into the future). The net impact on banks’ net interest levels may be negative, though. In previous recoveries, this effect has been offset by increased loan volumes, allowing banks to return to sustainable growth levels. Furthermore, as an economy recovers, banks may quickly benefit as short-term assets roll over at higher rates

To summarize: Bank net interest income is important (64%), and falling. Banks have had a key revenue source taken away from them (Debit interchange) and are also facing another merchant led suit on credit card interchange. Bank brands and reputations are on a steady downward trend. Consumers don’t care about rates, but react strongly on fees. … A new regulatory agency to protect consumers is just now forming and looking to make its mark. What are banks to do?

Transaction Account

What is the purpose of a bank provided transactional account today? Well certainly our mattresses are a little less lumpy, and the relationship factors have largely gone away. So what is left? Transactionality?

The banks have long recognized that the transactional account is the #1 factor driving a consumer relationship. Virtually every other banking product and service hangs from this account. Most retail banks view direct deposit (internationally known as Salary Domiciliation or Sal Dom) as the key indicator of the transactional relationship. Consumers have limited “energy” to connect to more than one network (as outlined in followed my previous blog on Weak Links). 

This financial supermarket concept, authored by Sandy Weill and John Reed, has not exactly been a slam dunk success. Nonetheless every retail bank starts selling with a checking account, even if nothing else is attached. What are the key factors influencing the selection of a transactional account?

  • Why are deposits important to banks?
  • Driver of overall relationship à Customer Net Revenue
  • Liquidity ratio ->Risk ->Agency Rating -> Capital Costs
  • How do consumers select a bank?

The public compete data above is completely consistent with previous proprietary studies I’ve commissioned. Consumers tend to pick their bank based on how convenient the branch and/or ATM is.

Is there something fundamentally changing? What if consumers don’t visit a branch… or no longer use cash? Are there new value propositions? Where will consumers (and their deposits) go?

Recent market developments/Announcements

The Amex Bluebird product is revolutionary in terms of fees. It is the lowest cost reloadable card in the market today. Beyond the product, I’m even more impressed with WalMart’s business strategy here. They seem to be willing to break even on payments/banking in order to win the overall consumer relationship and increase foot traffic and loyalty in their stores. Take a look at the suite of products offered by WalMart. While banks are pushing out the bottom forty percent of mass consumers, WalMart has made a bet that it cannot only serve them, but do so profitably.

There are many different types of pre-paid cards (more below), however most are not regulated as bank accounts. In almost every geography, consumer deposits (interest bearing, insured) are regulated because they drive both bank liquidity (which drives lending and cost of capital) and profitability. Remember before capital markets existed to securitize assets (loans) retail banks could only lend to the extent of their balance sheet (deposits). Consumers put their money with banks in order to earn interest (the carrot) with the downside of fees on usage (the stick).  In the US consumers are beginning to ask themselves “is the carrot big enough”?

In emerging markets many banks have a poor reputation, additionally access to legal resources are limited, as are consumer protections. How would you feel if you showed up to your bank for a withdrawal and your bank said “sorry your money is gone” and you had no recourse? This dynamic has propelled other banking models in emerging markets. For example my friend Nick Hughes and his Vodafone/Safaricom team created MPESA in Kenya which provided enormous value to consumers. However MPESA caused an apoplectic reaction from the banking regulators as 10% of Kenya’s GDP sat in a non-interest bearing Vodafone owned settlement account. MPESA therefore impacted bank liquidity (IF the funds would have gone into a bank account as opposed to just M1/cash). Visa and MA have worked hard to try to make prepaid the underlying account for mobile money in emerging markets, to very little avail. The problem is not connecting people to the V/MA network.. and giving balances to an approved bank. The problem is first transferring money to entities currently not on any network, then paying a very small number of billers.  

Why are consumers defecting in the US? Ernst and Young just published a phenomenal global study on this subject. The result of their analysis was that consumer confidence in banks is degrading. E&Y outlined a call to action by banks: reconfigure your business models around customer needs. My hypothesis is that consumers have reached a tipping point where they view banking services as commodities… In the UK, this is already well established.

Prepaid

I haven’t spent much time thinking about prepaid cards so I thought it was time to refresh myself, particularly in light of MCX and the prospect of retailers acting as Banks.

From the US Fed

Prepaid cards offer much of the functionality of checking accounts, but that does not mean the underlying economics are the same. A typical prepaid card in the data is active for six months or less, a small fraction of the longevity seen with consumer checking accounts. As a result, account acquisition strategy and the recovery of fixed and variable costs are likely different than for checking accounts. …. prepaid cards with [direct deposit are uncommon but] remain active more than twice as long and have 10 times or more purchase and other activity than other cards in the same program category. As a result, these cards typically generate at least four times more revenue for the prepaid card issuer

Similarly Pre-paid cards also face a complex web of regulation (See Philadelphia Fed Paper 2010), across 31 different types of cards.

31 types of cards? Did anyone else realize the diversity here? Wow… For the sake of this blog, let’s focus on reloadable (GPR) open loop cards (references to prepaid below are on this card type only). It would seem that GPR pre-paid is following the general disruption pattern of serving a lower tier of the market at a more attractive price point. According to Mercator, In 2009, consumers loaded $28.6 billion onto prepaid cards. By 2015, prepaids will hold $168 billion.

Last month’s WSJ ( Prepaid Enters Mainstream) outlined this dynamic

Traditional leaders in GPR pre-paid have been Green Dot, NetSpend, . The Durbin amendment exempted most prepaid cards. This means that pre-paid is largely example from the Durbin interchange restrictions… (with several conditions). Thus the business case for pre-paid is rather strong, and Banks themselves are assessing if they can make this the new “starter” account (ex Chase Liquid). However Three Party Networks (Discover and Amex) have a significant advantage.

From Digital Transactions, March 2012

While the Federal Reserve’s rule implementing the Durbin Amendment has its greatest effect on traditional debit cards, it affects prepaid cards too, especially its provision that banks’ prepaid cards can avoid Durbin price controls only if cardholders can access the funds exclusively through the card itself. That provision thwarted banks’ efforts to make prepaid cards more like demand-deposit accounts and led them to scale back or end bill payments through prepaid card accounts.

But American Express and Discover are not subject to Durbin’s controversial provisions, Daniel and Brown noted. Both companies are so-called “three-party” payment systems that function both as merchant acquirer and card issuer. In contrast, Visa and MasterCard debit and prepaid cards are part of “four-party” systems in which the issuer and acquirer are usually different companies and rely on the Visa and MasterCard networks to route transactions among them. The Durbin Amendment exempts, or “carves out” in industry parlance, three-party networks from its provisions, including interchange regulation.

“There’s no restriction on what AmEx can pay itself” for prepaid card transactions, said Brown. Thus, AmEx and Discover have a new opportunity to grow their prepaid businesses, the attorneys said.

Clearly Discover (DFS) and American Express (Amex) have an opportunity to “Kill” prepaid cards, what are they missing? Physical distribution, service and reach in the mass market. These are the very things that retailers like WalMart can provide, and in fact economically benefit by providing them.

As you can tell, regulations are driving the business models here. Most large US retailers leverage a fantastic team of attorneys from Card Compliant that specialize exclusively in prepaid cards (run by my friend Chuck Rouse). WalMart’s move to Amex is brilliant both from a regulatory and business model perspective.  

Today’s pre-paid dynamics may be the tipping point by which 3 party networks begin to overtake V/MA in growth. A trend that will accelerate when other business models require “control”. This next phase will be centered around merchant/consumer transaction data, which will begin to unlock the advertising revenue pool, which is almost 4 times larger than that of payments.

Payments and core banking will become a “dumb pipe” business unless Banks create value and assume a larger orchestration role. POS Payments are the central feature of a transaction account, if banks loose this relationship they will be in a poor position to orchestrate. 4 party networks are very, very hard to change.

I see a battle where 3 party networks work to branch into orchestration and advertising, and existing orchestrators (ie Apple/Google) integrate legacy dumb pipes (payments and telecommunication) to deliver value to the consumer. What do consumers value today? This is the call to action for bankers… who are not always the best at creating alliances.

Here is one idea, focus on trust and helping consumers solve problems they don’t face frequently. For example,

  • Make financial planning easier and less of a sales job.
  • Help manufactures and retailers connect to target consumers.
  • Become a buyers agent?
  •     Help navigate the college application and loan process,
  •     Help  buy a new car for the lowest possible price…

I know this is not a clean finish.. but that’s all the time I have.

References

Thank you Kansas City Fed for the fabulous brief from the: CONSUMER PAYMENT INNOVATION IN THE CONNECTED AGE. Bill Keeton and Terri Bradford were nice enough to invite me, but unfortunately I couldn’t attend. In my last visit to the KC fed we spoke about future payments types, but we also spent quite a bit of time discussing where mass market consumers will go if banks view the bottom 4 deciles of retail banking as unprofitable (according to proprietary McKinsey Study).  Today I thought I would pull together a compendium of my learnings on retail deposits, MSBs and pre-paid… the “transaction account” by which payments flow.

Green Dot Bank: Finally Wal-Mart gets to Play

16 Jan 2012

http://www.reuters.com/finance/stocks/GDOT.N/key-developments/article/2447460

GDOT Bank – Federal Reserve Authorization

GDOT bought Bonneville Bancorp for $15.7M + $14M Capital Infusion on 8 Dec 2011. Bonneville was a Utah licensed state bank and a  Fed member (regulated by Fed). This is a very significant deal for several reasons:

  • Sets a new regulatory guidepost in the creation of “national” bank with a pre-paid focus. See Bank Talk article on how GDOT was able to get Fed Approval, specifically around CRA responsibilities.
  • Is essentially WMT’s retail bank for consumer services (WMT owns ~15% of GDOT)
  • Model for future deals in State Chartered banks (particularly for retailers)
  • Highlights need for reassessment of “pure play” banks in pre-paid space (ex. Meta)
  • NEW PRODUCT potential in interest bearing pre-paid accounts targeted to the lower mass market

This is a brilliant move by the Fed, and by GDOT. The Fed is rightly concerned about the fact that the bottom 4 deciles of customers are no longer profitable for the big banks.. and there is an exodus. How does the US financial system retain customers in the lower mass? GDOT and WMT believe it is not through the typical branch model. Just as with Tesco in the UK, Retailers are proving to be excellent distributors of banking services. Retailers do not need to make their margins on bank services alone, in fact banking services improves the overall retail value proposition, brand and loyalty. The same holds for mobile operators internationally.  Why should I pay for all of those branches and sales people if all I need are basic payment services?

I joined Citi in 2006 with the mandate to grow the retail business without growing the number of branches. Creating the ING direct competitors.. the HOOK was high yield savings. GDOT bank could be catalyst for a new retail banking model, with a HOOK associated with “payment”, retail convenience, loyalty and data use.

What are the core product innovations? Here is my list:

  1. Combining a GPR card with retailer brand and distribution (WMT). Banks normally have to seek charters that enable them to operate nationally (ex. Fed, the now defunct Thrift, …) when doing business in multiple states. Virtual GPR cards don’t have this problem as consumers are buying a banking product in another state.
  2. Stand alone consumer value proposition. GPR card that can earn interest on funds held on balance. GDOT/WMT also have a established a rate structure that is one of the best in the business.
  3. WMT’s integrated value proposition. International transfers ( WalMart owns part of MGI they are 30% of MGI’s TPV), International Banking (Mexico, Canada, GDOT, …), StraightTalk prepaid mobile, … they have all the components to deliver value. Can they bring it all together?

Banking is a network business.. the GDOT opportunity is to build the network quickly through key retailers (as physical distribution). What other innovations can they bring to market? At the top of my list would be instant credit (Paypal BillMeLater does this through a WebBank a Utah ILC). Or real time transfers to any bank (using  $0.58 Fed wire…).

Today, MSBs are restricted in both offering interest on accounts and the length of time they can hold a balance (escheatment). There will be some regulatory scrutiny by the State Regulators on how cash in/out is performed at the physical retail outlet, and what constitutes a “bank”. From the Retailer’s perspective, the GDOT card is a product which can be bought (buy $100 GDOT reload), with cash out from ATM or through a Mastercard purchase. GDOT is a licensed MSB in 39 States (according to their 10-k) with a network of 50,000 cash in/out locations. Previously GE Money was the US bank for the WMT MoneyCard. A single state licensed bank owned by an MSB network may face some state regulatory scrutiny. GDOT can probably address by keeping as separate legal entity with its own BOD and capital.

If I were thinking of starting the next PayPal… I would skip getting MSB licenses in 47 states and start looking for a Utah bank I could buy.

What to look for:

  • Retailers following this model (including ISIS, Amazon, …). Particularly retailers serving lower mass market
  • Salary d0miciliation (direct deposit) onto a card
  • Future of GE Money. GE has been looking to sell Mark Begor’s business for some time. It is subscale, and WalMart is its largest US customer. My guess is that WMT had to develop fall back plans in case GE did sell the business. I would not be surprised to see GDOT bank be the primary bank behind the MoneyCard.. but it hasn’t happened yet.
  • Pre-paid processors and platforms looking to create their own brands.. or change their relationships to retail branded banks
  • MSBs moving toward a state bank license. Issue is cash in/out. MSBs that require their own branded physical distribution will keep MSB license… those that are virtual will move to GDOT model.
  • Consumers making switch to a “new” banking model centered around payments.
  • Semi closed payment networks with integrated loyalty and incentives.
  • New Payment Banks which make money on marketing and data (not interchange). See Googlization

For those interested in a Utah Bank.. please call my favorite Utah Banker.. Crawford Cragun..

Your thoughts are appreciated. As always sorry for the typos and the brevity.

Payments Innovation in Europe

So in Europe see the consequences of ubiquity. While SEPA was designed to increase competition and create new European schemes, there are few business models capable of supporting investment. Hence Europe is not the place to start a retail payments business. This is why I look to Asia, LATAM and Canada as great places to start a payments business (my picks: PH, HK/China, Brazil, Malaysia, SG, Colombia, Indonesia and New Zealand).

8 March 2011

Why do I like the Payments business? It is ubiquitous, sticky, with good margins and strong annuity revenue.

What do I hate about the payments business?

In the US, it is over regulated, concentrated, difficult to change and frustrating enigma driven by large FSIs with unlimited resources…. Within Europe the situation is little different.

After coming back from last week’s trip the Valley, I was attempting to develop an investment hypothesis on Europe, mobile, payments and innovation in general.

While Europe’s individual talent is second to none, and capital is plentiful, the European market is designed to resist change and thus impedes the development of early stage ideas and companies. Early stage companies can incubate within a single country but are challenged to expand beyond, due to complex regulatory and market dynamics. Navigating these dynamics causes early stage companies to develop more slowly, thus a requiring a higher risk premium on invested capital.

                   – Tom’s European Venture Capital Hypothesis

SEPA Overview 

(European colleagues can skip this section). 

SEPA and PSD (SEPA’s enabling legal framework) attempt to create harmonization of payment schemes across the EU (See SEPA Blog, and excellent PodCast). The result?  837 pages of detailed and contradictory EU law with no business incentive. SEPA has been plagued with delays and issues, as should be expected given that there was no business incentive nor a PAN EU regulator to enforce it. SEPA Credit Transfers and SEPA Card Framework have been in place for a few years (2008). While the SEPA framework commoditizes payments, and while this is consumer friendly, there is no business incentive to for large banks to implement it (see Barclay’s consumer support on SCT).  The same can be said for the SEPA Card Framework (See MA’s Self Assessment). The main points from ECB’s regular status report:

  1. Banks must create greater awareness of SEPA, and must offer better products, based upon the SEPA infrastructure. Government should accelerate programs to adopt SEPA as the standard for its disbursements.
  2. The banking industry must commit to work together to remove obstacles which might compromise the Nov 1 2009 launch date of the SEPA Direct Debit. Debates on the launch date, the validity of existing DD mandates, and interchange fees must be closed out rapidly.
  3. Bank systems need to be improved to enable end-to-end straight-through-processing, originated by files submitted or by e-payment, e-invoicing, and m-payments.
  4. The ECB wants to see a target end date for migration to SEPA products, and for exiting out of older credit transfer and direct debit.
  5. The SEPA card framework in its current form has not yet delivered the reforms which the ECB wants. In particular, ECB wants to see a European card scheme emerging.
  6. The ECB perceives a lack of consistency in card standards. It wants to ensure that a clear set of standards are adopted and promoted throughout the industry.
  7. A common, high level of security for Internet banking, card payments and online payments is needed.
  8. Clearing and settlement organizations in many countries have made good progress on SEPA, and several are upgrading from national to pan-European.
  9. The banking industry, and its representative body, the EPC have not sufficiently involved other stakeholders.

 SEPA’s Impact on Innovation

European harmonization is a fantastic objective, but translating EU guidance in to country law, with each country’s banking regulators responsible for interpretation and guidance, is problematic. This becomes even more difficult when Banks (who were not included in the SEPA design) have an inverse adoption incentive. An analogy in the telecom world would be telling the land line carrier that the must open up the switch to anyone that wants it at no cost.. and they have to assume all of the risk and operational responsibility.

Early stage companies and “payment innovators” are left with a complex set of constraints.

  • Dependent on local national relationships to launch a product,
  • SEPA creates harmonization, but country specific laws and regulatory guidance are unique
  • ECB initiatives (ex. See ELMI) create opportunities for non-bank participation in payments,  but SEPA has removed all margin from the business

So in Europe we see the consequences of over regulation.  While SEPA was designed to increase competition and create new European schemes, there are few business models capable of supporting investment. Hence Europe is not the place to start a retail payments business.  Hence Asia, LATAM  and Canada are all great places to start a payments business (my picks: PH, HK/China, Brazil, Malaysia, SG, Colombia, Indonesia and New Zealand).

Europe and Advertising

I don’t have time to finish the thought here. For those of you that read my blog you know I’m very enthused about the prospect for advertising to be a future payments revenue driver. Unfortunately for the EU, consumer privacy regulations (and subsequent “tracking” issues) are the most onerous in the world. In Germany for instance, my Citi team was forced purge the web log of IP addresses every 30 minutes.. for our own customers. The point here is that we could not even maintain loosely correlated consumer information in regulated accounts. Google has similar problems today (see Das ist verboten).

Where is the EU opportunity?

Where there is an intersection of: low margin payments, businesses with frequent cross border (within EU) transactions, without need or desire for banking relationship. MoneyBookers is an excellent example of this model in gaming.

Other possible  investment drivers relate to when payment transaction infrastructure is a commodity:

Arbitrage – Move intelligence to new regions or countries where the cost of maintaining it is lower

Aggregation – Combine formerly isolated pieces of dedicated infrastructure intelligence into a large pool of shared infrastructure that can be provided over a network

Rewiring – Connect islands of intelligence by creating a common information backbone

Reassembly – Reorganize pieces of intelligence from diverse sources into coherent, personalized packages for customers

 Thoughts appreciated.

Investor Short Take – Payments

VCs can expect $5-$10B of industry investment in payments over next 5 years as new networks develop. Its important to ensure existing investments have plans to align to one of the emerging ecosystems. Go it alone will not work…

7 Dec 2010

Summary for investors:

  • Ensure existing investments have plans to align to one of the emerging ecosystems. Go it alone will not work.
  • Expect $5-$10B of industry investment in payments over next 5 years as new networks develop.
  • Seed teams with people that have experience in payments and working across large players. Success will not come from “technology” ..
  • Focus on delivering value to one leg of the network. Merchant friendly value propositions are recieving new focus.. but retailers are not participating where there is “traditional” bank leadership.. new non-bank networks are forming.
  • Digital goods payments is red hot, and also likely to be focus of Google, Apple, Amazon, Visa, MA, PayPal, … Solutions will be driven from multiple players, the “channel masters” of: content, social network, consumer payment, consumer advertising, …
  • The relationships between the large banks and Visa/MA are deteriorating, particularly in the area of innovation. NFC is still an area for collaboration, but small and mid-size banks are more likely to align w/ Visa/MA plans than the large players.
  • Consumer payment behavior changes in 20 year cycles, largely because there is little differential value (beyond rewards). There are exceptions, as Target is attempting to prove through its REDCard. Other large retailers are assessing plans to buy a bank, replicating  Target, and WalMart (in Mexico and Canada)
  • As a rule, Banks are not collaborating with each other or internally and seem to be engaged in multiple initiatives in a hedge your bets strategy (to see what sticks). If your companies are working with a bank, don’t assume there is coordination internally.. your teams must learn to work across complex political lines.

Quite a few interesting “rumblings” this week.

1) Bank of America Merchant Services and First Data are assessing development of a new card network.

2) Google and a major bank (?Citi) are working heads down on a mobile payment platform network driven by mobile advertising revenue. Citi would make sense given its 110M cards and it’s key weakness in merchant acquiring (vs. Chase Paymenttech and BAMS). This team still would leave a large gap at POS…. So perhaps Discover is there as well? Yeah that is a very wierd prediction.. Citi rebranding all of its portfolio Discover so it could regain control.

3) Apple working on a 2Q11/3Q11 iAD platform, with couponing and purchasing. This is a rather big project as they also work to consolidate 4 internal payment systems (legacy apple store, iTunes, app store, and Treasury) with new mobile walled (Apple Patent) and a major bank as partner (?Chase?)

4) Wells Fargo and Bank of America retail teams assessing collaboration on a mobile P2P platform.. which was taken away from their Pariter JV.  See related Blog. I’m sure the cards groups must be shaking their heads a little given the anticipated volume, but banks cannot cede this space.. and it is critical to bank leadership. I just wish the banks would focus on the business and not on the technology.. just buy Cashedge and put it in The Clearning House or something.

5) Merchant acquirers and processors putting together more focused offerings for large retailers. See Target Red Card.

6) Visa and MA have M&A plans around pre-paid which are in flight, a focus more on the G2P and Cross border segments rather than mobile… re: mobile, Visa and MA have retrenched here after “learning lessons” in failures of Mastercard MoneySend (Obopay) and Visa Money Transfers. Funny that MA learned its lessons on a remittance focused Obopay, while VMT attempted to focus on domestic card-card and now is “refocusing” on remittance.

Chase QuickPay and Quick Deposit

Chase has a stellar eCommerce and mobile team in both their retail and cards organization, and they are poised to deliver tremendous payment innovation across both of these business units. This innovation that has been “in the works” over the last few years, and Jack Stephenson (PayPal’s former head of strategy) is fortunate to have a joined at a time where both the payment platform and team is gaining traction. This month the JPM retail team has delivered new capability in its iPhone versions of QuickPay and Quick Deposit products.

25 July 2010 (Updated 20 Aug)

Chase has a stellar eCommerce and mobile team in both their retail and cards organization, and they are poised to deliver tremendous payment innovation across both of these business units. This innovation has been “in the works” over the last few years, and Jack Stephenson (PayPal’s former head of strategy) is fortunate to have  joined at a time where both the payment platform and team is gaining traction. This month the JPM retail team has delivered new capability in its iPhone versions of QuickPay and Quick Deposit products.

QuickPay Overview:

QuickPay is a JPM’s money movement “pay anyone” service that provides registration for both Chase and non Chase customers. Chase was very late to the money movement game, rolling out its first QuickPay service in 2008 (whereas Bank of America and Citi have been providing this since 2002  through CashEdge). From a strategy and organizational perspective, JPM is well known for their “preference” to develop applications internally. It may have taken some time for JPM to complete the QuickPay internal build, but in the current release it has surpassed the domestic capability (and usability) of all other banks. JPM is now the leader in retail online payments.

Non-Chase customers can register for QuickPay before or after receiving funds. For non customers, registration for QuickPay is similar to PayPal (or CashEdge’s PopMoney), with the QuickPay wallet currently constrained to single linked checking account. Chase customers have a streamlined enrollment process and the QuickPay functionality is integrated into their existing online experience (demo above). This differs substantially from BAC, where the same capability to transfer funds exists but the usability is very poor. BAC is missing a substantial opportunity to capture beneficiary phone/e-mail information, an unnecessary miss since the capability exists (BAC is Cashedge’s largest US customer but has not yet signed on with CashEdge’s mobile POP money service).  Beneficiary information is critical to maintaining an accurate directory.. the key element in any payment system. Chase’s QuickPay maintains e-mail, phone and other information which gives it a head start in the directory battle (subject of future blog).  Given Chase Paymentech’s role in acquisition (for card, paypal, …) you can see potential for further directory synergies internally.

Quick Deposit

The articles above provide a great overview of the new iPhone App, with Chase following in the footsteps of USAA’s Deposit@Mobile. Application is from Mitek Systems and it is just super, and for small merchants this may become the payment method of choice (when compared to card):

Merchant benefits:

  • No transaction costs (savings of 150-350bps)
  • Usability and simplified enrollment
  • Same day availability of funds
  • Fits existing consumer behavior pattern (checks)
  • Legal protections/enforceability (paper checks vs. electronic signature)
  • Instant verification, risk and fraud management
  • Leverages bank imaging systems and processes (regulatory and consumer receipt)
  • Notification/receipt to consumers

JPM Business Case

  • Check imaging (op expense)
  • Small business acquisition (Customer Net Revenue for SME = $3-$5k)
  • NRFF for non-customers (NIM on settlement funds held)
  • Future “directory” business case, cards growth
  • Prevention of DDA Account Number Breach

The JPM Quick Deposit application was reportedly built in-house, other Vendors such as EasCorp’s Depozip provide similar functionality. As for the success of this application, NetBanker reported USAA’s recent numbers for Deposit@Mobile. (update 20 Aug, my friends at BAC tell me that they have been trialing the Mitek application for almost 3 years now, fine tuning the app and the support process and are set for launch any day) .

Given that the audience for this blog (investors, start ups and innovators), you might ask why it takes 2 years for a bank to roll out this type of innovation. An excellent question! The iPhone app itself is the easy part, perhaps consisting of less then 20% of the overall budget. The “hard work” is in integrating it into existing systems and risk controls. For example, the primary value proposition, for QuickDeposit, is improving check acceptance and funds availability. At the teller line, banks have tools like DepositChek which allows the bank to determine if information on the check is correct and the account is in good standing (stopping check fraud before the check image gets into the system). These same tools must be integrated into the online and mobile process to reduce risk. I’ve picked this particular example because it is a tool unique to bank entities (not available to non-banks). In addition to the technical integration costs, banks have become very prudent in testing, and accessing impact of new functionality to call center support costs. Given the wide availability of both of these applications, it is essential that they are intuitive to JPM customers.

These applications are a great retail success. I understand that the JPM cards team is also poised for a major release in mobile soon (with multiple alliance partners). Well done JPM!

Enroll for QuickPay – www.chase.com/QuickPay

Overview of Quick Deposit  – www.chase.com/quickdeposit

Thoughts appreciated

Firethorn gets new CEO

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

9 March 2010

Press Release

Previous Post “Obopay and Firethorn”

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

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

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

– All the best Rocco