Tag: networks

Banks/Non-Banks and Commerce Networks

Banks/Non-Banks and Commerce Networks (Why I love V/MA)

27 July 2014

This blog has been in 50% mode for 2 weeks! Obviously summer is not my productive time (I must be German). There will be a noticeable change in my blogs these next few months as I work on a newco launch. Blog will therefore focus more on concept, much less G2.  This will be a transition piece…

What is the benefit of becoming a bank? Would Paypal buy a bank? That is the rumor… I have no idea on this one.. 0% confidence.. my guess is no way. There are some great payment+bank companies (Amex, Wirecard and Alliance Data), and some great payment non-bank companies (Visa, MA, Stripe, Paypal, …etc). What are the business drivers of becoming a bank? What are the Pros/Cons?

Summary

For those without time to read below, a bank license brings on enormous compliance cost and restricts: what business you can do, how you manage consumers and their data, and what risks you can take. The upside for being a bank? You get to take risk with other people’s money. Simply put, any company contemplating a bank license must have a business plan MORE dependent on managing risk than on orchestrating commerce value.  Today there are many bank licensed “specialists” which support non-banks (TBBK, Meta, Alliance Data)… so why would you want to become one? Paypal is on the fence here, as historically they won in eCommerce because of their ability to manage risk (CNP Fraud). Do they want to grow in risk management? or in everything else?

When looking for the right regulatory structure of any company, we must assess their current network plans in the context of commerce AND banking. Not just how your network delivers value today… but rather how you deliver value in the future? Banks tend to make most of their money within their own node, whereas others in commerce are highly dependent upon other partners (manufacturers, distributors, agencies, sales, …). Electronic payment growth and network services are set to grow geometrically, yet payments are very very sticky and hard to change. This is the start up investor conundrum:  How do you make intelligent investments in payments/new networks? There are 3 basic options

1) Help others expand their networks

2) Build new networks

3) Build communities with minimal need to network outside of your environment (Facebook, Amazon, Alibaba, BANKS?…)

92% of all electronic transactions are done in the top 10 markets. (Cap Gemini’s World Payments Report is a must read). 90% of the worlds population is not connected to financial services. There is a n-squared dynamic when this takes place.

Many entrepreneurs, journalists and technologists miss THE CORE facet of Visa and Mastercard: a business platform where thousands companies invest billions of dollars. There is no way to compete technically with this business model, rather the ONLY way to “compete” is on value and services. Where Amex has the ability to deliver much broader and richer services (as they own both merchant and consumer accounts), they have a downside: no one else investing in their network (scale/adoption).

My firm belief is that both V and MA have the opportunity to grow Revenue 4-10x in the next 5-10 years. Their principal challenge is to “tilt” their models away from Banks and toward the 2 parties that matter most in commerce: Merchants and Consumers. Payments work well, but so did the Sony Walkman. The bets that Google, Apple, Amazon, Facebook and others are making is on value orchestration (in a new network). Does this involve payment? Not really.. at least not as a primary focus.. Payment is there.. but orchestration is about commerce; payment is just one of many important processes (See blog Payment in the OS).  Don’t look at payments as something in isolation, payments are the “connections” made in commerce; they are made for a purpose. These payment connections are rapidly changing from many environmental forces:

  • Internet flow of information,
  • Google enabled discovery
  • MNOs have enabled constant connectivity
  • Social has enabled reputation across activities
  • Online retail has enabled price transparency, comparison and product reputation
  • Changing of Bank roles, products and services
  • New Consumer behaviors

Payments = Network

Payments are the connections of the GDP. If we were to map payment flows, we would unlock a map of the global GDP at the micro level, from employment to shopping, behavior and preferences, to demand and supply. Perhaps this is why our government loves payment information. Oh.. the stories here.. (for another time). Free information flow on the internet is enabled through openness and a single primary protocol, whereas payments operates within 100s of proprietary networks with a complex series of clusters and “switches” (there is effort in connecting, authenticating and managing risk). Just as it would be nearly impossible to change the protocol for the internet, it would be difficult to bring abopayments pyramidut fundamental change in payments (see Rewiring commerce).  Connecting business is much different than connecting information (the core of my NewCo.. but I digress).

From a network strategy perspective, the business opportunity of changing “payments” pales in comparison to the opportunity to influence connections in commerce, banking and manufacturing. Payments support business and consumer needs; they do not alter their path. This insight is the downfall of bank payment strategies around “control”, and their inability to “tilt” toward merchant friendly value propositions.

A top 5 retailer provided my favorite commerce quote “I think of Commerce as a highway, the payment networks are like a toll bridge. I don’t mind paying them $0.25 to cross the bridge, but they want to see what is in my truck and takeUS Marketing Spend 2-3% of what is inside. Hence I’m looking for another bridge… “ (See Rewiring Commerce).  Google, Amazon, Facebook, Alibaba, Rakutan, V, MA, Amex, eBay all understand this. Rather than charging toll for crossing their bridge, these networks are beginning to execute against plans to grow the size of the goods in the merchant’s truck.

Intelligent use of data increases the effectiveness of the merchants, and in a way that also benefits consumers. Tilting more toward merchants and consumers.. means tilting away from banks. This is VERY hard for a bank to do. It is a change worth making however, as assisting merchants could meant 4x-10x of their current value creation (payments is roughly a $200B US business, marketing is $750B).

My favorite book on networks is Weak Links by Peter Csermely (viewable on Google Books here). If I had one book for you to read this is it. This book is tremendously arcane, detailed, technical, deep.. but I guarantee you that you will have a new view of commerce, banking, advertising, biology, social networks, payments, and society after reading it. In connecting to networks, each of us have limited resources. Therefore optimize our connections through finite set of “hubs” (unless there is some larger orchestrator).

Think about the battle in connecting networks, as each of us have limited resources we can connect only to a finite set of “hubs” (unless there is some larger orchestrator). Examples are Wikipedia and Google… these serve as the directories of information. It is almost IMPOSSIBLE to displace an efficient hub. This is why I love Visa, MA and Amex. If they can shake the issuer legacy.. and add a few merchant friendly services, they could drive 4x of their current value. Specifically, payments is roughly a $200B business, whereas marketing is $750B (in US).

Against this network strategy and services backdrop, there is an enormous transformation taking place in Commerce and Banking. In other words existing networks are evolving their services, as the “hubs” that they connect to (banks, retailers, manufacturers, aggregators, ..etc) undergo change within their “core”. See Remaking Retail, Future of Retail Banking: Prepaid?.

The regulatory/compliance “headache” for payment “innovators” revolve around connecting networks and engaging in non-commerce transactions. I’m not just talking about just small guys.. but BIG ones too (think Google, Apple, Amazon, Walmart, MCX, …etc).  Existing networks have an existing value proposition, and many don’t like to have their services leveraged by competitors (see Banking and Commerce: What is the Difference?, Don’t Wrap Me).

Banking Services

This leads us to Banking Services… expanding beyond commerce. This is area is very nebulous because of the complexity of regulatory authorities covering “banking” and money services. Here are just a few of the US regulators

Source – 2012 Dimon Letter to Shareholders

What are Banking Services? Anything the regulators say are banking services. I’m not joking.. this is why I put the Paypal 2002 prospectus at the top. Banks are highly regulated, and the compliance costs are extraordinary. Regulators are attacking all things payments and banking with renewed vigor. Along with compliance constraints, there are constraints on how you can use data. As an example, my online banking team in Germany had to purge the server logs of IP addresses every 30 minutes (regardless of use for fraud).   (see Banking and Commerce: What is the Difference).

So what is the upside of being a bank? It’s certainly not the regulation or the mandatory compliance courses forced on every employee. The “benefit” of being a bank is the ability to take risk with other people’s money. Unfortunately, the BIG downside to being a bank, is that data can no longer flow outside of your organization. I cannot understate this limitation.

Banks have much clearer and hence stricter obligations as regards the sharing and protection of sensitive information, commonly known as ‘bank secrecy’. This matches the generally more extensive regulation of a bank, as opposed to the regulation of an ELMI or MSB.

Acquiring a new consumer financial account is hard, even if you get the consumer to create an account with you, you must get them to fund it, or take credit risk on them. These are the problems that banks have dealt with for 100s of years.
take rate

Banks have much clearer and hence stricter obligations as regards the sharing and protection of sensitive information, commonly known as ‘bank secrecy’. This matches the generally more extensive regulation of a bank, as opposed to the regulation of an ELMI or PI. Based on the same reasoning why non-banks require less strict regulation for their business and prudential risk involved, it follows that also their activities and also access and handling of certain information and data is restricted accordingly.

Would Paypal Buy a Bank?

Again, I have no idea here, but it doesn’t seem to make much sense. Considering a bank license is like watching flies in your kitchen window: the ones on the outside want in, and the ones on the inside want out.

For long time readers, I put together a blog about 4 years ago covering this topic Payment Startup: MSB or Bank? and US Payment Regulations.  As I outlined, there are very few payment regulations covering purchase of tangible commercial goods (this is true globally). We can see the evolution from PayPal’s 2002 prospectus.

We believe the licensing requirements of the Office of the Comptroller of the Currency, the Federal Reserve Board or other federal or state agencies that regulate or monitor banks or other types of providers of electronic commerce services do not apply to us. One or more states may conclude that, under its or their statutes, we are engaged in an unauthorized banking business. In that event, we might be subject to monetary penalties and adverse publicity and might be required to cease doing business with residents of those states. A number of states have enacted legislation regulating check sellers, money transmitters or service providers to banks, and we have applied for, or are in the process of applying for, licenses under this legislation in particular jurisdictions. To date, we have obtained licenses in two states.

How does Paypal operate today?

US

  • Licensed money services business in 47 states (all states which require one)
  • Bill Me Later, and paypal working capital are structured so that loans are originated by WebBank (Utah ILC). See this 2013 note on structure/issues
  • PayPal had been a market leader in “deposit” rates, through the Paypal Money Market fund (see Link). This fund was shut down in 2011 due to treasury rates/market conditions (see link).
  • A Discover partnership has yielded little fruit at the POS. Paypal had been claiming that there was an “exclusive” nature to the network agreement, whereas DFS was clear they could work around it by providing other services. (My blog on topic)
  • Paypal has been telling investors it plans to move to the POS, both with mobile, and an experimental paypal plastic card (running on Discover). Nothing is moving here, my guess is that JambaJuice is their #1 in volume and would be surprised if that had more than $50-$100M TPV ($1.5M-$5M in Revenue).
  • MasterCard pre-paid card for PayPal “balance” spend. I love this product, it is how I get cash out of my paypal account at the ATM.
  • Wells Fargo Clears Paypal ACH volume in US.
  • Paypal as strong acquiring relationship with Chase.
  • ADS partnership (see WSJ). In 2013 Paypal and ADS created a partnership with 3 primary components: ADS credit risk management (BML), Paypal merchant acceptance, Data/analytics/marketing at POS.

Europe

Asia

  • In Australia, PayPal serves its customers through PayPal Australia Pty. Ltd., which is licensed by the Australian Securities Investment Commission as a financial product
  • Per eBay’s 10k “In markets other than the U.S., the EU, Australia, Canada, Brazil, and Russia, PayPal serves its customers through PayPal Pte. Ltd., a wholly-owned subsidiary of PayPal that is based in Singapore. PayPal Pte. Ltd. is supervised in Singapore as a holder of a stored value facility.”

I see little upside for Paypal expanding it’s EU bank model to the US, as its current network assets and future opportunity revolve more around supporting commerce than managing risk.  Paypal’s current structure and partnerships (with ADS, Discover, MA, GE, …) provide the flexibility to deliver banking/lending services. For Paypal, Bank ownership would only hinder their broader efforts to deliver value to consumer (through data). Alternatively, a bank structure does work for other companies like Wirecard. The Wirecard bank model is a tremendous fit within a network where mobile operators serve distribution channels for financial services.

With respect to the Paypal/Bank rumors, my guess is that there is an “opportunistic” assessment going on .. and that this rumor is just one of the paths they have looked at. I also have a strong feeling that Discover is looking for a “partner/acquirer” that can make use of its network while it is still somewhat relevant.  Particularly since its M&A discussions with a top 5 bank 2 years ago did not happen.

Token Acceleration

20 Feb 2014

Let me state up front this blog is far too short, and I’m leaving far too much out. Token strategies are moving at light speed… never in the history of man has a new card present scheme developed so quickly (4-6 MONTHS, see announcement yesterday). As I tweeted yesterday, the payment industry is seldomly driven by logic, and much more by politics. Given many of my friends (you) make investments in this industry, and EVERY BUSINESS conducts commerce and payments, movements here have very broad implications. The objective of this blog is to give insight into these moves so we can all make best use of our time (and money). I was flattered at Money 2020 when a number of you came up and told me that this blog was the best “inside baseball” view on payments. Perhaps the only thing that makes our Starpoint Team unique is that we have a view on payments from multiple perspectives: Bank, Network, Merchant, Online, Wallet, MSB, Processor, … etc.

It’s hard to believe I’ve already written 12 blogs on tokens… more than one per month in last year. As I outlined in December there are (at least) 10 different token initiatives (see blog).  Why all the energy around tokens? Perhaps my first blog on Tokens answered this best… a battle for the Consumer Directory. It is the battle to place a number in the phone/cloud that ties a customer to content and services (and Cards). The DIRECTORY is the Key service of ANY network strategy (see Network Strategy and Openness). For example, with TCH Tokens Banks were hoping to circumvent V/MA… (see blog). The problem with this Bank led scheme (see blog): NO VALUE to consumer, wallet provider or merchant. It was all about bank control.  The optimal TCH test dummy was almost certainly Google, and the “benefit pitched” was that Regulators were going to MANDATE tokens, so come on board now and you can be the first.Token schemes

Obviously this did NOT happen (perhaps because of my token blog – LOL), but the prospect of a regulatory push was the reason for my energy in responding to the Feds call for comments on payments. In addition to the failure of a regulatory push, the networks all got together to say no Tokens on my Rails (see blog). Obviously without network rail allowance, a new token scheme would have to tackle acquiring, at least for every bank but JPM/CPT (see blog).   Paul Gallant spent 3 yrs pushing this scheme uphill and had no choice but to look for greener pastures as the CEO of Verifone (Congrats Paul).

In the background of this token effort is EMV. I’m fortunate to work at the CEO level in many of the top banks and can tell you with certainty that US Banks were not in support of Visa’s EMV announcement last year. One CEO told me “Tom I found out about EMV the way you did, in a PRESS RELEASE, and I’m their [Top 5] largest issuer in the world”. Banks were, and still are, FUMING. US Banks had planned to “skip” EMV (see blog EMV impacts Mobile Payments). The networks are public companies now, and large issuers are not in control of rules (at least in ways they were before). Another point… in the US EMV IS NOT A REQUIREMENT A MANDATE OR A REGULATORY INITIATIVE. It is a change in terms between: Networks and Issuers, and Networks and Acquirers, and Acquirers and Merchants (with carrots and sticks).

In addition to all of this, there were also tracks on NFC/ISIS (which all banks have walked away from in the US), Google Wallet (See Don’t wrap me),  MCX, Durbin, and the implosion of US Retail Banking.

You can see why payment strategy is so dynamic and this area is sooooo hard to keep track of. Seemingly Obvious ideas like the COIN card, are brilliant in their simplicity and ability to deliver value in a network/regulatory muck. This MUCK is precisely why retailers are working

Payment Value

to form their own payment network (MCX), retailers and MNOs are taking roles in Retail banking, and why Amex has so much more flexibility (and potential growth).

Key Message for Today.

With respect to Tokens, HCE moves are not the end. While Networks have jumped on this wagon because of HCE’s amazing potential to increase their network CONTROL, Banks now have the opportunity to work DIRECTLY with holders of CARDS on File to tokenize INDEPENDENT of the Networks.

Example, if JPM told PayPal or Apple we will give you:

  • an x% interchange reduction
  • Treat as Card Present, and own fraud (can not certify unless acquirer)
  • Access to DATA as permissioned by consumer
  • Share fraudulent account/closed account activity with you to sync

If you:

  • Tokenize (dynamically) every one of our JPM cards on file
  • Pass authentication information
  • Collaborate on Fraud

This is MUCH stronger business case for participation than V/MA can create (Visa can not discount interchange, or give access to data).

This means that smaller banks will go into the V/MA HCE schemes and larger banks, private label cards, … will DIY Tokens, or work with SimplyTapp in direct relationship with key COF holders.

Sorry for the short blog. Hope it was useful

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.