Last week, I shared the news that JPMorgan has started charging for API access, a move that many see as a death blow to pay-by-bank and open banking in the US. While this might sound dramatic, I believe it’s a necessary reset. The truth is, the current model was never sustainable, and with the CFPB’s recent move to vacate its unlawful 1033 rule, the writing is on the wall. Open banking as we know it is dead in the US.
Continue readingTag Archives: JPM
In A World of 1000 Stablecoins? 4 Key Questions
Today’s blog will cover four topics:
- What are the differences between stablecoins?
- Why would consumers and businesses want to hold value in stablecoins?
- How will stablecoins be exchanged?
- Who is best placed to manage the exchange?
Understanding Payments Data – How it Plays Today and the Near Term Future
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I thought it was time for a payment data update. Given Paypal’s Feb 2025 investor day, JPM’s “Retail Media Network” now re-labled Media Solutions and JPM’s lawsuit against Transunion/Argus. My perspective is formed from my 8 yrs as CEO/Founder of Commerce Signals. I’ll touch on signals, intent and agentic at the end.
Top US Banks to Issue their own Stablecoin
Executive Summary
- As a former Banker running payments for 2 of the largest US banks I have a perspective on how this will play out. I may be wrong, but it is an informed perspective.
- As outlined 2 weeks ago banks in the EU are planning their own stablecoins.
- The GENIUS ACT forces stablecoin issuers to obtain bank licenses, thus this morning’s WSJ report that Bank of America, Wells Fargo and Chase are now in the mix is only logical
- As outlined in Stablecoin predictions, this will not impact cards as they retain their role in the last mile and banks protect the card model.
- As outlined in Power of Bank Networks, Payments are where the power of banking is unlocked. The major US banks are payment hubs that connect to all networks, from TCH, RTP, Swift, Card, …etc. These banks are leaders in innovation and in managing operations that consistently clear trillions of dollars PER DAY.
- The stablecoin settlement model is much simpler than an RTP network where each participating party has to register as a sender or receiver of payments. Senders must have settlement funds which restrict their ability to clear payments. In a Stablecoin model, originators only have to have valid stablecoins to transact, and can also create programmable rules around them (see Programmable Money)
- The business drivers are remittance, cross border, B2B, and the prospect of growing the global deposit base as international consumers and businesses buy stablecoins. Italy’s finance minister is quoted as saying USD stablecoin adoption (ie dollarization) represents a greater threat to the EU than Tarriffs.
- In my view this is a 3 yr effort. Banks don’t move quickly in isolation, and even more slowly in consortium. I do think that this will first move with commercial use cases and remittances, with banks as stablecoin issuers. Within retail consumer UCs, P2P and Zelle are the area that would be impacted first.
- US Banks should consider the slippery slope of Stablecoin. Once issued, their transfer can’t be restricted, and will operate without friction. Every movement of money becomes instant. This is why I don’t think we will see consumer interfaces within US bank domains in near term. Priority 1 is creating the stablecoin issuing platform and legal structure. Priority 2 is focusing on UCs like cross border and B2B.
Risk – Carving it up in Payments
Private Label.. “New” Competitive Environment?
JPM/V Scenarios… Which one is it?
MNOs giving away Billions to Banks.
Future of Retail Banking: Prepaid?
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
- 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…
- 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?
- 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
- American Express/WalMart BlueBird
- Tesco Bank
- Merchant Consumer Exchange (MCX)
- Safeway activating ACH on Club Card (Fast Forward)

- American Bankers Association – Prepaid from Banks
- Network Branded Prepaid Card Association (analysis)
- Barclays Pingit Service
- Google Wallet goes Plastic
- MNOs rule in Emerging Markets
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
- August 2012 US Federal Reserve – Consumer use of prepaid cards
- Federal Regulation of the Prepaid Card Industry – April 2010
- Chicago Fed – Checking Accounts What Do Consumers Value – 2010
- AT Kearny Retail Banking Profitability – Europe
- Network Branded Prepaid Cards Association (NBPCA)
- American Banker – Amex Prepaid Card
- Center for Financial Services Innovation
- Top Global Brands – Interbrand
- WSJ Prepaid Enters Mainstream
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.
Debit Fees – Newton’s third law in banking
2016 – This post is 4+ years old now.. I wouldn’t take it too seriously.. but good historical context
1 October 2011
First… 2 paragraphs of venting and perspective.
I was quite surprised to see BAC’s $5/mo debit card fee on the national news today. Personally, I think it is a great thing.. customers should pay for services they want to use.. sticking the merchant with the cost of debit leads to some very poor incentives. One of the biggest “innovation stifling” problems we have in the US is that consumers don’t care about prices, for things they should (payments, health care, fraud, education, … ). The cause? the direct costs are hidden. Once consumers bear direct costs for services, market forces can take hold.
This is not to say I’m a supporter for HOW the Durbin change came about.. Dodd-Frank, Wall Street Reform and Consumer Protection Act represent the most sweeping changes to financial regulations in the United States since the Great Depression. From my perspective the timing could not have been worse. Did Congress think the banks would just sit on the sidelines and patiently suffer? After being forced by regulators to act in good faith and “acquire” ailing community members like Country Wide? To suffer again as State AGs and the CPFB go after them for a few billion more (robo-signing). Retail banking is becoming a very unattractive business, particularly in the lower mass market segments. For the recovery to take hold, we need banks to be healthy… these are not a bunch of “fat cat” millionaires.. but a core component of commerce that is instrumental in managing the lifeblood of our economy.
Debit Reaction.. equal and opposite
Well the banks have reacted to the finalization of Durbin fees. As I related in my previous blog on Debt, the fee plans have been in the works for some time, and for good reason: the lower mass segments are no longer profitable. US banks are well capitalized…. with excess liquidity, and a cost of funds near zero. There is very little incentive for them to seek to increase their deposit base (improve liquidity ratio). The core issue in retail banking profitability is asset quality (few qualified people to lend to… who want a loan). This is even more true now that Dodd-Frank has virtually gutted retail banking fees. Two excellent articles below detail the role of transaction revenue and service fees in retail banking.
http://www.bai.org/bankingstrategies/payments/general/protecting-dda-profitability
http://www.novantas.com/article.php?id=317
http://www.standardandpoors.com/ratings/articles/en/us/?assetID=1245235038776
Of course not all consumers will be paying this $5/mo cost. For example, the folks reading this blog will likely have account relationships that warrant a fee exception. Mass market customers will likely be up in arms and seek to move their accounts.. believe it or not.. this is what the large banks want to happen since many of the lower tier customer segments are no longer profitable.
See this American Banker Article for more detail on alternatives to mass market customers
In the next phase of bank plans, expect the Visa logo to disappear from the standard card issued for a base checking account. The card will operate as ATM card, just as it did 20 years ago. As a side note, the banks (and PIN Debit networks such as Star, Pulse, NYCE) will be working with merchants and processors to expand adoption of PIN Debit separate from the card networks.
Market Forces in Payment
Now that consumers have to bear the costs of using a Debit Card. They have new choices:
1) Use credit card. This would be best for the banks, and perhaps best for the consumer as they collect merchant funded card reward points. The looser here is obviously the merchant. An important point to make here is that this is exactly the strategy behind new NFC based mobile payment types.. there are NO NFC enabled debit cards.. banks and the networks want you using your phone for payment to drive credit card usage. This is also the strategy behind Visa’s new EMV mandate, to drive retailer reterminalization. This will be a subject of a future blog.
2) Leave the bank and use pre-paid cards. This will certainly be the path for many lower mass customers
3) Pay the fee
4) Improve your relationship with the bank to meet a threshold and avoid the $60/yr fee.
5) Shift your transactional relationship to new “non bank” structures like PayPal or Google Wallet (both of which are licensed MSBs in all 47 states).
Downside for banks
CEOs make decisions based on data they have. The first 4 options have all been through. I would profer that creating a market for new competitors has not. I outlined in my previous blog “Banks will WIN in payments.. but WHICH ones” that banks are firmly in the position of control today. However there is a strong correlation between control and value delivered. In my upcoming blog I’ll describe how to value a payment network. My view is that payments are on a course of a utility service (i.e. dumb pipes with least cost routing), and that payment services are only the last step of a much more important commerce interaction. Any network business is highly dependent on balancing a value proposition between participants. Today retailers and consumers are not pleased. I only wish I could tell of you the wonderful things I’m seeing in Silicon Valley… IT IS NOT about technology.. but about creating business value.
Within 5 years, I see the strong possibility that a new network which will be able to PAY merchants for accepting a payment method.. (see my 2009 Blog on Googlization of Payments).
BTW… sorry for the lack of content this last month.. I have 15 page blog I’m about to publish.. I will never again try to write so much in one article.




