Keeping Up With Chaos: A Payments Stakeholder Reality Check

Short Blog – Bullets

It’s getting harder to keep up with payments, a subsector that has not been great for payment investors, between the Saaspocalypse, AI, agentic commerce, stablecoins, the Genius Act, open bank charters, and COF buying Brex, we are deep into “what just happened?” era. While I see tremendous opportunities, not everyone is impacted the same (see 2025: The Great Decoupling).

You don’t read this blog for deep tech insight; you read it to understand where change is actually happening and where the money, risk, and power are moving. Today is a short recap of which stakeholders face the biggest near-term impact, where progress is being made and where investment is flowing.

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CCCA: 5% chance that 5% of Network EBIT could be affected (in 2+ years)

Update to my 2023 blog on CCCA Complex Politics and Consequences. I’ve spent the last few weeks digging into the latest bill and I see an overstatement of potential impact that most analysts seem to have missed:

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UCP Enables a New Economy

Yesterday, Google’s CEO unveiled Universal Commerce Protocol (UCP) at NRF.  UCP represents a defining moment in the architecture of digital commerce; the strategic imperative is no longer merely about organizing the world’s information but about organizing the world’s commercial intent and empowering merchants to leverage their own data to construct superior customer experiences.  This shift is not incremental; it is a fundamental re-platforming of the digital economy, where Google is uniquely positioned to serve as the orchestrator within a “virtuous cycle” of interaction among retailers, consumers, and intelligent agents. 

“For many people, discovery is the fun part of shopping. Making a decision is where things get harder. As an indecisive shopper myself, I’m looking forward to the day when agents can help me get from discovery to purchase.

At Google, we’re busy laying the groundwork for this agentic ecosystem to work well. That includes building a common language for these systems and services to talk to each other.

As a next step we are introducing the Universal Commerce Protocol (UCP), designed for the era of agentic commerce. It was built to meet the needs of retailers AND customers, keeping the full customer relationship front and center — from the moments of discovery to decision and beyond”. – Sundar Pichai NRF – Jan 11 2026

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AP2 as Merchant Signals – 4 Scenarios 

Today I’m outlining three near-term scenarios (24 months) for how AP2 signals will work in agentic commerce. Per my blog last week, AP2 is the agentic payment scheme with the most momentum (160+ partners), but in the immediate term (2026–2027), it will operate primarily in a “signals” metaphor for 3 main reasons:

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Discount “On Chain”. Value Exchange and Commercial Frameworks Will Define Success

Case studies in Agentic and JPM Kinexys

Key Themes

  1. Value exchange requires a commercial construct such as a contract, marketplace agreement or commercial network.
  2. Tech is enabling fragmentation both within an organization and across domains with finer-grained access to services (ex APIs), faster settlement (ex blockchain), immutable digital representations of physical world goods (ex NFT), digital trust and assertions (ex W3C Verifiable Credentials), …etc.
  3. While the tech is progressing at light speed, the real battle surrounds the structures, incentives and politics for how value is exchanged, and risk is assumed. 
  4. This atomization of products, services and organizations has created new opportunities for value orchestrators. For example, what if the battle for AI and Agentic Commerce is not about LLMs efficacy, but about enabling consumers to choose the best agent and permission it from their phone (ex Apple). 
  5. Free and Open are great tech models, but terrible business ones (ex Open Banking). Fragmented voluntary Agreements in Web3 and Agentic Commerce spaces struggle to scale due to high transaction costs associated with establishing bilateral trust.
  6. We are in a flux period where incumbent marketplaces and networks will dominate.  For example, there is little prospect for OpenAI to disrupt Google across 7B+ Devices, 3B+ consumer accounts, GC, Advertising, Analytics, Consumer/Enterprise Services. While the buzz of “on chain” finance is loud, application of DLT in closed private blockchains is driving the majority of growth by bringing new efficiencies to established businesses (JPM Kinexys). 
  7. While alternative “federated” and decentralized models are possible, their core challenges surround economics and governance. Who owns the end-end risk?  Who manages bad actors or system flaws? Where is the commercial agreement that assigns risk? 
  8. The next 10 yrs will NOT be a uniform movement toward one single future, but a fragmentation of how value exchange happens. For example, how identity is handled in Agentic commerce will depend on WHO owns the risk for the transaction (merchant, bank, PSP, Platform, Consumer)?  
  9. At the consumer end, I see mobile platforms acting as the controller/orchestrator for trusted interaction across healthcare, retail, government, agentic … etc. I wouldn’t count Apple “out” of the AI race as they may assume the consumer interface role for “everything”.
  10. Kinexsys Case Study – Closed network, strong governance, massive scale. 

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V/MA Settlement – Tiered Acceptance

Quick Take on WSJ – V/MA Near Deal w/ Merchants

Merchants have long expressed frustration over card costs, but it’s critical to separate signal from noise. Their issue isn’t with network fees—those average just 5 to 7 basis points and fund the global infrastructure that securely moves trillions. The real pressure point is interchange, often 250 basis points or more for premium rewards cards. That imbalance has shaped years of litigation, and now a potential reset is emerging.

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The Shakeup PayPal Needs

Rumors are that a substantial organizational change at PayPal is in progress. Frankly, it’s overdue. For any global payments company to succeed, its leaders must possess a deep, almost intuitive, understanding of the global payments ecosystem. This is where PayPal is currently failing.

We have a CEO, Alex Chriss, known as a product specialist. While he may be excellent at getting products out the door, this is not the problem PayPal faces. Unfortunately, the team can’t see the forest fire given their conspicuously poor payment background. For example, look at Diego Scotti as EVP and GM of the consumer group. His experience comes from Verizon, and his chief credential is that he is the husband of Janey Whiteside, one of Alex’s closest payment advisors. When growth doesn’t happen and targets get missed, investors begin to look for the reasons and the resumes of those running the ship.

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Message to Bank CEOs as Stablecoins Take Hold

Bank Payment Strategy in the World of Agentic and Stablecoin

Stripe’s recent moves are massive and will solve stablecoin acceptance (globally). When (and if) a consumer champion goes all in on stablecoin we will see change in payment innovation akin to the “age of enlightenment”.  What are banks to do?


Cards are the most profitable banking product in the history of retail banking, and the power of banking is unlocked within the networks that link them (blog). While the power of banking is unlocked in networks, network innovation is like herding cats as each stakeholder works to protect their existing investments and competitive advantage (see Network Innovation).

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MRC Learnings – September 2023

Merchant Learnings

This week I was invited to speak at the Merchant Risk Council’s (MRC) – Santa Clara event. As a former banker, I never gave much throught to retailers. Fraud was something I worked to manage with Account Opening/KYC as a core focus because of the potential for regulatory hot water and NCLs as #2 because it drove reserves, profitability and investor scrutiny. Card transaction fraud was something we worked to keep under a threshold. 

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Merchants Tokenize – eCom Wallet Challenges

UPDATE – Nov 29 2022 – Note that I have conflated the relationship between SRC and 3DS 2.0. 3DS 2.0 is the authentication protocol used by SRC. 3DS 2.0 has been widely adopted as a mandatory replacement to 3DS 1.0. Part of the driver for adoption was the EU SCA mandate. SRC has NOT been widely adopted as it is a fairly broken consumer experience at the moment. 

I’m at M2020 today and it has been a “back to normal” fantastic event. Let me put my “merchant hat” on for a story from their perspective.

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