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9/28/2017 The Changing World of Payments 2
• Why regulate? – what is the point of regulation?
• Typically Regulation is forensic
• Can regulation be proactive?
• Can regulatory structures be fast-tracked?
Story Board
9/28/2017 The Changing World of Payments 33
I only have 5 min left and 42
slides to go…
Am I
excited?
I’m still hungry
Not in my
budgetThat will
never work
with our
banks
Typical Discussion on Regulatory Issues
9/28/2017 The Changing World of Payments 4
July 2016: “Trying to regulate the financial system is like trying to predict and control the global weather system.”
Economic Storms
Regulation is easy in rough times (bail out the water),
Hard in good times (its hard to sell buckets in smooth seas).
9/28/2017 The Changing World of Payments 6
Classical and Neo-Classical economists,
believe that an economy moves
naturally towards maximum economic
welfare and full employment when its
markets were allowed to operate freely.
Why Regulate?
Adam Smith
Jean-Baptiste Say
David Ricardo
John Stuart Mill
Thomas Robert Malthus
9/28/2017 The Changing World of Payments
John Maynard Keynes response to the Great Depression clearly showed that a macro-
economy would not always automatically or quickly self-correct.
The contrast between the Classical and Keynesian perspective is often expressed in
terms of the extent to which Adam Smith’s invisible hand works, or fails, to maximise
economic welfare.
Why Regulate?
not an evidence-
based model
9/28/2017 The Changing World of Payments 8
Those on the Classical side of the argument believes
the invisible hand works , while those on the Keynesian
side generally believe it does not, and that full
employment equilibrium is a special, rather than a
general case.
This Creates the Regulator’s Dilemma
How much regulation is needed and at what time?
9/28/2017 The Changing World of Payments
Permanent Income Theory: Consumption of the individual (or
household) depends on his (or its) permanent income. Permanent
income may be thought of as the income an individual expects to
derive from his work and holdings of wealth during his lifetime.
The ”Chicago School”Adds a new Facet to the Regulators Dilemma
Rational Expectations Theory: individuals take into account their
best guesses about the future when they make decisions.
Chicago: individuals are relatively deliberate and sophisticated in
how they make economic choices.
Keynes: individuals are short-sighted and simple-minded.
9/28/2017 The Changing World of Payments
Key Drivers in the connected economy
Non-FS PlayersTechnology giants, telcos,
NGOs
TechnologyTechnology is the key
enabler of the Internet and
fintech
ConsumerGrowing middle class and
millennial adoption
RegulationConducive regulatory
environment
AdoptionIncreasing adoption of
various forms of payment
modes
Mobile Penetration Exponentially increasing
mobile and smartphone
penetration
9/28/2017 The Changing World of Payments 11
The fundamental challenge facing policymakers is that the
costs and benefits of regulation are not shared equally across
all parts of society.
9/28/2017 The Changing World of Payments 12
Source: How to Run a Country: the burden of regulation by Richard Harries and Katy Sawyer, 2014
Regulatory Impacts
Regulatory Costs Regulatory Benefits
Direct Costs
Direct Compliance Costs
• Charges• Administrative Burden• Compliance Costs
Hassle Costs
• Corruption• Annoyance• Waiting time
Enforcement Costs
Monitoring Adjudication
Enforcement
Direct Benefits
Indirect Costs
Indirect Compliance CostsOther Indirect Costs
Substitution Efforts
Transaction Costs
Reduced• Efficiency• Competition• innovation
Wider Range of products/services
Monitoring
Health Safety
Environment
Indirect Benefits
Wider Macroeconomic
benefits
Other, non monetizable benefits
Indirect compliance
benefits
Ultimate Impacts
Well-beingHappiness
Life satisfactionEnvironmental
qualityGDP GrowthEmployment
Market Efficiency
Improved Information
Cost Savings
9/28/2017 The Changing World of Payments
What is the right balance for Payments Regulation?
Savers
Spenders
Bank’s Value Proposition
Bank’s Business Model
9/28/2017 The Changing World of Payments
The Historical Value Proposition for Banking
Value
Proposition
Shareholders
Safety
Interest Rates
Integrity
Return on Investment
Customers
9/28/2017 The Changing World of Payments
21st Century Bank’s Value Proposition
Value
Proposition
Customers
Shareholders
Convenience
Level of
customer intimacy
Ease of use
Cost
Security
Fidelity
Corporate
values
Telephone banking
ProfitabilityGrowthCommunity standing
Treated like an account
Feel like an individual not a number
Customisation andpersonalisation of servicesLow cost High Quality
Branch(Access)
ATM(1st generation)
Expanded Hours
ATM(2nd generation)
Remote locationsExtended
reach
Internet(With linkedServices)Extendedbreath ofServices
Branch ofthe future(Advisory)Extendsdepth ofService
Physically safe Deposits insured
Accuracy of information Discretion Secrecy
Morals Ethics CommunityNationalism(keeping the profits in the country)
9/28/2017 The Changing World of Payments
Emerging 20th Century Bank’s Value Proposition
convenience
(availability/time
)
Value
Proposition
perceived value
(standardization/
customization)
value for money
(price/cost)+ +=
Short-term goal: increase shareholder value
Long-term strategy: demonstrate value to customers
9/28/2017 The Changing World of Payments
Just as Banks have Value Propositions so do Regulatory Frameworks?
Regulatory
Value
Proposition
Improve Financial System Efficiency
Protect Consumers/Investors
Facilitate growth
Balance risk in society
Provide the framework for a stronger and more productive economy
Protect the vulnerable from harm
Uphold the rights of consumers
Promote a level playing field for businesses
Spur Competition
Safeguarding the stability of the financial system
9/28/2017 The Changing World of Payments
Regulate the Business Models
1. Operator CentricOperator acts as the acquirer, payment network and
issuers
2. Bank CentricFinancial institutions own payment systems; cards
payments
3. CollaborativeCollaboration between banks and operators
4. Peer to Peer3rd party company that links customers, merchants
and bankers.
9/28/2017 The Changing World of Payments 20
Retail Payments Value Chain
Web Hosting & Shopping Carts Value Added Services Gateways
• Expand sales of eCommerce
solutions by developing additional
plugins to major carts & VARs
• Develop new referral partnerships
• Incentivize acquired merchants to
sign-up for merchant services
• Enhanced gateway functionality and achieve market parity pricing
• Partner with or acquire unique functionality and customer sets
Expand into new merchant segments by integrating new features:
• Advanced Fraud Screening• Alternative Payments• Recurring Billing w/Profile Mgt.• B2C eCommerce Module• eCommerce in-a-box
Customer InternetPaymentGateway Acquirer
Issuer
eCommerceEco System
Merchant Website & Shopping Cart
Value Add Services (ex. Fraud)
Adaptive Strategic Thinking to Policy MakingCard Payments Value Chain
9/28/2017 The Changing World of Payments 21
Pure Acquiring
Transaction
capture
mechanism /
payment
gateways,
provided by
merchant
acquirers or
third parties
Card Issuer
Card HolderMerchant
Merchant Acquirer
In-house
gateway
services
Third
party
gateway
Gateway
ISV/VAR
Card
Scheme
Adaptive Strategic Thinking to Policy Making
9/28/2017 The Changing World of Payments 22
Safeguard stability of financial system 20-40%
Facilitate Growth 60-80%
Attact new businesses 20-40%
Encourage existing players to spin-off business 60-80%
Facilitate Incubators to create new market entrants 70-90%
Establish national payment switch or central hub 10-30%
Develop mechanisms for self regulation or for arms-length monitoring 50-70%
Develop fast-tract experiencial policy making 50-70%
expand financial system capacity 5-25%
Provide frameworks to improve market effeciency 20-40%
Establish buffers to absorb systemic shocks 5-25%
Protect vulnerable from harm 20-30%
Reduce Market Cost
Reduce Selling Cost
Reduce Servicing Cost
Reduce Credit Risk Cost
Balance the Risk in Society 60-80 %
Facilitate Compliance 20-40%
Provide centralized infrastructure 45-65%
Spur Competition 5-25%
Decreasecosts 10-30%
Grow the Economy 70-90%
Protect consumers and investors 10-20%
Regulatory Intent
Provide Level Playing Field 20-40%
Tactical Agenda
Strategic Agenda
Business Models and Technology Priorities are Evolving
9/28/2017 The Changing World of Payments 23
ATM
ATMInternetPhone
Phone
2012 2015
Internet
Mobile
Branch
InternetMobile
High
High
Low
Low SALES TRANSACTIONS
SER
VIC
E TR
AN
SAC
TIO
NS
9/28/2017 The Changing World of Payments 24
Regulatory Challenge: Technology is Changing the Rules
From domestic supplier to
international distributor in 3
days, with no banks involved.
Xiamen City, Fujian Province, CHINA
Cambridge, UK
9/28/2017 The Changing World of Payments 25
$99 13.56MHz ISO14443A & NFC Type 2 NTAG216 RFID
chipset
A Regulatory Dilema:
Payment Chip in His Arm
Regulations Impact Commerce in Ways That We Might Not Expect
9/28/2017 The Changing World of Payments 27
Margins in retail are notoriously
small. Best Buy has a profit margin of
~3% as does Wal-Mart. So having a
10% price advantage means that
Amazon could have had lower
prices (including tax) and still have a
higher profit.
In the beginning, Amazon.com didn’t need to collect
sales tax because of a gap in interstate regulation.
Regulations Impact Commerce in Ways That We Might Not Expect
9/28/2017 The Changing World of Payments 28
Uber disrupted a highly regulated market and again, undercut on price.
• In 2009 a license to operating a taxi in Chicago was $150k-$200k.
• Regulators set limits on how many cabs could operate and prices
charged.
• This meant that there was money to be made in driving a cab which
drove up the value of medallions.
• Uber enters and skips that whole business and just offers rides for a
fee. Bypassing regulatory costs prices could be lower.
Regulations Impact Commerce in Ways That We Might Not Expect
9/28/2017 The Changing World of Payments 29
Uber’s business model has been challenged by regulators and
adapted to comply in local markets.
Fast Track:a system of light touch scrutiny for deregulatory and low-cost regulatory measures.
9/28/2017 The Changing World of Payments 32
A fast track system is intended to :-
• Speed up the implementation
• Strengthen proportionality and reduce the burdens on
Departments by focusing appraisal and scrutiny on
regulatory measures with the most significant impacts
• Promote self regulation
• Collaboration based to adjust as conditions change
Challenges for Payments Regulation Today
9/28/2017 The Changing World of Payments 33
Constant changes in technology, society and
demographics is rapidly altering the financial
markets, which requires more complex
monitoring.
An increasing number of policy and regulatory
stakeholders are focusing in payments creating new
levels of uncertainty.
The rate and pace of change is
compromising the effectiveness of existing
legislation and regulatory structures.
Currently, the view of regulators is to encourage innovation in fintech by restrained supervision, this is the ethos of the ‘Sandbox’ similar to technology incubators
9/28/2017 The Changing World of Payments 34
Some countries view a Sandbox as a non-intervention environment until the
initiative has scale and other view it as ongoing light monitoring.
Regulators help innovation when they:
• act pragmatically in the application of
rules (to remove the dogma of
compliance),
• observe/ monitor closely the innovators
through Sandboxes
• have a thorough understanding of the
areas through running Sandboxes
• are able to act decisively to level the
playing field or pass an Act to allow the
equivalent infrastructure to be built.
Attributes Regulators are considering:
• Payment services often are the entry point into
using formal financial services
• Poor regulation is one of the major obstacles to
financial inclusion.
• Lack of good infrastructure slows implementation
• Weak institutions and poor cooperation restricts
capacity
• Unstable economic and political conditions reduce
innovation and adoption.
9/28/2017 The Changing World of Payments 35
28.9.2017 г. The Changing World of Payments 35
Policy
Risk
Strategy
Threats
Vulnerabilities
Impact
Probable
Improbable
Possible
Hi
Lo
Hi
Lo
Sense of
Proportion
Deterrence
Detection
Timing
Response
Policy
Tactical
Plan
Policy Mitigation Philosophies: Reactive Versus Proactive
Policy Mitigation Philosophies:Reactive Versus Proactive
9/28/2017 The Changing World of Payments 36
Interoperability as a market solution
In Tanzania, interoperability in the mobile-payments market
emerged as a market solution through an industry-wide
process facilitated by the International Finance Corporation
(IFC) who acted as an impartial broker between participants.
The regulator’s stated preference was for the market to reach
interoperability on its own.
Airtel, Tigo, and Zantel became interoperable on September
2014. Vodacom joined in early 2016.
Policy Philosophies: Reactive Versus Proactive
9/28/2017 The Changing World of Payments 37
Partial interoperability through ex-post regulation
In Kenya, business incentives created by an ex post regulatory
approach led to partial interoperability.
M-Pesa operated on a trial basis for 7 years which lead to the
National Payments Systems Act.
Safaricom’s M-Pesa, the leading mobile money service, lacks full
interoperability with services offered by other operators.
Kenyan authorities were concerned about the high-level of agent
exclusivity (before July 2014, 96 percent of agents were serving one
provider exclusively).
In July 2014, Safaricom opened up its M-Pesa network of 85,000
agents to competitors just before the Competition Authority of
Kenya ordered it to do so.
9/28/2017 The Changing World of Payments 38
Adaptive Strategic Thinking to Policy Making
Evidence-based
policymaking
requires careful
analysis of the
available data.
What statements
can we confidently
make?
To what extent can
we extrapolate
data for policy
development,
analysis and
delivery
evaluation?
Data
an
d In
form
ati
on
So
urc
es
Preservationist
(Develop policy
to grow
domestic
payments)
Internationalist
(adopt global
standards,
liberalize markets
to foreign
competition)
Protectionist
(change policy
to preserve the
status quo)
Reformist
(centralize
infrastructure to
strive for
efficiency)
Technology Innovation
Infrastructure Stagnation
Hig
h R
eg
ula
tio
n
Lo
w R
eg
ula
tion
Scenario Based Policy Making
Storyboard
Global Trends
• Political, economic and financial
Regional Trends
• Social, demographic and traditional
• How do they apply to the local markets
9/28/2017 The Changing World of Payments 2
Global trends that Regulators should have seen on their radar
9/28/2017 The Changing World of Payments 3
Emerging Markets
Consumer and Demographics
Developments in Competitors
Technology Advances
Macroeconomic Directions
9/28/2017 The Changing World of Payments 4
CHANGE IN WORLD ECONOMIC ORDERHas the Americanization of the World Ended?
CHANGES IN ECONOMIC ACTIVITYWill emerging economies surpass service economies?
CHANGES IN NATIONAL POLICIES AND REGULATIONIs free market capitalism an answer or a question?
CHANGES IN AGGREGATE CONSUMER BEHAVIORWill global consumerism initiate a
global battle for natural resources?
Macr
oeco
no
mic
Direct
ions
9/28/2017 The Changing World of Payments 5
GDP Per Capita vs Median Age 80000
70000
60000
50000
40000
30000
20000
10000
0
Australia
Germany
Canada
Japan
USA
FranceUK
ItalySpain
S Korea
Russia
China
Saudi Arabia
Mexico
Brazil
Argentina
Turkey
Indonesia
S Africa
India
Bubble size = country GDP value relative to USA
GDP Per Capita $ 2015
15 20 25 30 35 40 45 50Median Age in Years
POOR BUT YOUNG
RICH BUT OLD
POOR AND AGEING
Singapore
Malaysia
Thailand
Macr
oeco
no
mic
Direct
ions
Source: IeC analysis, IMF, CIA Factbook 2014
9/28/2017 The Changing World of Payments 6
• In 148 economies only 50% of adults have a bank account
• 35% of the world’s adults have barriers to establishing a bank account
• 85% of world retail payments are cash in 2015
• 4 to 8% of the world’s money supply is coins and notes
Macr
oeco
no
mic
Direct
ions
Source: Demirguc-Kunt and Klapper 2014
9/28/2017 The Changing World of Payments 8
Interpreting Trends:Gauging Economic Growth
Tower Cranes TrafficTourism
Em
erg
ing
Mark
ets
9/28/2017 The Changing World of Payments 9
Interpreting Trends:Gauging Economic Growth
Em
erg
ing
Mark
ets
Many Choices
Checkers
Eco Marche
Leader Price
Lulu Hypermarket
Metro
Park 'n' Shop
Pick n Pay
Shoprite
Spar
Woolworths
Fewer Choices
Is my life getting
better using this
bank?
Commissions, charges
and fees how is this
making me wealthy?
I don’t understand, I deposit
my money so they can lend it
out to other people to make
a profit. They pay me very
little interest and I have to
pay fee for this privilege?
The New Customer Centric KPI’s
9/28/2017 The Changing World of Payments 10
Co
nsu
mer
and
Dem
og
rap
hic
s
9/28/2017 The Changing World of Payments 12
China:Chongqing Paints Street Lane for Mobile Phone Users
Co
nsu
mer
and
Dem
og
rap
hic
s
Source: Barcroft Media 2014
9/28/2017 The Changing World of Payments 13
Millennials
Co
nsu
mer
and
Dem
og
rap
hic
s
Source: Commonwealth Bank,
2016
9/28/2017 The Changing World of Payments 14
Facebook, London, August 1935
Co
nsu
mer
and
Dem
og
rap
hic
s
Source: Modern Mechanix, 1935
9/28/2017 The Changing World of Payments 15
New Financial Behaviours
Co
nsu
mer
and
Dem
og
rap
hic
s
Source: Maybank, 2016
9/28/2017 The Changing World of Payments 16
Five General Observations• Regulators have been late to react to social economic
changes and innovations in banking
• Customers in many markets demand more services and
are becoming fee conscience
• The higher your social/economic standing the less cash
you carry in proportion to your wealth
• The less money you have, the more debt you
accumulate
• An increasing number of factors that determine a bank’s
performance are beyond the bank’s direct control
Co
nsu
mer
and
Dem
og
rap
hic
s
21st Century Financial Services
9/28/2017 The Changing World of Payments 17
Top 10 Cross Border Payment Systems in Asia
Deve
lop
ments
in C
om
petito
rs
Source: trulioo.com, 2016
9/28/2017 The Changing World of Payments 18
Deve
lop
ments
in C
om
petito
rs
Source: Skrill.com, 2016
9/28/2017 The Changing World of Payments 19
Deve
lop
ments
in C
om
petito
rsIn most of Africa it has not been
financially viable for banks to
offer last-mile services.
African Fintech is not disrupting anything
Source: World Bank, 2011
9/28/2017 The Changing World of Payments 21
Deve
lop
ments
in C
om
petito
rs
Source: Digital money forum, 2015