Paypal A Smart Step: Putting Innovation At The Heart Of Payments Regulation
PAYPALA SMART STEP:PUTTINGINNOVATIONAT THE HEARTOF PAYMENTSREGULATION
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2PayPal A Smart StepINTRODUCTIONA four-part paper:1. Context2. Problem3. Solution4. ActionsWe are pleased that you want to read this paper and hope that you find it both insightful andstimulating. Join us in our vision to deliver a safer, easier and more rewarding payments experienceto the market supported by better regulation.Focused on the payments arena, this four-part document explains the transformation that is takingplace in the industry, sets out why we think the approach to regulation can similarly innovate andtransform, offers concrete ideas about how this could be done and ends with a case study and callto action.SynopsisPart 1 sets the scene andprovides the contextPart 1 explains how the business of payments is being transformed across six key areas of thepayments landscape. This transformation is challenging the existing regulatory approach and offerssignificant potential for more effective and more efficient regulation.Part 2 describes effective andefficient regulation and whywe think there is a problemPart 2 sets out the ‘timeless’ goals and key objectives of payments regulation; goals that we believeare shared by all stakeholders. It then uses the attributes and principles underlying these goals tohighlight where we think that the existing process is falling short.Part 3 shares ideas to unlock thepotential for better regulationPart 3 shares our ideas for improving the current regulatory process by gathering market data andapplying modern technology and analytics tools. It also advocates a new model for developingregulation - SMART Governance - so that the regulatory process can benefit from the same cuttingedge practices that are revolutionizing today’s industry.Part 4 provides a case study,draws conclusions and makesrecommendationsPart 4 applies our ideas to a key payment attribute, identity, showing how they can be employedto improve the effectiveness and efficiency of Know Your Customer regulation before making fourconcrete recommendations for putting them into action.eBay EU Liaison OfficeAvenue des Arts 441040 BrusselsBelgium
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4PayPal A Smart StepEXECUTIVE SUMMARYThe overarching policy goals behind payments regulation remain relevant . However, rapid changesin consumer behaviour, technology and merchant need are transforming the payments industry. Atthe same time geopolitical instability and a greater sophistication in financial crime are also radicallychanging the payments industry threat profile.PayPal believes that the overarching regulatory goals are widely shared; no-one questions the need tocombat money laundering and fraud. Where there is less consensus and more debate is about howthe existing regulatory process can be enhanced to bring these goals about.The key challenge is to define and operate regulation to achieve these goals in the most effective,most economic and most efficient way possible. The issue is not so much about the “what” butmore about the “how”. Developments in technology and data analytics provide new opportunities toimprove the regulatory process.PayPal advocates the use of a new decision-making model – SMART Governance – to better deliverthese goals in a manner that benefits government, consumers, and industry.SMART Governance uses technology and data to better inform and validate the regulatorydevelopment process. PayPal believes that this will get better regulation into the market with betterresults than is the case today.The SMART Governance model applies complex systems thinking and the classic ‘Boyd Loop’ forstructured analysis and problem solving, as conceptualised for regulation by Mark Fell in the paper“Smarter Intervention in Complex Systems” (2013) to payments regulation.Fell’s “Smarter Intervention” presents a framework that allows policy makers to adopt an approachto problem solving akin to that employed by nearly all modern companies, not merely those in thetechnology sector.The framework of Securing data, using Machines to organised databases, creating Algorithms toderive insights, Reassessing results, and Targeting insights is making industry more efficient acrossthe board; it will do the same for the regulatory process.This approach respects the role of regulators and supplements it with cutting edge thinking by: Proactively identifying the most appropriate actors to collaborate with on an issue-by-issue basis; Understanding the opportunities to delivery policy goals in the new business models andoperating models; Being more results and outcomes focused; and Using technology and results-based data from regulated entities.Technology and data make up the engine of this new model, but collaboration, innovation andexperimentation are the key to unlocking insights from the data; it is the application of these insightsthat will result in better regulation.The Know Your Customer regime serves as an example. SMART Governance encourages the useof data analytics to scrutinise the traditional data elements (i.e. name and address) and the traditionalmethodology by which those pieces of data are collected (i.e. presenting picture ID).To encourage a shift towards an agile, more collaborative and insightful regulatory process, this paperconcludes with a series of specific recommendations to apply the SMART Governance model toforthcoming regulatory proposals:1. Reinforce the role of the Payment Systems Market Expert Group to apply SMARTGovernance to Payments2. Employ Simplified, Efficient and Effective Due Diligence Requirements3. Recognise That New Technologies Create Opportunities and not Only Risks4. Expand and Generalise the Use of a Risk-Based Approach
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6PayPal A Smart StepCONTENTSPART I:CONTEXT. THE PAYMENTS LANDSCAPEPayments are Really ImportantThe Payments Landscape – Past and Present779PART 2:PROBLEM. PAYMENTS REGULATION TODAY14PART 3:SOLUTION. A SMART NEW MODEL18PART 4:ACTION. PUTTING SMART INTO PRACTICE26CONCLUSION32Timeless Goals Behind Payments RegulationThe Payments Regulatory Model is Falling ShortTechnology and Data Underpin Problem SolvingA Better Framework is NeededThe SMART Governance CycleCase Study – Know Your CustomerPutting Smarter Payments Regulation into practice15161919222729
7PayPal A Smart StepPART I:CONTEXT. THE PAYMENTS LANDSCAPEFour factors are acting onthe payment industry todrive innovationOver the last 30 years, the payments industry has been in a process of intensified transformation.Four factors have been driving this transformation:1234Retail customer needs, expectations and behavioursTechnology opportunity and development;Economic and environmental developments; andPolicy intervention and regulatory action.SECTIONSA.B.C.D.Payments are Really importantPayment AttributesPayments RiskPayments Landscape – Past and PresentA. PAYMENTS ARE REALLY IMPORTANTPayments are critical toeconomic and societal wellbeing, which is why they areregulatedAccess to payments, especiallyonline, is particularly importantto achieve economic, societaland financial inclusionThe Quantity Theory of Money shows the relationship that the payments business has to theeconomic output of an economy.Without payments, markets would cease to function, production would halt and government wouldbe unable to operate. If individuals have limited access to payments then they are constrained fromeffectively participating in society. Payments serve a variety of important purposes:– From a retail perspective, payments allow people to share their wealth with others, to consumegoods and services and to store wealth for a rainy day.– From a corporate perspective, payments allow companies to purchase goods and servicesfrom suppliers, to recompense providers of capital and labour and to convert their propositionsand products into cash.– From a government perspective, payments allow taxes to be collected, benefits to be paid andfor governments services to be paid for.– From an investor perspective, payments allow investments to be made, returns to be receivedand capital to be exchanged.Reducing the time taken tooriginate, process, clear andsettle a payment is key todriving up liquidity andeconomic growthThe irony is that despite their importance, the majority of payments have little utility. “No-one getsup to make a payment1” is a common phrase in the payments industry. This is evidenced in surveyafter survey, where consumers place a high premium on the simplicity and ease of use by which apayment can be transacted.Increasing payments efficiencyand avoiding regulatory frictionis therefore really important.There are other factors that will motivate someone to use one payment instrument over anotherincluding price incentives, reward incentives and security incentives.In short, the less friction in the payment process and the faster cash can be made to flow though asupply chain, the greater the opportunity for economic growth and for economic well-being.The Quantity Theory of MoneyMV PYThe stock of money (M) multiplied by the number of times that it is transacted/used (V), is equal to theamount of economic output (Y) multiplied by the price level (P).This basic model conveys the core relationship of payments to the real economy. Making paymentsmore efficient (V) and creating new forms of money (M) should contribute to increased economicgrowth.1Anon
8PayPal A Smart StepB. PAYMENT ATTRIBUTESPayments involve a transfer ofvalue between two partiesThe concept of a payment has been in existence since c9000BC2 and was created to solve acritical economic problem – the transfer of value (transient or stored) from one person to another.The application of technologyhas generated substantial newvalue potential in paymentsbecause of the:The form of a payment, the instrument by which it is initiated and the process by which it iscompleted has changed significantly over time, but it has always involved a consistent set ofpayment and trust attributes, Figure 1. Common Attributes.– data involved;– the relationships betweenthat data;– the ability to analyse thatdata in milliseconds; and– the ability to unbundle andbundle it.The payment context has also changed and become much more sophisticated; physical attributeshave given way to abstractions, relationships between form and attribute have become lessdependent and technology developments have put much more information into the payment process.Figure 1. Common AttributesPayment Attributes–––––An instrument to initiate itA mechanism to accept itA process to undertake itA currency that is acceptedA clear amount and valuationTrust Attributes––––––Recognised mark of authorityKnown identitiesUndertaken for good reasonPrior experienceThird party attestationProper authorisationC. PAYMENT RISKTypical payments risktaxonomies include:–––––Market riskCredit riskOperational riskLegal riskReputational riskIdentity and authorizationare key risks withinOperational RiskA persistent feature in any payment transaction is the concept of payment risk.Although many different taxonomies exist to describe payment risk, all of them consistently includeoperational risk and reputational risk and within them specific risks such as:1.2.3.4.Identity impersonation;Instrument counterfeiting;Money laundering; andTerrorist financing.A key control in each of the examples above is the requirement that the parties undertaking atransaction are who they say they are and that they are acting within their powers. Where theyare acting in the role of agent, the underlying parties must also be known. It also requires that thetransaction being undertaken is an acceptable transaction.These risks have required a public policy response and regulatory intervention to reduce the level ofthreat, to prevent risk from being accepted into the system, to detect it when it has been acceptedand to minimise the impact on other system participants.Simply replicating a physicalworld control in an onlinecontext may be ineffectiveor inefficientCare is required to understand how risk is changed in a different context and to assess the newopportunities for control. The key mistake is simply to replicate a physical world control since thismay either not manage risk in the same way or to the same extent, it may also introduce inefficiency.Where a payment mechanism is confined to a single organisation, these issues have relatively lessimportance, but where it is provided to the wider market then depending on adoption, volume andvalues transacted they can become much more systemically important and transmit risk betweenthe financial sector and broader sectors - Figure 2. Market risk Transmission Mechanism.2Davies and Davies, 1999, A comparative chronology of money
9PayPal A Smart StepPayment systems also transmitrisk and a key element ofOperational Risk, particularlyin the context of automatedpayments, is Systemic RiskFigure 2. Market Risk Transmission MechanismMarketsScenariosFinancial SectorMarketCreditOperationalBroader SectorsParticipantsMechanismsImplications Financial Institutions(Fis) Non-Bank Fis Financial MarketInfrastructure Payment Systems Government Businesses Consumers Citizens Assets Markets BehavioursEconomicPoliticalSocietalFinancialFigure 3. LegislationPolicyPolicy / IndustryDIR93DIR110EconomicTechnologicalREG: RegulationDIR: DirectiveD. THE PAYMENTS LANDSCAPE – PAST AND PRESENTThe business of payments is a two-sided business and one with a complex ecosystem of users,providers and enablers.A structured summary of the payments landscape – past and present – is summarised in Figure 3.The Payments Landscape, which provides a macro-economic framework tailored to the paymentsindustry.This summary provides the context to understand the opportunities and the threats to thepayments regulatory framework.EnvironmentalHistorically, payments was regarded as a banking activity, highly technical and best regulatedby a national central bank. Perceived as a private good, the payments architecture was typicallyhierarchical and ‘managed’ by a small number of settlement banks with accounts at the centralbank and clearing banks providing clearing services to other banks and financial institutions.Today, policy makers increasingly understand the relationship between payments and theeconomic, social and strategic performance and welfare of their constituents. Increasingly thebusiness of payments is regarded as a public good with basic bank accounts being sometimesregarded as a human right3.3 Report in Worldcrunch about expected proposals for basic social rights expected from the European Commission in June 2013
10PayPal A Smart StepFigure 4. The bank centric ‘payments architecture’Central Bank NCBSettlement Bank SBClearing Bank CBAgency Bank ABAB1Clearing / B.Historically, currency was the sole preserve of the central bank and payments were synonymouswith banking as well as delivered by a hierarchical payments system; Figure 4 Bank CentricArchitecture.IndustryIn this system, the ‘payments architecture’ that has evolved is one where:–––––Local banks and branches held payment accounts;Clearing banks exchanged payment instructions;Clearing banks provided access to Agency banks and owned payment market infrastructure;Settlement banks settled clearing bank liabilities; andA central bank exchanged value between settlement banks.Technology, policy and market forces are transforming this model, increasing access to marketinfrastructure and defining new regulated payment service providers such as Payment Institutionsand Electronic Money Institutions. The Cloud allows new entrants to enter the market like neverbefore. This is done by combining standardisation, the SEPA PE-ACH concept to increase reach,as well as the ubiquity of the Internet / TCP-IP enabled devices.Companies from a variety of sectors are now launching payments-related products and services.What these companies have in common is a desire to make the payments process more efficientfor consumers. Figure 5 Example Payment Innovations contains a slice of the range of players andinnovations that currently exist in the payments sectorFigure 5. Example Payment InnovationsInnovative Product(s)& FunctionalityIndustry SectorAPPLETechnologyStores creditAT&T, T-MOBILE, andcards for appVERIZONstore purchases.Passbook App storesrewardsTelecomISIS stores paymentscredentials onsmartphone; NearField Communicationused for paymentsEBAY INC.InternetPayPal storesWALMART, TARGET,paymentsSEARS, BEST BUYinformation in securewallet in the cloud forboth online and pointof saleRetailMerchant ConsumerExchange (MCX)currently developingand testing a mobilepayments platform4Company(s)Industry SectorInnovative Product(s)& FunctionalityCompany(s)e.g. telephony companies, merchants, money transmission companies, technology companies
11PayPal A Smart StepCompany(s)Industry SectorVISAPaymentsSTRIPEInnovative Product(s)& FunctionalityInnovative Product(s)& FunctionalityCompany(s)Industry SectorCredit cards providepayments at point ofsale; v.me for secureonline paymentsAMAZONInternet RetailAmazon Paymentsallows merchantsto accept paymentsusing Amazonaccount informationStartup InternetDeveloper-focusedmethod for acceptingpayments online.DISCOVERPaymentsCashback rewardsprovides consumerswith cash rewards forpaymentsBARCLAYS ORANGEBank TelecomQuick Tap allows UKcustomers to utilizetheir mobile phonesfor contactlesspaymentsSQUAREStartup InternetAllows smallbusinesses to acceptpayments using adongle that attachesto a mobile deviceGOOGLEInternetWallet storespayment credentialsin digital wallet;Near-FieldCommunication usedfor paymentsINTUITAccounting andFinancial SoftwareIntuit Pay smartphoneapp connects to aChip & Pin readerthat allows for pointof sale paymentsacceptanceBANK OF AMERICABankMobile Pay onDemand allows smallbusinesses to acceptpayments using asmartphone dongleWESTERN UNIONPaymentsEnables onlinepayments service forbusinesses makingcross border bankto-bank paymentsBarclaysMobile PaymentsA mobile paymentservice, Pingit, forinitiating paymentsusing the mobileSafaricomMobile BankingA mobile telephonebased service thatovercomes orically, the payments business was a very manual process centred on the branch, which hasbeen increasingly automated as technology has developed. Two innovations stand out as suchin, Figure 6. Payments Timeline - the ATM and the card payment instrument. More recently onlinebanking is evolving to meet the new transactional needs of today’s market place.Today the technology landscape is evolving at a dizzying pace, with component technologies seeingexponential growth in their performance and at ever decreasing levels of cost. The implications of thisare impacting all elements of the payments value chain to create new value propositions and include:– Fixed and wireless network capacity – more can be moved faster;– Functionality and performance of end user devices, particularly mobile ones – propositions canbe more rich and diverse; and– Data storage capacity and performance – data can be accessed, manipulated and usedmore easily.Figure 6. Payments TimelinePre 9000 BCBarter through to standardisation1960sThe credit card, the ATM and automated payments1970sThe mag stripe, cross-border payment messages barcodes and deregulation1980sFrequent flyer rewards, telephone banking, digital PC and online payments, RTGS and connected POS devices1990sThe Internet, online auctions, pre-paid card systems and online banking2000siTunes, Facebook, PayPal, CHIP and PIN, price comparison iPhone, Faster Payments, Contactless, Bitcoin2010zGoogle Wallet, Pingit, Facebook credits, switching services
12PayPal A Smart StepThe Internet, the mobile device and the Cloud amplify the effects of these developments. Each ofthese technology-based services and propositions are being packaged and combined to createsignificant opportunity and drive change in the payments business.Advances in cryptography are also transforming how and where payments are conducted –bringing security to mobility and enabling new digital currencies such as Bitcoin. New virtualcurrencies in gaming, social networking and other digital contexts are growing, becoming acceptedin other contexts and challenging real-world currencies and regulatory controls. In 2006 a Chinesestate prosecutor even suggested that QQ coins might challenge the legitimate status of the Yuan5.EconomicHistorically, banks have derived substantial value from their retail payments franchise through NetInterest Income, the deposit multiplier and float in the payments process. However, the financialcrisis in 2007/8, quantitative easing and the more recent economic recession have all combined todisplace traditional sources of value in retail payments.As economies work their way out of recession, the value pool of payments is likely to increasesubstantially and outpace growth in GDP. This is because of the shift from off-line to onlinepayments with 50% of European consumers projected to make online purchases by 20136,the displacement of cash by mobile instruments and the growth in payments for digital contentpurchases by virtual currencies.Socio-CulturalThe retail customer has been evolving at the same time as the payments market and is typicallyclassified in one of six generations; GIs, Traditionalists, Baby Boomers, X, Y and Z. Each of thesegenerations has needs, expectations and behaviours that have been shaped by their experiences,values and characteristics.Figure 7. UK / US Generation Y ProfilesUnited KingdomUnited States80— 0—4435—3930—34Gen %2%4%6%8%Source: UN Demographic Yearbook (2011) /KPMG AnalysisGeneration Y, people born between 1978 and 2005, make up a substantial proportion of the nationaldemographic, Figure 7 UK / US Generation Y Profiles, and have been brought up with digital.Connected, online and living their lives through their social networks they are large consumers ofonline content. With a high degree of social responsibility and a distrust of government they willembrace and want to embrace payment mechanisms that match their lifestyles – digital, online andmobile. Generation Y are therefore very comfortable shopping online with over 82% doing so7.567Asia Times online / China DeskInternet Retailer / EurostatVisa
13PayPal A Smart StepUnderstanding the differences between these generations, and in particular the data and datarelationships that they create in today’s more connected and digital world, allows regulatorsopportunity to imagine and identify new ways of achieving their objectives.PolicyHistorically, payments policy in Europe was limited and narrow. The business of payments wasregarded as a bank issue and the level of intervention was relatively low. Where intervention didoccur it tended to focus on delivering certainty and predictability of instruments like the cardsand cheque.Today, the business of payments is a major public policy issue. It is recognised as a part of criticalnational infrastructure and the threats posed to it by financial crime and geopolitical terrorism arehigh on the agenda. This shows no sign of abating in the foreseeable future.Economic, terrorist and operational incidents have all stimulatedsubstantial policy intervention:– 2007/8 financial crisis – banking system fragility, recovery and resolution, ring fencing– In 2001, “9/11” World Trade Centre in New York City - the Financial Action Task Force roleextended to including combatting terrorist financing and extended its anti-money launderingrecommendations;– In 2012, a number of retailing banking incidents saw a significant number of UK customersunable to access their bank based payment services – up to one month in some regions.These issues have resulted in new:––––Supervisory institutions being formed;Localised pieces of regulation;Prudential requirements being established; andDefinitions of business conduct and processes.In individual markets and at the community level, regulators have acted to stimulate innovation andtransformation. It is important that the volume and nature of regulation does not of itself constraininnovation, which is why it is vital to develop it effectively and efficiently.
14PayPal A Smart StepPART 2:PROBLEM. PAYMENTS REGULATION TODAYINTRODUCTIONPayPal supports effective andefficient payments regulationPolicy is the expression of a society’s choices about what must be either done or achieved andregulation is the means to make sure that this happens. Regulation per se is therefore a necessarypart of a healthy and functional society.PayPal’s purpose in writingthis paper is to contribute tomaking the regulatory processmore efficientOver time a set of timeless goals has evolved that underlie all effective payments regulation. Thispaper supports these goals and seeks to ensure their more efficient delivery through improvementsin regulatory development and conduct.SECTIONSA. Timeless Goals Behind Payments RegulationB. The Payments Regulatory Approach is Falling Short
15PayPal A Smart StepA. TIMELESS GOALS BEHIND PAYMENTS REGULATIONSociety needs payments to bewell regulated from a prudentialand conduct perspective.Doing so creates trust andfairness in the system as well asspurring innovation and growthin the market.Payments regulation isfounded on a timeless set ofprudential goals and conductobjectivesThere is a general consensus on the key policy goals that should underlie payment regulationamongst the key payments stakeholders around the world. National central banks, conductauthorities, prudential authorities and competition authorities are defined as key paymentsstakeholders.Synthesising each stakeholder’s specifically stated objectives produces a clear set of commonprudential goals and conduct objectives. These goals and objectives should underpin the effectiveregulation of any world-class payment system in the market that the system serves.Overarching Prudential Goals8Specific Conduct Objectives Efficient capital allocation/economic liquidity Proper macro-economic functioning Reduce economic volatility/increased resilience Remove market imperfections Protect depositors, investors and customers Ensure safety of financial infrastructures Deliver mandated political goals Achieve demand-side/supply-side externalities Balance interests of market participants Foster innovation and competitiveness Increase consumer protection Reduce financial crime More effective market and firm governance Increase access to financial infrastructures Greater transparency of information and pricing More fairness in conduct and recourse Increase innovation of products and services Improve security of information and systems Greater predictability in the operation ofpayments in all plausible scenarios Legal certainty of systems and processesPrudential goalsThe overarching goals arefocused on achieving asafe, customer-focused andcompetitive marketPrudential goals exist and persist because they underpin the operation of the market itself.Protection of depositors and consumers lies at the heart of trust in the financial markets. It alsounderpins the concept of credit and creates the confidence to make or receive payments.1. Issuers may not innovate in payment instruments unless acquirers invest in acquiring devicesand vice versa leading to an innovation impasse; or2. Collaboration to resolve the innovation impasse may lead to market concentration of power,barriers to entry and barriers to long run innovation.Equally, the governance structure and collaborative requirement in the payments industry providepolicy makers and regulators with a relatively easy mechanism to affect change and deliver policy.This is evident in the development of Know Your Customer requirements.Conduct objectivesThe conduct objectives providethe detail on how the marketgoals are actually delivered inpracticeConduct objectives exist and persist because they support the prudential goals and deliverkey policy objectives in how the market should function. Conduct objectives are where marketparticipants are required to change the way they conduct their business or operational activities toaddress specific policy issues.For example, this may be to address asymmetric information relationships in providing financialproducts and services, establishing requirements to treat customers fairly in terms of informationdisclosure and providing a clear means and mechanism of recourse.Alternatively, this may be to more effectively operate sanctions restrictions on countries,organisations or individuals by requiring greater Know Your Customer controls and due diligencein the payments process and then filtering and screening transactions to identify prohibitedtransactions.
16PayPal A Smart StepB. THE PAYMENTS REGULATORY APPROACH IS FALLING SHORTA better understanding of the landscape is neededRecent developments havebegun to capture a wider rangeof organization and context but more needs to be doneIt has only been relatively recently that payments regulation has begun to bring all organisationsproviding payment services into a more formal supervisory structure with the establishment of thePayment Services Directive9 in 2009. This followed an earlier intervention addressing ElectronicMoney Institutions in 2000.Up until this point, in Europe these organisations had difficulty identifying applicable legislation.Despite this more still needs to be done for example:– A major prepaid contactless system – A substantial payment mechanism that allowspayment across a number of transport organisations, which has issued a significant number ofpayment instruments, c55 million that is roughly the si
A. PAYMENTS ARE REALLY IMPORTANT The Quantity Theory of Money shows the relationship that the payments business has to the economic output of an economy. Without payments, markets would cease to function, production would halt and government would be unable to operate. If individuals have limited access to payments then they are constrained from
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PayPal requires you to provide three ways for your customers to access PayPal Express Checkout. See Table1 . Table1 PayPal Express Checkout Methods Method Description Shortcut Place the Checkout with PayPal button on your checkout page. Payment Place the PayPal button on your payment page
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