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Australia’s Latest Payments System Development Initiative-
    Could This Show An Alternative Path to Greater Financial Inclusion for
                             Developing Countries?

                                      Louise Malady1
                                      February 2013

Overview

The Australian payments industry, with strong involvement and encouragement
from the Reserve Bank of Australia (the RBA is the regulatory body responsible
for the oversight and regulation of the Australian payments system), is working
together to establish a new payments system infrastructure which will support
future innovations in payments for businesses and consumers. An update from
the payments industry on proposed plans was expected to be considered at the
RBA’s Payments System Board (PSB) meeting on Friday 15 February 2013.

This article seeks to highlight this Australian initiative for developing countries
seeking greater financial inclusion, and aid organisations assisting these
countries. This Australian initiative could show an alternative path to greater
financial inclusion for developing countries.

It is expected the changes being proposed in Australia will enable the banks’
underlying payments system infrastructure to support more efficient and
innovative payments products and processes than what is available to Australian
businesses and consumers today. The changes will pave the way for banks’
customers (both individuals and businesses) to be able to ‘Pay Anyone,
Anywhere, Anytime’.

Australian businesses and consumers have, in recent years, already enjoyed
some benefits of greater payments innovations being undertaken by Australian
banks. Due to a combination of technological advances and banks being driven
to compete for domestic depositors’ funds, as a result of limited international
funding sources, banks turned their focus to competing on product
differentiation and speed of processing payments. However, these innovations
are built to run on the banks’ existing payments system infrastructure which are
becoming out-dated, inflexible and exposed to greater operational risk. There is
a general acceptance by Australian payments industry players that their systems
need greater operational resilience.2 The RBA is also keen to see industry

1 Louise Malady is a researcher and consultant for mobile banking and payments regulation.
Louise is currently based in Sydney, Australia, and she has lived and worked in Singapore, India
and the Philippines. In 2011 Louise was engaged by the Asian Development Bank as a Payment
Systems and Mobile Banking Specialist. From 2001 to 2006 Louise worked for the Monetary
Authority of Singapore, where among other roles she was an Assistant Director in the Payments
Infrastructure Division. Louise started her career in 1989 at the Reserve Bank of Australia where
she gained broad experience in payments policy and banking supervision. Louise holds a Master
of Applied Finance from Macquarie University, Sydney. Louise can be reached at
louise.malady@yahoo.com.
2 This acknowledgement of a need for greater operational resilience was highlighted in a paper

by the RBA: “Operational Incidents in Retail Payments Systems: Conclusions”, November 2012, p3.

                                                                                               1
players focus their efforts on ensuring the underlying payments infrastructure is
an adequate support base for future innovations in payments.3

In developing countries, new payment methods and payments innovations have
been hailed as a means towards greater financial inclusion. However, a
stumbling block in many countries has been how to design a new payments
product or system which can reach a critical mass of end-users to truly enable
users to ‘Pay Anyone, Anywhere, Anytime’. New payments products and systems
are often confined to a limited user group, determined by the end-user’s choice
of Telco provider or bank or the dominant Telco provider or bank in that
particular market. Efforts are being made to build interoperable payments
products and systems.4 However, the initiative underway in Australia to
overhaul the payments infrastructure takes a step back from the myriad of
innovations in end-user payments products and systems and looks at how to
develop the architecture of the underlying infrastructure so as to provide
adequate support for ongoing innovations in payments.

Payments regulators in developing countries, and the aid organisations
supporting greater financial inclusion in these countries, could direct more focus
and funding towards payments system infrastructure development initiatives
similar to those currently being undertaken in Australia. While it may be argued
such payments system development is too costly for developing countries to
consider, it is possible developing countries face a different cost structure to
developed countries as the former are unlikely to have the vast legacy systems
which the latter must contend with; the developing countries may be able to
“leap frog” some of costs involved in such infrastructure development work.

Central banks and payments regulators in developing countries would also need
the support to strengthen their capacity to implement this type of broad
payments system development initiative. Supporting and driving this type of
initiative would be consistent with aid organisations’ objectives of financial
inclusion as it could provide developing countries with a much stronger
foundation on which to subsequently build more accessible payments products
and processes.

This article is structured as follows:
    Section I describes the proposed key features for the end-users of the new
       infrastructure being considered in Australia. Of note is the RBA’s
       emphasis on the use of the ISO 20022 message standards to support
       carrying richer data with payment instructions and interoperability and
       also the RBA’s willingness to enhance its settlement system to facilitate

(http://www.rba.gov.au/payments-system/resources/publications/payments-au/201211-
operational-incidents-in-retail-payments-systems-conclusions/)
3 The RBA released its “Strategic Review of Innovation in the Payments System: Conclusions” in

June 2012. This document is widely used and referenced throughout this article.
(http://www.rba.gov.au/payments-system/reforms/strategic-review-
innovation/conclusions/index.html)
4 For a recent review of such efforts, see The Economist, Schumpeter, “All together now”,

17 January 2013 and Readers’ comments online
(http://www.economist.com/blogs/schumpeter/2013/01/mobile-money)

                                                                                                 2
real-time interbank settlement for retail payments using the new
        payments system infrastructure.          This enhancement would mean
        settlement funds are final and irrevocable; eliminating the settlement risk
        which is present in many retail payment systems today;
       Section II highlights the driving forces creating the necessary
        environment for change in Australia’s payments infrastructure. An
        appreciation of these local conditions and context are important because,
        as with any development initiative, there cannot simply be carbon copies
        made and applied throughout the world; and
       Section III concludes this article with a recommendation that the lead role
        being played by the RBA in this initiative be followed and emulated where
        possible by payments regulators in countries wanting to embrace new
        payment methods as a means of achieving greater financial inclusion.


Section I - The Payments Initiative Underway in Australia – It’s time to ‘Pay
Anyone, Anywhere, Anytime’

A significant and far-reaching payments initiative is now on the horizon in
Australia. The Australian payments industry, with strong encouragement from
the RBA, is working together to establish a payments system which will enable
banks’ customers (both individuals and businesses) to ‘Pay Anyone, Anywhere,
Anytime’. It is expected this payments innovation will:
   - enable all Australians to make and receive payments in day-to-day
       business and consumer transactions irrespective of who they bank with
       and with confidence the person receiving the payment will receive the
       funds almost immediately as cleared funds;
   - provide an easier system of addressing payments. Individuals receiving a
       payment will no longer need to remember their BSB and Account No..
       Instead a more memorable alias may be able to be used, such as an
       individual’s mobile phone number or email address; some form of
       centrally managed database in the background could link users bank
       account details to their chosen alias; and
   - make it easier for people to integrate remittance information with their
       payments details by increasing the amount of information which can
       accompany a payment instruction. In this way business owners can look
       forward to less time spent on reconciliation processes (often an arduous
       process for business owners).

The RBA has identified two notable features it would like to see adopted in the
new payments system infrastructure:
   - The adoption of the ISO 20022 message standard in the new payments
      infrastructure.5 ISO 20022 is used to support interoperability in payment
      systems and it enables a greater quantity of data to accompany the



5Reserve Bank of Australia, “RBA Core Criteria for a ‘Fast Payments’ Solution”, November 2012,
p2. (http://www.rba.gov.au/payments-system/reforms/strategic-review-innovation/201211-
rba-core-criteria-fast-pay-solution/index.html)

                                                                                                 3
payment instruction, thereby creating the possibility of “marrying” a
        payments instruction with remittance information;6 and
    -   Real-time interbank settlement for retail payments using the new
        payments infrastructure. The RBA would enhance its RTGS system
        whereby settlement funds would be final and irrevocable, eliminating the
        type of settlement risk which is present in many retail payment systems
        today. Such settlement risk is now an unnecessary risk given the
        technological advances of recent years enabling it to be more easily
        mitigated.

Payments industry regulators, participants and observers around the world
realise this type of payments initiative requires an overhaul of existing payments
system infrastructure as it involves transforming from batch-based overnight
processing to real time processing. This is a large and complex project for a
developed country such as Australia where banks’ core payments systems are
old, complex and with excessive interdependencies.7 Furthermore, what is
needed is for payments players to work together on this initiative because they
are changing the underlying infrastructure into which all payments players
connect. Such cooperation is understandably difficult to achieve amongst
competitors focused on protecting their depositor base and their existing
investments in payments products and arrangements. However, due to
underlying forces now driving transformative change in Australia’s payments
infrastructure it appears the ever evasive “cooperative innovation” could be
achieved.


Section II - Underlying Forces Driving Transformative Change in Australia’s
Payments System

In 2013 in Australia the time appears right for the successful development of a
payment system to enable Australians to ‘Pay Anyone, Anywhere, Anytime’ with
cleared funds. The time is right because there are currently a number of forces
driving transformative change in Australia’s payments system.8

-    Reputational Risk and Legacy Systems - Banks in Australia acknowledge a
     transformational change in their payments infrastructure is overdue in
     order to avoid further payments incidents and reputational damage arising
     from reliance on legacy systems. (See the RBA’s paper “Operational
     Incidents in Retail Payment Systems: Conclusions”, November 2012, for a
     detailed discussion on the problems banks in Australia are experiencing with
     their core banking and payments systems and why there is a general
     industry realisation that transformational change is needed.);



6 Reserve Bank of Australia, Op. cit., June 2012, pp 10 and 11.
7 As highlighted in the paper by the RBA: “Operational Incidents in Retail Payments Systems:
Conclusions”, November 2012, p3.
8 These driving forces were identified by the RBA in its paper - “Operational Incidents in Retail

Payment Systems: Conclusions”, November, 2012.

                                                                                                    4
-   Consumer Demand - Banks have been intensely competing on the payments
    front to attract what was much needed domestic funding. Consumers have
    benefitted from this intense competition as it has led to greater payments
    innovations and other technological innovations. Internet and mobile
    banking and payments products continue to be improved upon by banks in
    an effort to differentiate their products and attract new depositors. Banks
    are also competing in terms of how fast they can move money for their
    customers, irrespective of the payments channels being used – be it via card
    payments or the Direct Entry system or mobile and internet payments.

    Examples of recent bank innovations include: assisting the customer to do
    online banking in a new or easier way or to purchase products using ‘pay
    and wave’ technology in addition to ‘PIN or sign’; or improving merchants’
    cash flow management by reducing the time between them selling their
    goods via EFTPOS or credit card channels and receiving reimbursement
    from their bank for the goods sold. However, many of the innovations ride
    on banks’ existing payment systems infrastructure. Furthermore, these
    innovations are often ‘stand-alone’ innovations or useful for your own
    banking with your bank or your banking with someone else so long as you
    both bank with the same bank (i.e. in technical payments terms these
    innovations often only benefit users operating in a closed network).

    Banks are aware an overhaul of the underlying payments infrastructure is
    needed to provide the necessary building blocks to support future
    innovations and to maintain their competitive edge. Consumer demand for
    increased banking convenience through greater technological innovation
    and payments efficiency will drive banks to develop their underlying
    systems;9 and

-   RBA’s Conclusions from its Strategic Review of Innovation - Last, but not least,
    as it is arguably the most important driving force for change, is the initiative
    of the RBA’s PSB to now regularly set strategic objectives for the payments
    system which reflect the PSB’s assessment of the public interest. The PSB’s
    initial strategic objectives include a description and timetable for the
    industry to work towards a “Fast Payments Solution” (which this article
    refers to as a ‘Pay Anyone, Anywhere, Anytime’ payments innovation). The
    PSB’s actions can be supported by broad legislated powers in the Payments
    Systems (Regulation) Act 1998. However, the PSB is initially adopting a
    consultative approach but has indicated if the industry is not able to reach
    agreement on how to realise the objectives of the PSB then it may use its
    legislated powers or “it might seek to establish infrastructure itself”.10 (See
    Box A at the end of this article for more detail on why the PSB is now setting
    these strategic objectives.)


9 Dr John Laker, Chairman of the Australian Prudential Regulatory Authority, noted banks’
increased focus on technological innovation as a response to the banking environment of low
credit growth – see Dr Laker’s speech to the American Chamber of Commerce in Australia, “Life in
the Slow Lane”, 11 May 2012.
10 Reserve Bank of Australia, Op. cit., June 2012, p21.


                                                                                              5
The Australian payments industry is expected to announce shortly (possibly
     this month, February 2013) a proposed way forward.11 In terms of the
     timetable for Australian businesses and consumers, they will have to wait
     until end 2016 to see this new payments infrastructure become a reality.
     This is a deadline set by the RBA, however, it reflects the major overhaul of
     payments infrastructure required and the significant financial investment,
     not to mention overcoming the challenges faced in getting the industry to
     cooperate in what is a competitive field. However, if Australia gets this right
     it could be among the world’s leading countries for this form of payments
     initiative.


Section III – Conclusion and Recommendation for Developing Countries
and Aid Organisations assisting these Countries

In recent years, developing countries have been in the midst of their own
payments revolutions in attempts to discover new payment methods which are
transformational. Commercial operators are keen to develop their new
payments products in developing countries as these markets represent an
opportunity to tap into an unbanked population. Aid organisations are eager to
offer financial and technical support for, most commonly, mobile banking
initiatives in the hope such payments innovations will be transformational and
assist in the alleviation of poverty for the unbanked population through greater
financial inclusion.12

One missing piece to the puzzle, making the transformational goal difficult to
realise, is that the mobile banking and payment systems in developing countries
are often not being built as interoperable for end-users. This is potentially
limiting the chance for these systems to reach the critical mass of end-users
needed to ensure ongoing success of what are financially inclusive payments
innovations.13

The payments initiative being considered by the Australian payments industry,
with strong encouragement from the RBA focuses on benefitting the end-user.
Specifically, as outlined in Section II above, the intention to adopt international
message standards which support interoperability and greater data transmission



11 As noted by Andrew Cornell, in the Australian Financial Review, 11 February 2013, in
“Payments: banks still out of tune”, the payments industry through a committee established in
response to the RBA’s initiatives, has put its proposal to the RBA’s Payments System Board which
is meeting on Friday 15 February, 2013.
12 The list of aid organisations in this area includes (in no particular order and not limited to): the

Alliance for Financial Inclusion; the CGAP Technology Group; the GSMA Development Fund; the
UK Department for International Trade; USAID; Mercy Corps; AUSAID; the World Bank; the Asian
Development Bank; and the Bill and Melinda Gates Foundation.
13 This is not to say the issue is not being discussed among industry players. Various aid

organisations have published articles articulating the case for interoperable mobile payments
systems in developing countries, for example search “interoperability” at
http://www.gsma.com/mobilefordevelopment/programmes/mobile-money-for-the-unbanked/
to read some articles on the topic.

                                                                                                     6
capabilities and the plan to improve clearing and settlement arrangements to
eliminate settlement risk are initiatives benefitting the end-user.

Another missing piece to puzzle of how to achieve the transformational goal is
the limited capacity of financial system regulators in developing countries to
carry out payments system reform due to a lack of resources and trained staff.
This capacity could be strengthened by directing aid organisation funds towards
supporting payments system regulators in adopting high level strategic
approaches to payments system reform.14

In mobile banking and payments developments regulators are sometimes
viewed as creating barriers to the development of payments innovation. As an
example of such viewpoints, a Nomura Equity Research article noted regulations
such as Know Your Customers (KYC) requirements could be a “hurdle” and
referred to requirements such as KYC arrangements; agent authorisation; and
licenses for mobile banking activities as “regulatory challenges”.15 Reasoned
cases can be made for the necessity of such “regulatory challenges”, however,
that is a separate discussion.16 The point to be made here is that the RBA is not
approaching payments innovation from a micro-regulatory angle but instead it
has stepped back to take a broad strategic view on how to build the
infrastructure so as to support new and existing payments participants with
greater efficiency in new and existing payments products.

While developing countries are constrained due to a lack of funding for
infrastructure development and a lack of skills or trained staff in regulatory
agencies, they may have one advantage over developed countries; there is the
potential for developing countries to be able to “leap frog” concerns about how
to deal with the legacy systems bogging down development as such systems may
not exist or if they do they may not be too out of date.

Supporting and driving this type of payments system development in developing
countries could provide these countries with a much stronger foundation on
which to build payments products and processes accessible by all, the banked
and unbanked, thereby truly working towards the goals of financial inclusion.




14 See the Consultative Group to Assist the Poor and World Bank Group, 2010. “Financial Access
2010, The State of Financial Inclusion Through the Crisis”. This Survey found that for low-income
countries in particular they lacked the dedicated resources for implementing financial access
reforms.
15 Nomura Equity Research of Asian Telecoms, “Despite scale, can Asian telcos be banked upon?”,

July 20, 2012, pages 10 and 18.
16 See for example Malady, L., “Mobile Payments: Financial Regulatory Approaches in South East

Asia”, (http://www.slideshare.net/hipster40/mobile-banking-financial-regulatory-issues-may-
2011) and also the CGAP Technology Blog for topics relating to the regulation of mobile money.


                                                                                                7
BOX A

RBA Strategic Review of Innovation in the Payments System and Next Steps
In June 2012, following two years of research and consultation, the PSB
published its conclusions to its “Strategic Review of Innovation in the Payments
System”. As part of these conclusions the PSB undertook to change its direction
in relation to payments innovation due to what it saw as some market failures
preventing innovation in the payments system and the PSB’s belief that
innovation is important to its mandate to control risk, promote efficiency and
promote competition in the market for payment services.17

Part of the change in direction of the PSB is it will now establish high-level
strategic objectives which should be met by the payments system by a specified
time. This setting of strategic objectives will be done every three years by the
PSB. The industry will be left to determine the means for meeting the strategic
objectives, reflecting the PSB’s role as a “policy body, not a technical body”.18
The PSB will seek to ensure the objectives are met providing detailed guidance
when necessary.

The PSB’s first set of strategic objectives were outlined in its Conclusions to its
strategic review of innovation.19 The ‘Pay Anyone, Anywhere, Anytime’ concept
is a key component in these initial strategic objectives and the RBA refers to this
as a “Fast Payments Solution” or “real-time retail payments”. In November 2012,
the RBA published its “Core Criteria” which it developed to clarify the
benchmark criteria for assessing proposals for the provision of real time
payments for business and consumers. In publishing these criteria the RBA was
reminding the industry to develop a system where pricing and access
arrangements are considered important and where the project development for
the new system is done “in a way that is open, transparent and consistent with
principles of good governance”. 20

The PSB also set down two additional but related initiatives to its proposal to set
high level strategic objectives: (i) to encourage the “constitution of an enhanced
industry coordination body that is suitable to both interact with the Payment
System Board on behalf of the industry and to provide cooperative agreement on
issues that would not normally be taken up by the Board”; and (ii) to “establish a
framework for more direct interaction between this industry body and the Board
itself.”21 The PSB considers these initiatives necessary to ensure its strategic
objectives are able to be effectively implemented.




17 RBA, Op. cit., June 2012, p3.
18 RBA, Ibid., June 2012, p19.
19 RBA, Ibid., June 2012, p20.
20 RBA, Op. cit., November 2012, p1.
21 RBA, Op. cit., June 2012, p18.


                                                                                 8

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Australia's latest payments system development initiative 17 feb2013

  • 1. Australia’s Latest Payments System Development Initiative- Could This Show An Alternative Path to Greater Financial Inclusion for Developing Countries? Louise Malady1 February 2013 Overview The Australian payments industry, with strong involvement and encouragement from the Reserve Bank of Australia (the RBA is the regulatory body responsible for the oversight and regulation of the Australian payments system), is working together to establish a new payments system infrastructure which will support future innovations in payments for businesses and consumers. An update from the payments industry on proposed plans was expected to be considered at the RBA’s Payments System Board (PSB) meeting on Friday 15 February 2013. This article seeks to highlight this Australian initiative for developing countries seeking greater financial inclusion, and aid organisations assisting these countries. This Australian initiative could show an alternative path to greater financial inclusion for developing countries. It is expected the changes being proposed in Australia will enable the banks’ underlying payments system infrastructure to support more efficient and innovative payments products and processes than what is available to Australian businesses and consumers today. The changes will pave the way for banks’ customers (both individuals and businesses) to be able to ‘Pay Anyone, Anywhere, Anytime’. Australian businesses and consumers have, in recent years, already enjoyed some benefits of greater payments innovations being undertaken by Australian banks. Due to a combination of technological advances and banks being driven to compete for domestic depositors’ funds, as a result of limited international funding sources, banks turned their focus to competing on product differentiation and speed of processing payments. However, these innovations are built to run on the banks’ existing payments system infrastructure which are becoming out-dated, inflexible and exposed to greater operational risk. There is a general acceptance by Australian payments industry players that their systems need greater operational resilience.2 The RBA is also keen to see industry 1 Louise Malady is a researcher and consultant for mobile banking and payments regulation. Louise is currently based in Sydney, Australia, and she has lived and worked in Singapore, India and the Philippines. In 2011 Louise was engaged by the Asian Development Bank as a Payment Systems and Mobile Banking Specialist. From 2001 to 2006 Louise worked for the Monetary Authority of Singapore, where among other roles she was an Assistant Director in the Payments Infrastructure Division. Louise started her career in 1989 at the Reserve Bank of Australia where she gained broad experience in payments policy and banking supervision. Louise holds a Master of Applied Finance from Macquarie University, Sydney. Louise can be reached at louise.malady@yahoo.com. 2 This acknowledgement of a need for greater operational resilience was highlighted in a paper by the RBA: “Operational Incidents in Retail Payments Systems: Conclusions”, November 2012, p3. 1
  • 2. players focus their efforts on ensuring the underlying payments infrastructure is an adequate support base for future innovations in payments.3 In developing countries, new payment methods and payments innovations have been hailed as a means towards greater financial inclusion. However, a stumbling block in many countries has been how to design a new payments product or system which can reach a critical mass of end-users to truly enable users to ‘Pay Anyone, Anywhere, Anytime’. New payments products and systems are often confined to a limited user group, determined by the end-user’s choice of Telco provider or bank or the dominant Telco provider or bank in that particular market. Efforts are being made to build interoperable payments products and systems.4 However, the initiative underway in Australia to overhaul the payments infrastructure takes a step back from the myriad of innovations in end-user payments products and systems and looks at how to develop the architecture of the underlying infrastructure so as to provide adequate support for ongoing innovations in payments. Payments regulators in developing countries, and the aid organisations supporting greater financial inclusion in these countries, could direct more focus and funding towards payments system infrastructure development initiatives similar to those currently being undertaken in Australia. While it may be argued such payments system development is too costly for developing countries to consider, it is possible developing countries face a different cost structure to developed countries as the former are unlikely to have the vast legacy systems which the latter must contend with; the developing countries may be able to “leap frog” some of costs involved in such infrastructure development work. Central banks and payments regulators in developing countries would also need the support to strengthen their capacity to implement this type of broad payments system development initiative. Supporting and driving this type of initiative would be consistent with aid organisations’ objectives of financial inclusion as it could provide developing countries with a much stronger foundation on which to subsequently build more accessible payments products and processes. This article is structured as follows:  Section I describes the proposed key features for the end-users of the new infrastructure being considered in Australia. Of note is the RBA’s emphasis on the use of the ISO 20022 message standards to support carrying richer data with payment instructions and interoperability and also the RBA’s willingness to enhance its settlement system to facilitate (http://www.rba.gov.au/payments-system/resources/publications/payments-au/201211- operational-incidents-in-retail-payments-systems-conclusions/) 3 The RBA released its “Strategic Review of Innovation in the Payments System: Conclusions” in June 2012. This document is widely used and referenced throughout this article. (http://www.rba.gov.au/payments-system/reforms/strategic-review- innovation/conclusions/index.html) 4 For a recent review of such efforts, see The Economist, Schumpeter, “All together now”, 17 January 2013 and Readers’ comments online (http://www.economist.com/blogs/schumpeter/2013/01/mobile-money) 2
  • 3. real-time interbank settlement for retail payments using the new payments system infrastructure. This enhancement would mean settlement funds are final and irrevocable; eliminating the settlement risk which is present in many retail payment systems today;  Section II highlights the driving forces creating the necessary environment for change in Australia’s payments infrastructure. An appreciation of these local conditions and context are important because, as with any development initiative, there cannot simply be carbon copies made and applied throughout the world; and  Section III concludes this article with a recommendation that the lead role being played by the RBA in this initiative be followed and emulated where possible by payments regulators in countries wanting to embrace new payment methods as a means of achieving greater financial inclusion. Section I - The Payments Initiative Underway in Australia – It’s time to ‘Pay Anyone, Anywhere, Anytime’ A significant and far-reaching payments initiative is now on the horizon in Australia. The Australian payments industry, with strong encouragement from the RBA, is working together to establish a payments system which will enable banks’ customers (both individuals and businesses) to ‘Pay Anyone, Anywhere, Anytime’. It is expected this payments innovation will: - enable all Australians to make and receive payments in day-to-day business and consumer transactions irrespective of who they bank with and with confidence the person receiving the payment will receive the funds almost immediately as cleared funds; - provide an easier system of addressing payments. Individuals receiving a payment will no longer need to remember their BSB and Account No.. Instead a more memorable alias may be able to be used, such as an individual’s mobile phone number or email address; some form of centrally managed database in the background could link users bank account details to their chosen alias; and - make it easier for people to integrate remittance information with their payments details by increasing the amount of information which can accompany a payment instruction. In this way business owners can look forward to less time spent on reconciliation processes (often an arduous process for business owners). The RBA has identified two notable features it would like to see adopted in the new payments system infrastructure: - The adoption of the ISO 20022 message standard in the new payments infrastructure.5 ISO 20022 is used to support interoperability in payment systems and it enables a greater quantity of data to accompany the 5Reserve Bank of Australia, “RBA Core Criteria for a ‘Fast Payments’ Solution”, November 2012, p2. (http://www.rba.gov.au/payments-system/reforms/strategic-review-innovation/201211- rba-core-criteria-fast-pay-solution/index.html) 3
  • 4. payment instruction, thereby creating the possibility of “marrying” a payments instruction with remittance information;6 and - Real-time interbank settlement for retail payments using the new payments infrastructure. The RBA would enhance its RTGS system whereby settlement funds would be final and irrevocable, eliminating the type of settlement risk which is present in many retail payment systems today. Such settlement risk is now an unnecessary risk given the technological advances of recent years enabling it to be more easily mitigated. Payments industry regulators, participants and observers around the world realise this type of payments initiative requires an overhaul of existing payments system infrastructure as it involves transforming from batch-based overnight processing to real time processing. This is a large and complex project for a developed country such as Australia where banks’ core payments systems are old, complex and with excessive interdependencies.7 Furthermore, what is needed is for payments players to work together on this initiative because they are changing the underlying infrastructure into which all payments players connect. Such cooperation is understandably difficult to achieve amongst competitors focused on protecting their depositor base and their existing investments in payments products and arrangements. However, due to underlying forces now driving transformative change in Australia’s payments infrastructure it appears the ever evasive “cooperative innovation” could be achieved. Section II - Underlying Forces Driving Transformative Change in Australia’s Payments System In 2013 in Australia the time appears right for the successful development of a payment system to enable Australians to ‘Pay Anyone, Anywhere, Anytime’ with cleared funds. The time is right because there are currently a number of forces driving transformative change in Australia’s payments system.8 - Reputational Risk and Legacy Systems - Banks in Australia acknowledge a transformational change in their payments infrastructure is overdue in order to avoid further payments incidents and reputational damage arising from reliance on legacy systems. (See the RBA’s paper “Operational Incidents in Retail Payment Systems: Conclusions”, November 2012, for a detailed discussion on the problems banks in Australia are experiencing with their core banking and payments systems and why there is a general industry realisation that transformational change is needed.); 6 Reserve Bank of Australia, Op. cit., June 2012, pp 10 and 11. 7 As highlighted in the paper by the RBA: “Operational Incidents in Retail Payments Systems: Conclusions”, November 2012, p3. 8 These driving forces were identified by the RBA in its paper - “Operational Incidents in Retail Payment Systems: Conclusions”, November, 2012. 4
  • 5. - Consumer Demand - Banks have been intensely competing on the payments front to attract what was much needed domestic funding. Consumers have benefitted from this intense competition as it has led to greater payments innovations and other technological innovations. Internet and mobile banking and payments products continue to be improved upon by banks in an effort to differentiate their products and attract new depositors. Banks are also competing in terms of how fast they can move money for their customers, irrespective of the payments channels being used – be it via card payments or the Direct Entry system or mobile and internet payments. Examples of recent bank innovations include: assisting the customer to do online banking in a new or easier way or to purchase products using ‘pay and wave’ technology in addition to ‘PIN or sign’; or improving merchants’ cash flow management by reducing the time between them selling their goods via EFTPOS or credit card channels and receiving reimbursement from their bank for the goods sold. However, many of the innovations ride on banks’ existing payment systems infrastructure. Furthermore, these innovations are often ‘stand-alone’ innovations or useful for your own banking with your bank or your banking with someone else so long as you both bank with the same bank (i.e. in technical payments terms these innovations often only benefit users operating in a closed network). Banks are aware an overhaul of the underlying payments infrastructure is needed to provide the necessary building blocks to support future innovations and to maintain their competitive edge. Consumer demand for increased banking convenience through greater technological innovation and payments efficiency will drive banks to develop their underlying systems;9 and - RBA’s Conclusions from its Strategic Review of Innovation - Last, but not least, as it is arguably the most important driving force for change, is the initiative of the RBA’s PSB to now regularly set strategic objectives for the payments system which reflect the PSB’s assessment of the public interest. The PSB’s initial strategic objectives include a description and timetable for the industry to work towards a “Fast Payments Solution” (which this article refers to as a ‘Pay Anyone, Anywhere, Anytime’ payments innovation). The PSB’s actions can be supported by broad legislated powers in the Payments Systems (Regulation) Act 1998. However, the PSB is initially adopting a consultative approach but has indicated if the industry is not able to reach agreement on how to realise the objectives of the PSB then it may use its legislated powers or “it might seek to establish infrastructure itself”.10 (See Box A at the end of this article for more detail on why the PSB is now setting these strategic objectives.) 9 Dr John Laker, Chairman of the Australian Prudential Regulatory Authority, noted banks’ increased focus on technological innovation as a response to the banking environment of low credit growth – see Dr Laker’s speech to the American Chamber of Commerce in Australia, “Life in the Slow Lane”, 11 May 2012. 10 Reserve Bank of Australia, Op. cit., June 2012, p21. 5
  • 6. The Australian payments industry is expected to announce shortly (possibly this month, February 2013) a proposed way forward.11 In terms of the timetable for Australian businesses and consumers, they will have to wait until end 2016 to see this new payments infrastructure become a reality. This is a deadline set by the RBA, however, it reflects the major overhaul of payments infrastructure required and the significant financial investment, not to mention overcoming the challenges faced in getting the industry to cooperate in what is a competitive field. However, if Australia gets this right it could be among the world’s leading countries for this form of payments initiative. Section III – Conclusion and Recommendation for Developing Countries and Aid Organisations assisting these Countries In recent years, developing countries have been in the midst of their own payments revolutions in attempts to discover new payment methods which are transformational. Commercial operators are keen to develop their new payments products in developing countries as these markets represent an opportunity to tap into an unbanked population. Aid organisations are eager to offer financial and technical support for, most commonly, mobile banking initiatives in the hope such payments innovations will be transformational and assist in the alleviation of poverty for the unbanked population through greater financial inclusion.12 One missing piece to the puzzle, making the transformational goal difficult to realise, is that the mobile banking and payment systems in developing countries are often not being built as interoperable for end-users. This is potentially limiting the chance for these systems to reach the critical mass of end-users needed to ensure ongoing success of what are financially inclusive payments innovations.13 The payments initiative being considered by the Australian payments industry, with strong encouragement from the RBA focuses on benefitting the end-user. Specifically, as outlined in Section II above, the intention to adopt international message standards which support interoperability and greater data transmission 11 As noted by Andrew Cornell, in the Australian Financial Review, 11 February 2013, in “Payments: banks still out of tune”, the payments industry through a committee established in response to the RBA’s initiatives, has put its proposal to the RBA’s Payments System Board which is meeting on Friday 15 February, 2013. 12 The list of aid organisations in this area includes (in no particular order and not limited to): the Alliance for Financial Inclusion; the CGAP Technology Group; the GSMA Development Fund; the UK Department for International Trade; USAID; Mercy Corps; AUSAID; the World Bank; the Asian Development Bank; and the Bill and Melinda Gates Foundation. 13 This is not to say the issue is not being discussed among industry players. Various aid organisations have published articles articulating the case for interoperable mobile payments systems in developing countries, for example search “interoperability” at http://www.gsma.com/mobilefordevelopment/programmes/mobile-money-for-the-unbanked/ to read some articles on the topic. 6
  • 7. capabilities and the plan to improve clearing and settlement arrangements to eliminate settlement risk are initiatives benefitting the end-user. Another missing piece to puzzle of how to achieve the transformational goal is the limited capacity of financial system regulators in developing countries to carry out payments system reform due to a lack of resources and trained staff. This capacity could be strengthened by directing aid organisation funds towards supporting payments system regulators in adopting high level strategic approaches to payments system reform.14 In mobile banking and payments developments regulators are sometimes viewed as creating barriers to the development of payments innovation. As an example of such viewpoints, a Nomura Equity Research article noted regulations such as Know Your Customers (KYC) requirements could be a “hurdle” and referred to requirements such as KYC arrangements; agent authorisation; and licenses for mobile banking activities as “regulatory challenges”.15 Reasoned cases can be made for the necessity of such “regulatory challenges”, however, that is a separate discussion.16 The point to be made here is that the RBA is not approaching payments innovation from a micro-regulatory angle but instead it has stepped back to take a broad strategic view on how to build the infrastructure so as to support new and existing payments participants with greater efficiency in new and existing payments products. While developing countries are constrained due to a lack of funding for infrastructure development and a lack of skills or trained staff in regulatory agencies, they may have one advantage over developed countries; there is the potential for developing countries to be able to “leap frog” concerns about how to deal with the legacy systems bogging down development as such systems may not exist or if they do they may not be too out of date. Supporting and driving this type of payments system development in developing countries could provide these countries with a much stronger foundation on which to build payments products and processes accessible by all, the banked and unbanked, thereby truly working towards the goals of financial inclusion. 14 See the Consultative Group to Assist the Poor and World Bank Group, 2010. “Financial Access 2010, The State of Financial Inclusion Through the Crisis”. This Survey found that for low-income countries in particular they lacked the dedicated resources for implementing financial access reforms. 15 Nomura Equity Research of Asian Telecoms, “Despite scale, can Asian telcos be banked upon?”, July 20, 2012, pages 10 and 18. 16 See for example Malady, L., “Mobile Payments: Financial Regulatory Approaches in South East Asia”, (http://www.slideshare.net/hipster40/mobile-banking-financial-regulatory-issues-may- 2011) and also the CGAP Technology Blog for topics relating to the regulation of mobile money. 7
  • 8. BOX A RBA Strategic Review of Innovation in the Payments System and Next Steps In June 2012, following two years of research and consultation, the PSB published its conclusions to its “Strategic Review of Innovation in the Payments System”. As part of these conclusions the PSB undertook to change its direction in relation to payments innovation due to what it saw as some market failures preventing innovation in the payments system and the PSB’s belief that innovation is important to its mandate to control risk, promote efficiency and promote competition in the market for payment services.17 Part of the change in direction of the PSB is it will now establish high-level strategic objectives which should be met by the payments system by a specified time. This setting of strategic objectives will be done every three years by the PSB. The industry will be left to determine the means for meeting the strategic objectives, reflecting the PSB’s role as a “policy body, not a technical body”.18 The PSB will seek to ensure the objectives are met providing detailed guidance when necessary. The PSB’s first set of strategic objectives were outlined in its Conclusions to its strategic review of innovation.19 The ‘Pay Anyone, Anywhere, Anytime’ concept is a key component in these initial strategic objectives and the RBA refers to this as a “Fast Payments Solution” or “real-time retail payments”. In November 2012, the RBA published its “Core Criteria” which it developed to clarify the benchmark criteria for assessing proposals for the provision of real time payments for business and consumers. In publishing these criteria the RBA was reminding the industry to develop a system where pricing and access arrangements are considered important and where the project development for the new system is done “in a way that is open, transparent and consistent with principles of good governance”. 20 The PSB also set down two additional but related initiatives to its proposal to set high level strategic objectives: (i) to encourage the “constitution of an enhanced industry coordination body that is suitable to both interact with the Payment System Board on behalf of the industry and to provide cooperative agreement on issues that would not normally be taken up by the Board”; and (ii) to “establish a framework for more direct interaction between this industry body and the Board itself.”21 The PSB considers these initiatives necessary to ensure its strategic objectives are able to be effectively implemented. 17 RBA, Op. cit., June 2012, p3. 18 RBA, Ibid., June 2012, p19. 19 RBA, Ibid., June 2012, p20. 20 RBA, Op. cit., November 2012, p1. 21 RBA, Op. cit., June 2012, p18. 8