A Good Digital Payment Ecosystem: Characteristics and Recommendations
A good digital payment ecosystem is one that enables financial inclusion, an ecosystem that allows all citizens to participate in the growth and development trajectory of the economy.
The key stakeholders in the digital payment scenario are numerous – internet service providers, payment system operators, technology providers, mobile network operators, banks and retailers form the actual players in the market. The digital transaction system allows banks to increase their customer base with lower costs and risks. According to Booz Allen estimates, banks can reduce cash logistics by 10% through use of cashless payment transactions. Telecom and internet service providers gain by increasing customer retention, higher revenues through value added services etc. Retailers and service providers benefit through fast access to a larger base of customers, better payment collections etc. There is a synergy between the digital world and the financial world that needs to be exploited successfully to give the final benefit to the consumer. However, at the same time the government and regulators of banking, telecommunications, payment systems, competition issues, anti-money laundering, all form the environment in which the digital payments business model functions.
Given that the business of digital transactions is new and unfamiliar, governments and regulators tend to be cautious about allowing innovations that may disrupt financial stability of the economy. As has been emphasized in the previous sections of this paper, while on one hand financial inclusion is the stated objective of governments, and new technology has been widely accepted as a tool for financial inclusion, regulatory and supervisory concerns have inhibited the development of digital payments in many countries, including India. For a new product market to develop, it is important that the enabling environment be one which blends legal and regulatory openness and certainty – openness will allow innovation to flourish while certainty will give confidence to entrepreneurs to make investments. Thus the markets which develop fastest are those which are in environments that are moving towards greater openness and greater certainty. The most crucial issue here is to ensure that the market remains open and competitive for entrepreneurs to take up new business models. The key characteristics have been mentioned and discussed at various points in the preceding sections. These are:
1. Ensure entry by ensuring a high degree of inclusiveness in types of service providers, ensuring a level playing field, and also ensure that both large and small players can enter the industry.
Inclusiveness: Both banking and non-banking entities should be encouraged to enter the industry.
The basic concerns of regulators in the financial sphere revolve around (i) maintaining financial stability, (ii) raising economic efficiency, (iii) increasing access to financial services, (iv) ensuring financial integrity, and (v) ensuring consumer protection, and (vi) ensure rapid accessibility of such services for the masses with heterogeneous requirements.
Given the focus of financial regulators to ensure financial stability, it is but natural for them to have a bank focus. But, disruption to financial stability deals with systemically important payment systems, and not retail payment systems, especially of micro-magnitude. This distinctiveness of retail and micro-amounts should be well understood to avoid stifling innovation that has the potential to help the masses of the country. Consequently there is no need to limit this industry only to the banks.
According to the Bank of International Settlements, one of the main objectives of payment regulation is to address those legal and regulatory barriers to market development and innovation. It is for the RBI and other regulators to work towards this end, so that the potential of technology can be exploited to the full in meeting the goal of financial inclusion.
Level playing field: The close links between the network service providers and the consumer should not provide inordinate advantages to those companies at the cost of other players. For instance, currently the mobile phone is considered the most potent tool of financial inclusion. However the mobile industry is characterized by only a handful of operators both in India and abroad. Given the close links between the consumer and the mobile service provider and the tie-in of the consumer to the service provider, a monopolistic digital transaction industry would be a likely outcome if a level playing field is not created.
A digital-payment platform set up by the service provider should be open to other account holders within a specific agreed time period, and new entrants should be allowed to use existing payment infrastructures. Just as landline users can choose between different long distance providers, so too must regulation ensure that various financial service providers can access the user.
Large and small: The digital transaction eco system should involve, and not keep out, small firms.
Large firms should not derive undue advantage from regulatory prescriptions. This is important for many reasons. Take for example Micro-finance initiatives and how they can leverage the intra-communities ties for lowering cost of credit. Whether we have MFIs or bank correspondents, or private money-lenders, or NGOs, or other entities operating in small distinct communities, such entities need not be debarred from providing their services to their users through digital means.
Though certain prudential norms would be essential, they should not follow a one size fits all approach and, depending upon scale and scope of their operations, their regulatory requirements also need to be appropriately structured.
2. Ensure low cost access for the masses that is integrated with the economy.
Know Your Customer Norms: If digital transactions are to be truly transformational, it is important to bring unbanked customers into the fold of payment systems. KYC regulations put in to ensure financial integrity can hamper the growth of this market and hence affect the aim of financial inclusion.
According to RBI guidelines, mobile payment services to be offered by banks are not only restricted only to their customers, but also to those customers who are KYC/AML compliant. Since subscription to a mobile phone also involves identity checks, this is a duplication of effort and can given rise to inconsistencies in norms. Standardizing the system of compliance across digital and financial worlds will also help sharing of data and information. These may seem as small glitches now, but can appear as roadblocks later on retarding the goal of integrating the latest digital technology with financial services. Discussion on evolving systems is important to keep abreast of technological and market developments.
Integration: Facilitate a variety of services that are easy to integrate with all sectors of the economy.
In the digital transaction market, there is a significant coordination problem that arises due to the overlapping role of multiple regulators of banking, telecom and payment system supervisors, competition and agencies involved in monitoring activities of money laundering and fraud. The problem is compounded because of the dynamic nature of the industry and continuously evolving technology. This means that the regulators have to be flexible, be quick on the uptake to change when needed and deliver appropriate regulatory orders in a coordinated and consistent fashion.
3. Ensure that the system can serve heterogeneous requirements
Inherent flexibility: A one size fit all approach that is currently the practice in banking regulation needs to change to become more flexible and adapt to the different needs of the consumers at the bottom of the pyramid, who are a highly heterogeneous group. The terms ‘masses’ and ‘under-privileged’ are a highly heterogeneous segment. They include self-employed and unemployed, cultivators and land-less laborers, literate and illiterate, nuclear households and joint families, indeed the range is large. And so are the requirements.
Conclusion: Financial inclusion is recognized as a goal by all policy makers as the economic growth and development story will remain incomplete without participation by the poorest of the poor. Evolving technology has changed the landscape of the financial world as digital payments bring with them significant efficiencies. Further, with the fast adoption of mobile phones and spread of the networks, costs of making transactions have been significantly reduced. Experiences in other countries and modern technology shows that the future lies in involving non-bank institutions as intermediaries. While vigilance is justified when confronted with new, unfamiliar systems, stifling innovations and market developments through extreme caution will only retard the growth trajectory of the economy. The policy makers should therefore work towards providing an environment where all stakeholders can perform the functions they do best. An added problem in the digital payment space is that the overlapping roles of multiple regulators leads to coordination failure and this should be well understood by all policy makers. The need of the hour therefore is to work with clarity and consistency and speed up the process of moving towards greater openness and greater certainty in the digital payment sphere.