Retail
Payments at Crossroads: Economics, Strategies and Future Policies
by Shri G Padmanabhan, Executive Director of the
Reserve Bank of India, Paris, 21 October 2013.
I am deeply honored to be here and thank the European
Central Bank and Banque de France for inviting me as a member of this important
panel. I have been asked to specifically comment on three aspects of the topic
we are discussing and let me attempt that in seriatim.
I. How can financial intermediaries and financial
inclusion contribute to the economic growth of the country?
1. As Global Payments 20131 report points
out we are facing a “two speed world” as far as payments activities are
concerned – one in mature economies and the other in emerging or rapidly
developing economies. This calls for two different approaches for the two types
of economies.
2. Developed economies have already reached a level of
market maturity in terms of retail payments and are looking for the next
generation of efficiencies in these systems by re-discovering their relevance
in the society. However, in the case of emerging markets, retail payments have
been on the policy radar as we try and get away from cash based and paper based
payments. Hence we continue to `re-dedicate’ on its development rather than
`re-discover’ its importance. Our challenge has been to enable such systems to
`develop’, `consolidate’ and `converge’ with innovation at each stage.
3. So in India we have continued to focus on both
paper based and electronic payment systems. But realizing the rapid scale of
innovations and for focus we decided to encourage the formation of a separate
organization - a non-profit organization called the NPCI (National Payments
Corporation of India) as the umbrella organization for retail payment systems
in India. This entity is now spear-heading the innovations in retail payments
in India and has introduced several products and payment services such as the
inter-operable inter-bank mobile payments with 24 x 7 real-time transfer of
funds (IMPS - Immediate Payment Systems), payments based on Aadhaar (Unique
national id based on biometrics), a domestic card network – RuPay which is
being used for various purposes viz. enhancing financial inclusion, food
procurement, farmer credit, etc. Besides, NPCI has also enabled ISO compatible
National Automated Clearing House (NACH) systems.
4. It is
a well-accepted fact that a well-functioning payment system contributes to
monetary and financial stability and ensures economic efficiency. How do you
define the term “well-functioning”? In the emerging market context, such a
system must ensure users' trust in these payment methods similar to the trust
they have in cash transactions. There is always the “fear of unknown”. One bad
experience in the beginning can make them rush back to cash usage. This is even
a bigger challenge particularly when we are reaching out to the financially
excluded to adopt electronic payments.
5. It must be appreciated that
financial inclusion has been accorded high priority in policy hierarchy in
recent times as the advent of technology has enabled increased reach and
delivery of financial products in a cost effective and viable manner. So more
appropriately what is being aimed is technology led financial inclusion.
Business correspondents play an important role in this effort since the lack of
penetration of brick and mortar bank branches could be attributed to financial
exclusion. Different countries have adopted different models but in any model
business correspondents are important entities in the chain. Further, alternate
payment models are the hallmark of the FI efforts across the countries.
6. In this regard, various studies2 have shown that customers who have quick and reliable access
to payment points and customers who use alternate non-cash payment methods tend
to keep more funds in their accounts for larger periods of time. Therefore,
provision of safe, accessible and efficient alternate payment channels assumes
critical importance. This is crucial for the banking systems in India when the
savings and loan spreads are high. So financial inclusion makes huge commercial
sense. In fact, the CGAP report3
also highlights the
beneficial impact of financial inclusion through increased deposit and lending
to GDP ratios on national income.
7. As I have said earlier, different
countries have adopted different models to achieve financial inclusion. For
example, Pakistan has put in place a mechanism of person-to-person funds
transfer through the banking system using BCs without the need for opening
accounts; customer identification being based on national identity as well as
mobile number. In India while BCs play an important role, financial inclusion
aims not merely at remittances but also aims at savings product, a loan/credit
product, remittance product as also insurance product.
Further the basis for a remittance
product outside banking systems pre-supposes the existence of a national
identity system in the country.
8. A few words about Indian approach
to FI. We have always been alive to the need for extending the reach of the
financial sector to the under-privileged sections of the society. Financial
inclusion for us aims not merely at remittances but also aims at savings
product, a loan/credit product, remittance product as also insurance product.
Thus, in India we believe that, financial inclusion has the potential to bring
in the unbanked masses into the formal banking system, could lead to increased
savings, provide timely credit to the unbanked masses and all these positive
externalities would lead to economic growth. The efforts to channelize the
government benefits and subsidies through direct benefit transfers programs to
beneficiaries’ bank accounts directly would not only be helpful in plugging the
leaks in distribution but also help in inculcating banking habits.
9. How has India approached FI? We
have adopted a structured, planned and an integrated approach towards FI by
focusing on both the demand and supply side constraints. We have permitted
non-bank entities to partner with banks for their FI initiatives. The
technological advancement has made it possible for us to think of novel and
innovative ways to approach the objective of financial inclusion. For example,
handheld devices, used by bank agents to draw people living in remote areas
into the banking fold. Mobile technologies are trying to reach out to the
populace starved of banking services as well. Financial institutions are also
joining forces with network operators in providing access to mobile based
payment services even to those who do not have bank accounts.
10. Let me give you some statistics
on our financial inclusion initiatives4:
ô€€¹ Nearly
268, 000 banking outlets have been set up in villages as on March 13 as against
67,694 banking outlets in villages in March 2010
ô€€¹ About
7400 rural branches opened during this period
ô€€¹ Nearly
109 million Basic Savings Bank Deposit Accounts (BSBDAs) have been added,
taking the total no. of BSBDAs to 182 million. Share of ICT based accounts have
increased substantially – Percentage of ICT accounts to total BSBDAs has
increased from 25% in March 10 to 45% in March 13
ô€€¹ With
the addition of nearly 9.48 million farm sector households during this period,
33.8 million households have been provided with small entrepreneurial credit as
at the end of March 2013
ô€€¹ With
the addition of nearly 2.25 million non-farm sector households during this
period, 3.6 million households have been provided with small entrepreneurial
credit as at the end of March 2013.
ô€€¹ About
490 million transactions have been carried out in ICT based accounts through
BCs during the three year period.
II. The relevance of international
standards and principles for stretching a retail payment services beyond
domestic boundaries
11. It is my considered opinion that
the international community for too long has not accorded adequate importance
to the retail payment system. I agree that reasons could be many and relevant.
For instance, retail payment systems are far too heterogeneous. However, the
growing importance of retail payments, the increased complexities and
technology driven payment systems call for a revisit. Further, there are some
retail payment systems in most countries which are ubiquitous in nature and
have system-wide importance. At least in a large country like India we are
talking about retail payment systems which are quite significant. Let me state
a few numbers. We clear on a daily basis approximately 4.5 million cheques,
operate nearly 2 million person to person electronic fund transfers, handle
around 1.5 million bulk payments i.e. one-to-many and many-to-one payments. These
are in addition to the large volume of card payments, internet and mobile
transactions. We will be certainly better off having some principles and
standards developed for the retail payment systems. Let me bring out a few
issues to support my argument for international standards for retail payment
systems.
12. There are retail systems that
have cross-jurisdictional presence. For instance, card payments, international
remittances, PayPal etc.
13. In the case of card payments, it
is generally the leading global card networks which are taking the lead in
determining the industry standards for form factor as well as security
standards (EMV Chip; 2FA), without active regulatory intervention. However,
such standards have implications for countries - in terms of cost of migration
to newer standards, impact on domestic card networks (cost of certification,
access to new standards / technology etc.). Should the regulators be involved
in standard setting so that there is a level playing field for both international
and domestic entities?
14. For large value payment systems,
regulatory arbitrage is sought to be addressed through international common
standards and principles. How can similar concerns be addressed for retail
systems with system-wide importance as the extant standards are either region-specific
or country-specific? One area where there is ample scope for common standards
is the areas of security in electronic payments. For instance, taking card
payments once again, while on the one hand Europe has the EMV standard already
implemented, USA is still continuing with Magstripe. So where does this leave
other emerging countries such as India? We are striving to move towards EMV but
are aware that Magstripe cards will be around for some time. Though we have
strengthened our card transactions domestically using 2FA with Magstripe cards,
there are still jurisdictions where magstripe is still in vogue but without 2FA
requirements. Hence, such arbitrage opportunities need to be addressed by
adopting minimum common security standards.
15. Despite several efforts at
addressing the issues relating to international remittances (for instance, the
World Bank has prescribed certain guidelines), challenges pertaining to
reducing the cost of remittance and addressing the AML / FATF issues (lack of
standards, legal and regulatory requirements between remitting and receiving
countries is being exploited) continue to persist. Since it is a recognised
fact that international remittances form a significant channel for cross-border
payments, and form major part of GDP of few countries, the need for common
standards and principles in this area would also be welcome.
16. The lack of international
standards in retail payments could also affect the inter-operability between these
systems – both at a domestic level as well as at international level. At a
domestic level, currently in India, we are facing a challenge in promoting
interoperability amongst the non-bank and bank operated payment systems. While
considering the access of non-banks to inter-bank payment network, the
challenges that need to be addressed are in terms of lack of standardisation of
form factors, message formats, non- adoption of international standards for
card security such as PCI-DSS etc.
17. At the same time, in India, we
have also seen the advantages that standardisation can bring in, for
facilitating inter-operability and contributing to the growth of certain
payment systems. Right at the outset, the mobile banking guidelines issued in
India prescribed certain standards for mobile banking message formats to ensure
interoperability in transactions. Going forward, the NPCI implemented the IMPS
for mobile banking facilitating inter-operable mobile banking transactions in
the country. This has given a very good impetus to instant funds transfer on
24x7 basis using mobile banking.
18. So clearly there is a case for
developing international standards and principles for cross border payment
systems at the minimum. But the issue would be how to enforce such standards.
19. Then the issues related to home
country and host country regulatory prescriptions also need to be addressed,
with minimal scope for regulatory arbitrage. The final thought I have on this
issue is besides international standards and principles, has the time come for
“co-operative oversight" for internationally pervasive retail payment
infrastructures?
III. What are the key considerations
to be followed while innovating retail payment systems?
20. The first thought that comes to
my mind when I consider this question, the remarkable foresight of the ECB in
coming out with the document on minimum safety recommendations to improve
online payment security to be implemented by 2015. I also want to acknowledge
the seminal guidelines issued by the ECB on data quality. Both are outstanding
documents.
21. To me, the thumb rule for any
central bank has to be encouragement of innovations. But before innovations
become a "product" of system wide importance, standards need to be
put in place. Otherwise, there would be bigger issues to reckon with. (eg:
cloud computing in the financial sector, rules for payment gateways, security
standards for mobile banking or enabling NFC based payment instruments are some
of the examples that come to my mind.) But be conscious that what is good for
goose may not be good for the gander (mature systems vs. emerging systems).
22. The need and focus of innovations
may vary significantly among countries – between countries with developed /
mature payment systems and those where payment systems are evolving.
23. While safety and security are
underpinnings of any innovation, in emerging payment system jurisdictions, the
key consideration for innovations may revolve around accessibility,
availability, affordability etc. whereas in mature / developed payments market,
the focus may have shifted towards convergence of payment channels and
real-time payments.
24. Another important issue that is
emerging in the innovations context, relates to legal and oversight issues of
the innovative payment services. Two examples come to mind: (a) virtual
currencies and (b) access to customer accounts by third party service providers.
25. When innovations take place outside the banking domain,
i.e., entry of non-banks in offering these services – raises certain issues:
access to National Payment Systems by non-banks, extent of regulation, customer
ownership and protection issues, data privacy and security.