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Mobile Payments Forum Of India Regulatory Recommendations and Discussion points Feb 2008 Regulatory Sub Committee S.No. Designation Name Organization 1. Special Invitee Mr. A.P. Hota RBI 2. Member Secretary Mr.V.Visweswar IDRBT 3. Member Mr. V. Dinesh Citi Bank 4. Member Mr.Pallab Mitra Bharti Airtel 5. Member Mr.Sanjay Bhargava Eko 6. Member Mr.Aditya D. Menon Obopay 7. Member To be decided IIT Chennai Sachin Khandelwal ICICI Bank Coordinator Agenda Introduction 2. Areas for Regulatory Assessment 3. Stakeholders and their expectation 4. Roles and Responsibilities 5. Regulator Framework, Policies and standards 6. Audit and Legal policies 7. Account-based Mobile Payments 8. Other Payment Considerations 1. Introduction Increased discussion around providing financial services solutions via mobile for social and financial inclusion. This in turn will increase adoption of these services making ubiquitous and hence successful over time. The more successful models have centered around Stored value and remittance products To do this successfully we will be need to design regulation that encourages common standards and inter-operability; with a level play field for all stakeholders Several examples of mobile payments and remittances services being used in various parts of the world. Some of these have been successful (Philippines and Africa) and others not so successful In India, banks, telcos and other technology companies, working together could provide provide the much needed platform for financial reach and ease. Areas for Regulatory Assessment Banks Telcos Anti Money laundering and KYC controls Anti Money Laundering laws, KYC regulations, Regulatory controls Regulatory controls Acceptance of deposits by Telcos, Application hosting and Network infrastructure Correspondent tie-ups Transaction monitoring Correspondent tie-ups Cash payment and handling infrastructure Fraud management / reporting, etc. Transaction capability and monitoring Transaction capability Bank account opening and maintenance Tie-up with merchants Telco Network for using domestic money remittances Third Party Payment processors Centralized cross bank settlement mechanism Stake Holders Expectations Consumers : Personalized service Minimal learning curve Trust, privacy and security Ubiquitous – anywhere, anytime and any currency Low or zero cost of usage Interoperable Solution Anonymity of payments like cash Person to person transfers Merchants : Faster transaction time Low or zero cost in using the system Integration with existing payment systems High security Being able to customize the service Real time status of the mobile payment service Minimum settlement and Payment time Stake Holders Expectations Telecom Network Providers: Generating new income by increase in traffic Increased Average Revenue Per User (ARPU) and reduced churn (increased loyalty) Become an attractive partner to content providers Mobile Device Manufacturers: Large market adoption with embedded mobile payment application Low time to market Increase in Average Revenue Per User (ARPU) Stake Holders Expectations Banks: Network operator independent solutions Payment applications designed by the bank Exceptional branding opportunities for banks Better volumes in banking – more card payments and less cash transactions Customer loyalty Software and Technology Providers: Large markets More points ……. Stake Holders Expectations Government : Revenue through taxation of m-payments Standards Regulator : Expand reach and ease of financial transactions Adequate standards AML and KYC to be of desired standards Roles & Responsibilities Banks Telcos Third Party Payment processors Facilitate Money Exchange( Inter & Intra Bank) through existing Banking Instruments & systems KYC and customer history. Ability to use Telcos KYC for financial transactions External low-cost hosting for interoperable solution Transactional services including processing and Audit Trail to be maintained Full responsibility for fraud management as per TRAI guidelines. Policies enabling audit and governance to be framed Fraud management & KYC Guidelines to be adhered to Distribution network to be used to provide financial services Fraud management and checks Banks to play active role in P2P and cash-cash payments External low-cost hosting at Telco should be explored Ensure compliance guidelines are enforced Setting up of infrastructure for undertaking Domestic Money Remittances along with the Bank Policies enabling audit and governance of such a model to be framed. Roles & Responsibilities Banks KYC Txn ease Txn cost Compliance Frauds Reach Telcos Third Party Payment processors Regulatory Framework suggested Ride on Existing Guidelines RBI’s Guidelines and policies on KYC , AML Settlement as per existing rules, guidelines & processes. Messaging systems standardisation Guidelines for Interoperability between Stakeholders Guidelines Cash In and Cash Out at Telco Outlets Usage of Telco’s KYC for P2P Payments Regulatory Framework suggested Account Opening should be similar to current process and adhere to existing guidelines Telco’s role should include providing platform to initiate transactions and carry the messages to the bank’s systems Standardization of the transaction processing and settlement Instruction formats for payments, remittances and Banking Standards for instructions, interfaces, data storage & transactions Regulatory policies and standards Standards and guidelines for data exchange AML for Funds transfer and P2P if outside Bank’s network & monitoring carried out by the Bank Sign up for service for Existing or new customer Transaction: PIN based transactions domestic remittances Agent appointment Audit policy Guidelines have to be evolved to ensure - Customer convenience - Transaction & Identity security Transaction Flows between stakeholders to adhere to existing guidelines & encryption for security Ombudsman to Audit systems and process of stakeholders Complete audit trail maintenance Existing networks like NFS, VISA and MasterCard etc. to be used for transactions Legal Guidelines Financial Transactions monitoring as per existing Banking regulations. 1. 2. 3. 4. 5. 6. Banking Regulation Act Information Security Act Evidence Act Indian Contract Act RBI Guidelines and Circulars Negotiable Instruments Act Extension of existing Control measures to Mobile Payments Dispute redressal Mechanism to take care of Stakeholders Account-based Mobile Payments Bank Account based Mobile Payments: Large customer base between Banks & Telcos Collaborate for m-payment solution Bank account linked to mobile phone number for transactions Credit Card based Mobile Payments: Huge Credit card and Mobile Base Credit card number is linked to the mobile phone number for transactions Ride on Existing settlement platforms Account-based Mobile Payments Telecommunication Company Billing of Mobile Payments: Post Paid Mobile Bill/ Prepaid Topup for exending creit to customers Repayment to Telco P2P Payments Real time money transfers through mobile phones. Financial Inclusion KYC, AML and frauds risk need to be considered Other Payment Considerations To develop a suitable framework to support the following payments: SIM based mobile payment application using SMS Extension of PayPal for the mobile context USSD based solution - mPay Pay-Buy-Mobile NTT DoCoMo Suggestions and Comments …