From Payment Regulation to Class Action

Transcription

1 From Payment Regulation to Class Action World Financial Symposium 2014 World Financial Symposium 2015 World Financial Symposium 2014

2 Australia 10 Years Later World Financial Symposium 2014 Lance Blockley Managing Director - Consulting RFI Intelligence World Financial Symposium 2015 World Financial Symposium 2014

3 Australian Regulation of Interchange What s happened since 2003? IATA World Financial Symposium 17 September 2015 Presented by Lance Blockley, Managing Director, RFi Consulting Commercial in Confidence Copyright RFi Consulting Pty Limited

4 Interchange fees flow from the Acquirer to the Issuing Bank in an effort to balance costs incurred in the system Four party card scheme: Merchant Acquiring Bank Card Scheme Cardholder Issuing Bank Merchant Service Fee = Interchange + Acquirer Margin Interchange Interchange rates depend on product type, channel, merchant, location Today in Australia: Credit card interchange rates range from 0.22% to 2.2% for Visa and MasterCard Debit card interchange rates are usually flat fees, ranging from 0.4 cents to 12 cents per transaction Commercial in Confidence Copyright RFi Consulting Pty Limited 4

5 Issuers use revenue from interchange to fund a variety of operational costs that are not recovered from the cardholder Funding the interest free period Credit losses Fraud losses Transaction processing costs and Issuers have increasingly begun to use interchange revenue to provide rewards programs Commercial in Confidence Copyright RFi Consulting Pty Limited 5

6 Interchange fees do not exhibit behaviour typical of competitive markets and have become a focus of reform by regulators Market theory suggests that competitive forces should drive prices down over time, as suppliers compete for customers and transactions However, in order to encourage banks to issue card products, there must be a mechanism to defray the costs of issuing In the absence of regulation, interchange rates therefore tend to increase, in order to encourage new issuers and stimulate competition Regulators in many markets have felt the need to intervene, most notably in Australia, Europe, Asia and the US Commercial in Confidence Copyright RFi Consulting Pty Limited 6

7 In Australia, the Wallis Report in 1996/7 catalysed reform of the payments system to increase efficiency and make fees transparent The Wallis Financial System Inquiry found there was scope for substantial gains in efficiency in the Australian payments system, including: The increased use of electronic payments; and Making card payment system fee arrangements more transparent The Report recommended a joint study between the Reserve Bank of Australia (RBA) and the Australian Competition and Consumer Commission (ACCC) be conducted to focus on: Interchange fee arrangements for credit and debit cards; and Opening up access arrangements (within the payment system) The study, conducted in 2000, led reforms that were implemented in 2003 It noted a number of systemic failures /market imbalances in the payment system Commercial in Confidence Copyright RFi Consulting Pty Limited 7

8 Market imbalances prompted the RBA to implement payment reforms for the first time in 2003 Systemic Failures 1. Credit Growth > Debit Growth 2. Opaque pricing; not reflective of costs 3. Rewards cards being subsidised by others 4. Access to system too restrictive Source: RBA Commercial in Confidence Copyright RFi Consulting Pty Limited 8

9 Market imbalances prompted the RBA to implement payment reforms for the first time in 2003 Reforms Announced 1. MC/Visa Credit Interchange 0.95% 0.55% 2. Remove No Surcharge Rules 3. Open up Access Regime Source: RBA Commercial in Confidence Copyright RFi Consulting Pty Limited 9

10 Market imbalances prompted the RBA to implement payment reforms for the first time in 2003 Reforms Announced 1. MC/Visa Credit Interchange 0.95% 0.55% 2. Remove No Surcharge Rules 3. Open up Access Regime Reforms Take Effect October 2003 Source: RBA Commercial in Confidence Copyright RFi Consulting Pty Limited 10

11 Issuing banks were quick to increase fees and reduce the value of rewards programs, while looking for new opportunities American Express Companion Cards $1 spend = 1 point $75 $40 E.g. Annual Fees 4. Customer Sub- Segmentation E.g. Low rate, no rewards cards $1 spend = 0.5 point E.g. Points earn rate 2. Commercial in Confidence Copyright RFi Consulting Pty Limited 11

12 Finer customer segmentation was supported by additional interchange categories and a wider spread from high to low Number of Credit Card Interchange Categories 2.0 Range of Visa Credit Card Interchange Fees* = 180 bps = 48 bps Pre Reform Nov-03 Jun-04 Nov-06 Jun-07 Nov-09 Jun-10 Nov-12 Jun-13 MasterCard Visa 0.0 Pre Reform Nov-03 Jun-04 Nov-06 Jun-07 Nov-09 Jun-10 Nov-12 Jun-13 Visa High Rate Visa Low Rate *Excludes the charity categories (which have an interchange fee of zero) and interchange fee categories with a flat-fee component; excludes GST Sources: MasterCard, Visa, RBA Commercial in Confidence Copyright RFi Consulting Pty Limited 12

13 Despite dire predictions surrounding the regulation of interchange, the Death Spiral failed to materialise A self-reinforcing cycle could be set in motion that could eventually lead to the whole open system unravelling: interchange fees set too low, leading to issuers charging higher fees to cardholders, leading to diminishing cardholders network, leading to fewer merchants acquired, leading to the need to further lowering of the interchange fee, and so on. This could be characterised as a death spiral process 1 interchange fees would still be necessary [in a mature network] to ensure that cardholders did not exit a network and, in so doing, cause merchants to exit the network, as a result of the reduced number of potential customers (in turn, a smaller merchant base could cause more cardholders to leave the network and so on in a vicious circle) 2 1 MasterCard Incorporated Submission to Reserve Bank of Australia, June 8, Visa International Service Association, Response to the Reserve Bank of Australia s Consultation Document and Report of Professor Michael Katz, (March 2002) Commercial in Confidence Copyright RFi Consulting Pty Limited 13

14 But overall, the reforms of 2003 did little to dampen the growth of payment card activity - both credit and debit increased # of Payments (m) 4,000 3,500 3,000 2,500 2,000 1,500 1, Australian Annual Transaction Volume By Type of Retail Payment (million) 0.95% 0.55% 0.55% 0.50% Cheque Direct Debit Direct Credit Credit & Charge Cards Debit Cards ATM Cash Withdrawals Source: RBA Commercial in Confidence Copyright RFi Consulting Pty Limited 14

15 However, a shift in volume from 4-party to 3-party schemes was seen with the introduction of AmEx companion cards Westpac first to launch companion cards in 2004 CBA last to launch in 2009, the last of the Big 4 to do so Large growth in commercial for AmEx Small Business Services (SBS) through vertical pipeline ~ Source: RBA Commercial in Confidence Copyright RFi Consulting Pty Limited 15

16 Neither did the interchange interventions result in major share shifts between the 4 major banks - product, servicing & marketing being key 25% 2002 Total Balances = $21.6B Estimated Share of Consumer Credit Card Balances 2014 Total Balances = $49.8B 20% 15% 10% 5% 0.95% 0.55% 0.55% 0.50% 0% Source: APRA, RFi Consulting Estimates Commercial in Confidence Copyright RFi Consulting Pty Limited 16

17 During 2014, another Financial System Inquiry (FSI) was conducted, with the payments realm once again included The FSI Final Report issued last December included broad sweeping recommendations across many aspects of Australia s financial system In the payments realm, the report recommended changes to: Credit card interchange fee structures; Limitations on merchant surcharging; and Regulation of American Express companion cards If implemented by the RBA, changes in these areas would have a significant impact on: Merchants Financial institutions Cardholders Loyalty businesses Commercial in Confidence Copyright RFi Consulting Pty Limited 17

18 FSI Recommendation 17 was the most pertinent for payments, specifying changes to the interchange and surcharging regimes Recommendation Improve interchange fee regulation by clarifying thresholds for when they apply, broadening the range of fees and payments they apply to, and lowering interchange fees. 2. Improve surcharging regulation by expanding its application and ensuring customers using lower-cost payment methods cannot be oversurcharged by allowing more prescriptive limits on surcharging. Source: FSI Final Report Commercial in Confidence Copyright RFi Consulting Pty Limited 18

19 There has been a premiumisation of Australian portfolios, as issuers sought to maximise interchange revenues between re-sets The RBA mandate is that the average credit interchange for a Scheme s entire portfolio should be no higher than 0.5% Actual rates subject to calculation and adjustment every three years The issuers and Schemes have caused a premiumisation of the market With the average i/c rate rising over each three year period The FSI wants to curtail this upward creep, and the highest interchange rate (currently only paid by small merchants) is likely to become capped Effective Interchange Rate 0.70% 0.65% 0.60% 0.55% 0.50% 0.45% 0.40% ***Illustrative*** Q Q Q Commercial in Confidence Copyright RFi Consulting Pty Limited 19

20 Although American Express companion cards provide issuers rebates, not interchange, they were also targeted for regulation American Express cards are currently not included in the interchange regulation neither proprietary nor Bank-issued Although not technically interchange, AmEx s high merchant service fees provide a strong issuerincentive rebate mechanism Funding high cardholder rewards If companion cards become regulated, banks may quickly drop the programs Instead focusing on their core MasterCard and Visa portfolios In turn, American Express will likely fight to convert high-spending bank customers to AmEx proprietary products Commercial in Confidence Copyright RFi Consulting Pty Limited 20

21 Changes to the surcharging rules will likely have an impact on merchants, especially airline booking service fees The FSI recommended differential surcharging for low, medium, and high cost card payment methods - Low cost debit cards: surcharging prohibited - Medium cost credit cards (MC & V): likely 1% cap - High cost credit cards (AmEx & Diners): no surcharge limit The 3 tier system is probably too complex, but a ban on debit surcharging and stronger policing of the regime are likely Flat fee surcharges, common in airlines, are likely to be banned and changed to an ad valorem fee Greater use of differential surcharging could discourage the use of American Express Commercial in Confidence Copyright RFi Consulting Pty Limited 21

22 The RBA published an Issues Paper in March 2015, commencing another review of card payments Reacting to the FSI, the RBA commenced another card review in March, including but not limited to: - Lowering of interchange and inclusion of AmEx companion cards - Reduction of upward drift in average interchange rates through annual reviews - A tiered surcharging system Public submissions were received in April and the RBA held a private forum in June New RBA draft regulations are expected soon Commercial in Confidence Copyright RFi Consulting Pty Limited 22

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25 From Payment Regulation to Class Action World Financial Symposium 2014 World Financial Symposium 2015 World Financial Symposium 2014

26 A Spanish Preview of What Implementing the New EU Regulations Will Look Like World Financial Symposium 2014 Luis Rázquin Tesorería y Financiación Iberia World Financial Symposium 2015 World Financial Symposium 2014

27 Card Payment Regulation IB Implementation Experience IATA World Financial Symposium September 2015

28 Spanish Legislation: Decree-Law 8/2014 On 4 th July 2014, the Spanish Government published Decree-Law 8/2014 On Urgent Measures for Growth, Competitiveness and Efficiency. Among other measures, this legislation pushed forward regulation related to card payments, which was then also discussed at European Union level Main points of Spanish DL 8/2014 about card payments: - Scope: affects all card transactions that comply with two conditions: the Point of Sale is in Spain a processor established in Spain intervenes. - Effective 1 st September Defines Corporate cards as those only used for professional expenses. 28 World Financial Symposium 2015

29 Spanish Legislation: Decree-Law 8/2014 (cont.) - Prohibits surcharge on regulated cards - Caps Interchange Fee for 4 Parties Consumer cards (including cards issued by licensees of 3 Parties Card Schemes): Debit consumer cards 0,2% (maximum 7 EUR cents) Credit consumer cards 0,3% Specific limits for micro payments, below 20 and 35 EUR, with no impact for airline industry. 29 World Financial Symposium 2015

30 IB implementation experience (1 of 4) Legal opinion was demanded about specific definitions and wording. A consensus was reached with our processors and acquirers on how the Decree-Law should be operationally implemented. IB had to move from a Debit/Credit card differentiation to a more complex differentiation between 3/4 Parties schemes, and between Consumer/Corporate cards, to correctly apply the legislation. 30 World Financial Symposium 2015

31 IB implementation experience (2 of 4) Iberia had to break down the cards in two groups: Cards that cannot be surcharged, must meet all following conditions: o Spanish issued cards. o Consumer cards. o 4 Parties schemes, and licensees of 3 Parties schemes. Cards that can potentially be surcharged, must comply with one of the following conditions: o Cards issued outside Spain. o Corporate cards. o 3 Parties card schemes. 31 World Financial Symposium 2015

32 IB implementation experience (3 of 4) Operationally IB produced a list of surcharge exempted cards, following the previous experience with the Debit cards surcharge exemption. Is a list of BINs (6 first digits of the card) that indicates the card scheme and category. Is used for differentiation. The result is an exemption list of about BINs. This list is updated monthly. In the IB case this exemption list has to be uploaded in different data bases, covering both direct and indirect sales. 32 World Financial Symposium 2015

33 IB implementation experience (4 of 4) The exemption BIN list (contains only Spanish issued cards) was created by aggregating information from different sources: - IB s Spain acquirer provided the Spanish issued BIN list for Visa and Mastercard, with differentiation between Consumer/Corporate. - issuers under licenses from 3 Parties cards schemes provided their BIN ranges, with differentiation between Consumer/Corporate. - 3 Parties schemes provided their BIN ranges for Spanish-issued cards, with the differentiation between Consumer/Corporate. 33 World Financial Symposium 2015

34 Comparison between Spanish Decree-Law and EU Package (1 of 2) Spanish regulation definitions wording is different from EU regulation, but in practice they are equivalent. Spanish legislation covers elements of both pieces of the EU regulations: Interchange Fee capping and Payment Service Directive update. Anticipated consequences of EU regulation for IB: IB will have to re-negotiate some merchant fees with more emphasis on the mix Consumer/Corporate cards. If in Spain the BIN exemption list contains about items, for all EU it may be 10 times bigger! Data volumes can create problems. 34 World Financial Symposium 2015

35 Comparison between Spanish Decree-Law and EU Package (2 of 2) Conceptually it is not a major change, implies to change from traditional Debit vs Credit differentiation to a focus on European issued 4 Parties Consumer vs rest of cards. BIN information sources. In our case it has been quite easy to secure reliable and updated sources of BIN information. At EU level may can be more challenging. Processors and card schemes have to deliver the information allowing merchants to implement correctly the Regulation. 35 World Financial Symposium 2015

36 Thank you. Muchas gracias

37 From Payment Regulation to Class Action World Financial Symposium 2014 World Financial Symposium 2015 World Financial Symposium 2014

38 European Union Policy in the World Financial Symposium 2014 Field of Payment Jean Allix Principal Administrator, DG Competition European Commission World Financial Symposium 2015 World Financial Symposium 2014

39 European Union policy in the field of payments. IATA Barcelone Jean ALLIX European Commission DG Competition Antitrust Payment Systems Brussels The views expressed in this presentation are the speaker's personal views, and do not necessarily represent the official position of the European Commission

40 Legislative package 24 July 2013 Proposed Regulation on interchange fees for card-based payment transactions Rules on interchange fees and business arrangements for payment card transactons And transactions based on those With 'two legs' within the EU (but occasionally with impact on all transactions, eg HACR) Proposed revision of Payment Services Directive (all payment instruments) Modernise the current legal framework Contribute to the promotion of security and innovation in the retail payments market Market access for new non-bank players Common rules on surcharging

41 Payment legislation Card based payment transaction Credit transfer Direct debit Regulation on interchange fees Regulation on SEPA end date (euro only) Payment services In the internal market Directive (PSD)

42 Classic card four party scheme with interbank IF Scheme Fees CARD SCHEME CARD SCHEME Schemes Fees Competition issues on the acquiring side due to: Issuing Bank Interchange fee Acquiring bank - Blending - Choice of application Payer Payee Reverse competition - Honour all cards rules - No discrimination rules

43 Regulation: two main objectives Reverse competition: provides clarity to Industry on how to change behaviour. Introduce more competition in a two sided market

44 Chapter II : interchange fees Article 3: debit cards ( ) Article 4: credit cards ( ) 0.2% 0.3% Article 5: prohibition of circumvention

45 Interchange fees caps: scope Included: four-party consumer cards Excluded: commercial cards but many will become consumer cards three party schemes without licensees

46 Credit transfer : Paypal, Western Union Payment Service Provider Three party scheme : payer and payee have the same payment service provider Payer Card : Amex Payee

47 Reference: sascityfed.org/~/ media/files/publi cat/psr/dataset/i ntl_if_august201 5.pdf Eu level December 2015

48 Effect for IATA Rough estimate by IATA : possible savings for all airline MC and Visa sales in Europe should be between and $

49 Business rules to improve competition mostly on the acquiring side Art 6:Licensing, no territorial restrictions ( ) Art 7:Split scheme & processor ( ) Art 7:Technical interoperability ( ) Art 8: Co-badging ( ) Art 8:Choice of application ( ) Art 9: Unblending ( ) Art 10: Honour all card rules (tying) ( ) Art 11: steering rules ( ) Art 12:Transparency, payee information ( )

50 Future of payments: Mobile payment (wallets) Wallet based on cards Wallet based on credit transfers (ACH)

51 Ban on Honour All Card Rule Merchants can refuse the expensive cards within a given brand. 51

52 Article 10.5: identifiable Payment instruments electronically identifiable visibly identifiable payees can know the instrument's category Entry into force:

53 Article 11: steering rules, surcharges Steering rules by merchants are allowed Nobody can prevent rebate (PSD) Surcharge: allowed on non capped cards (PSD).

54 BUT Notwithstanding paragraph 4, Member States may forbid or limit the right of the payee to request charges taking into account the need to encourage competition and promote the use of efficient payment instruments

55 Title II payment institutions New actors (PIS) prudential rules for authorisation PSD1 & 2 Title III information requirements increased transparency improve consumer protection and choice Title IV rights and obligations facilitate SEPA harmonisation legal certainty for providers and users Security promote consumer improve competition confidence Establish a harmonised legal framework for the development of pan-european payment services and infrastructures

56 What we want to avoid for consumers Why is this internet payment not working? Card based transaction: a payment by card without a piece of plastic Strong Customer Authentication

57 Payment: not a bank monopoly Newcomers (TPPs): Payment initiation services Account information services 25/09/2015

58 Private enforcement Many cases as regard interchange fees in EU countries where possible; Tesco Gets $61 Million/ 55 ( as Retailer Settles U.K. MasterCard Suit ). Several billion euros claims outstanding in UK alone. Will become possible in all EU countries on : Directive 2014/104/EU on antitrust damages actions

59 Questions?

60 From Payment Regulation to Class Action World Financial Symposium 2014 World Financial Symposium 2015 World Financial Symposium 2014

61 Interchange Litigation: The American Way? World Financial Symposium 2014 Joseph M. Vanek Attorney Vanek Vickers and Masini World Financial Symposium 2015 World Financial Symposium 2014

62 Overview of Litigation against Visa, MasterCard and American Express in the United States by Joseph M. Vanek September 17, 2015 Privileged and Confidential

63 What is the Goal? Lower Credit Card Costs by Securing the Right for Merchants to Steer Customers to Lower Cost Forms of Payment, such as debit. Examples of Steering include: Offering a Discount for a Preferred form of Payment Surcharging Expensive Forms of Payment Expressing a Preference, e.g., We Prefer Debit Privileged and Confidential

64 The Fine Point The Key is DIFFERENTIAL Steering! We Prefer Visa To Keep Costs Low, We Charge a 2% Convenience Fee on American Express Please Use MasterCard Differential Steering Allows Merchants to Shift Market Share between Credit Card Networks Leading to Price Competition between them. Privileged and Confidential

65 In re Payment Card Interchange Fee and Merchant Discount Litigation Privileged and Confidential

66 In re Payment Card Interchange Fee Litigation What has been accomplished? Merchants now have the right to: Differentially Discount Differentially Surcharge Communicate Payment Preferences to their Customers Those reforms were implemented in two phases, in July, 2011 and February, Some Merchants Claim the relief did not go far enough so the settlement with the Class Action is being appealed. That Case will be resolved sometime next year, at the earliest. Important Restrictions and the American Express Problem. Privileged and Confidential

67 In re American Express Anti-Steering Rules Antitrust Litigation (No. II) Privileged and Confidential

68 Three Players 1. The United States Department of Justice 2. The Class Plaintiffs 3. Individual Merchant Plaintiffs Privileged and Confidential

69 Three Players 1. The United States Department of Justice DOJ seeks to eliminate the prohibition against soft steering / and no discount rules. Does notseek to eliminate prohibition against the no surcharge rule. Privileged and Confidential

70 2. The Class Plaintiffs Three Players Soon to be dismissed in favor of individual arbitrations. The proposed class settlement has been denied. Privileged and Confidential

71 Three Players 3. Individual Merchant Plaintiffs Filed suit against Amex in 2008 seeking damages and rule changes. Only parties seeking relief to permit hard steering/surcharging in Court. Privileged and Confidential

72 U.S. v. Amex In 2010, United States Department of Justice sued Amex seeking to invalidate network rules that prohibit soft-steering and discounting. 6 week bench trial took place this summer before Judge Garaufisin a Federal District Court. The Department of Justice has prevailed. As a result, as of July 20, 2015 merchants have been permitted to differentially discount and softly steer to preferred forms of payment. Privileged and Confidential

73 Strategic Considerations Steering in the United States: watch the fine points! Damage Claims v. Amex Arbitration is the only option. Antitrust Claims in the United States are an assignable asset. Privileged and Confidential 73

74 Roundtable and Questions World Financial Symposium 2014 World Financial Symposium 2015 World Financial Symposium 2014

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76 Networking Lunch World Financial Symposium 2014 World Financial Symposium 2015 World Financial Symposium 2014