Mobile Money for Financial Inclusion

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1 Mobile Money for Financial Inclusion Brian Muthiora, Mobile Money Regulatory Specialist Africa, GSMA 25 February 2016

2 Billion Penetration Mobile can be a catalyst for financial inclusion 2.5bn adults without access to the financial system 1.7bn have a mobile phone % 39% % % 40% 30% 20% 10% 0% Active subscribers Penetration 2

3 World Bank s global Findex data 3

4 What is mobile money? Mobile money The use of information and communication technologies (ICTs) and non-bank retail channels to extend the delivery of financial services to clients who would not be reached profitably with traditional branch-based financial services. E.g., e-wallets to make P2P transfers or payments, to receive salary or transfers from the government. Customers can sign up for the service without an existing bank account Customers get money into and out of the service by going to a network of transactional agents outside of bank branches Customers initiate transactions using an interface that is available on basic mobile handsets 4

5 What is mobile money? Mobile banking The extension of banking services delivery through a mobile phone. Characteristics: Typically additive (additional to other access channels) Deposit-taking/banking principles apply Provided by traditional banks, e.g. Equity Bank 5

6 Differences: mobile banking and mobile money Mobile banking Banking business: deposit-taking and credit services. Bank can take risks (intermediate) customer deposits. Bank is liable for the customer deposits, which are typically protected under some deposit insurance or deposit protection scheme. Agents appointed by the bank are licensed to provide agency services and subject to a proportionately higher compliance standard. Their activities are restricted to taking deposits on behalf of the bank, facilitating withdrawals (much like ATMs), card collection and receiving (but not processing) applications for new accounts, loans, etc. Mobile money Payment service: limited to the provision of money transfer services domestic remittances, international remittances in some cases. No credit provision. Payment service provider/emi/mobile money provider prohibited from intermediating customer funds. Funds must be ring-fenced away from the service providers own funds to protect against insolvency. Ring-fencing requires the placement of the pool of funds in trust by a trustee appointed by the service provider or under escrow by a bank in liquid assets. This ensures the service provider s proximity to the funds is so remote that even upon service provider s insolvency its creditors cannot attach the customer funds. It also ensures that the funds are available on demand. Typically non-bank retail traders may be appointed as agents to facilitate new customer registration and Cash In / Cash Out. They also act as the customer-facing points of information for the customer. 6

7 Evidence of demand Microfinance loan Interest free loan from neighbours Savings held for neighbours Rent arrears Wage advance Microfinance savings account Shopkeeper credit Loans to others Remittance to home village Life insurance Home saving Cash in hand Savings with a moneyguard Poor households actively manage their financial portfolios using a range of formal, semi-formal and informal services. Formal Informal 7

8 and its social impact is evident Supports families to keep children in school Improves access to healthcare Helps with the provision of social benefits to vulnerable groups 8

9 Comparative cost of financial access points $250,000 Traditional branch $50,000 Branch in store $10,000 ATM $2,000 Agent with POS terminal $400 Agent with mobile $? No agent (cashless) Source: CGAP 9

10 Mobile money regulatory models Non-bank or MNO led model MNO authorised to offer the services directly Bank-led model Bank authorised to offer the service in partnership with MNO. Bank responsible for compliance Narrow Bank model New institution created and licensed under banking laws but restricted from offering credit 10

11 Mobile money regulatory models Telecom channel (e.g. USSD, STK) Brand and marketing Distribution / agent network Product / platform License holding Regulatory engagement Custody of customer funds MNO (or MNO subsidiary) activities Joint activities, led by bank Bank activities Kenya, Rwanda, Tanzania, Liberia Uganda Nigeria India, Mexico, Colombia (narrow banks) 11

12 Case study: Kenya The key issues: In 2007, the level of financial inclusion in formal institutions in Kenya stood at 26 per cent. Back then, there were a total of 740 bank branches and a modest number of deposit accounts. Most banks required customers to maintain a minimum balance on their account and would typically ask for an opening balance prior to allowing a customer to open a bank account. Mobile penetration was around 52 per cent in

13 Case study: Kenya The approach: The regulatory framework did not specifically provide for the licensing of e-money issuers. However the Central Bank had limited mandate under the CBK Act to come up with policies that provide for the regulation of the payments systems. When faced with an application made by Safaricom the CBK faced two stark choices: turn down the application on account of insufficient regulation; or consider the application on the basis of the limited mandate it had under the CBK Act The CBK thus adopted a wait and see approach, allowing the application to go through under its close oversight. A legal structure modeled on the common law of trusts was adopted to protect customer funds and to distinguish these services from deposit-taking activities. Providers were prohibited from offering credit services and self-imposed transaction limits were approved by the CBK A risk based approach was implemented under which the only KYC permitted was a National ID. 13

14 Case study: Kenya The outcomes: Kenya has seen financial inclusion levels rise from 26 per cent in 2007 to 67 per cent in The country now boasts 22 million mobile money subscribers with 18 million active mobile money accounts. The growth of mobile money has had a hugely positive impact on the development of the country s financial sector as well as the country s overall economic development. 14

15 Case study: Paraguay The key issues: Paraguay is one of the poorest countries in Latin America, with high levels of financial inequality and rural areas that suffer from inadequate access to education and financial services. Paraguay has one of the lowest densities of bank branches in the region, with just five branches for every 100,000 inhabitants. In mid-2010 there were 621,766 reported deposit accounts at Paraguay s banks and financial institutions, meaning that just 10% of the country s population had access to bank accounts. Mobile penetration in the country is close to 100 per cent. 15

16 Case study: Paraguay The approach: Tigo, the market leading mobile operator in Paraguay, launched its Giros Tigo mobile money services in The product focuses on domestic remittances and uses an over-the-counter model where the sender goes to an agent to send e-money to a recipient, who then receives a notification via SMS and can cash out using a PIN at their local agent point. Personal, the second largest operator, also launched its Billetera Personal service in It s an electronic wallet that allows users to transfers money and make payments. Billetera Personal is linked to a no-frills bank account, provided by partners Banco Atlas and Banco Continental. 16

17 Case study: Paraguay The outcomes: The enabling regulatory environment for mobile money services has been a key factor in the growth of mobile financial services in the country. Paraguay showed a country-wide commitment to improving financial inclusion, created policies that offered a balance between commercial interests and risk management, and allowed operators to use simplified Know Your Customer checks. While MNOs in the country have not publicly disclosed the number of users for their mobile money services, the Central Bank of Paraguay (BCP) estimates that there are approximately 60,000 active mobile money users in Paraguay. This means the country is now a leader in mobile money in the Latin America region. 17

18 Case study: Colombia The key issues: For many years, Colombia had one of the more sophisticated financial inclusion regulatory frameworks in the region thanks to its bank-led model. Flexible KYC for basic accounts including remote opening, use of agents, tax incentives and other government programs have been in place to boost financial inclusion since Access rates have increased as well as the geographical coverage of the financial sector. Nowadays around 70% of the population has a financial product and 100 per cent of the country s municipalities have at least one access point (agent, ATM or branch). Regardless, the use of transactional products is very limited and cash is still king. The impact of financial inclusion is very restricted. 18

19 Case study: Colombia The approach: Colombian law did not allow authorities to take a watch-and-learn approach to non-banks offering products such as e-money, so Congress needed to pass a law in order to allow non-banks to offer these types of transactional products. After a few years of discussions with the industry, and following strong opposition from those in the banking sector, a financial inclusion law was finally approved by congress. When it came to implementing and regulating the law, the regulator opted to take an approach where there was very open dialogue with the industry. 19

20 Case study: Colombia The outcomes: The government trusts that non-banks, especially those with well established IT infrastructure such as mobile operators will be incentivised to deploy business models that can increase the use of financial products among the population. Several firms, including mobile operators, are interested in applying for the e-payment license allowed under the new law. 20

21 Case study: Sri Lanka The key issues: Sri Lanka has a population of 20 million people and 9.3 million unique mobile subscribers. According to the International Finance Corporation (IFC), Sri Lanka has high penetration of bank accounts, but low access to electronic payments, such as debit and credit cards, due to the slow rollout of ATMs and Point of Sale devices. In 2007, the Central Bank of Sri Lanka (CBSL) authorised National Development Bank to launch a mobile money service called ez Pay with Dialog, a leading Sri Lankan mobile operator. However, the service failed to take off, and by 2012 there were only about 13,000 registered ez Pay users. 21

22 Case study: Sri Lanka The approach: With ez Pay struggling to take off, the CBSL, Dialog and Hatton National Bank PLC (another commercial bank), worked together to understand why the service was unsuccessful. After analysing the experiences of countries where mobile money was thriving, the CBSL issued new guidelines in 2011 on two distinct mobile money products: an e-wallet linked to a bank account and an e-wallet provided by a non-bank. In 2012, Dialog was awarded a licence to provide non-bank, mobile money services, under the ez Cash brand. The CBSL also agreed to let Dialog register users without requiring them to have a bank account and opted for proportional, risk-based KYC requirements for new users. 22

23 Case study: Sri Lanka The outcomes: The evolution of CBSL s approach created an open playing field for bank and non-bank providers, allowing mobile operators to launch a competitive set of mobile money products. This enabling regulatory environment extended the benefits of sending and receiving money electronically to a broad segment of society that had previously been excluded. In the first month, over 300,000 customers signed up to ez Cash, and after a year it had more than a million customers. In May 2013, 330,535 transactions were conducted through ez Cash with a total value that exceeded Rs435 million ($3.32 million). 23

24 Case study: Philippines The key issues: The Philippines is an island nation with a population of 92.34m spread over more than 7000 islands. In late 2007, just under two thirds of the population were mobile subscribers and the Philippines was called the texting capital of the world. Only 31.3 per cent of Filipino adults have a formal account (Findex 2014). 36 per cent of municipalities do not have a banking office (NSFI 2015). 24

25 Case study: Philippines The approach: When mobile operators Globe and Smart approached the Bangko Sentral ng Pilipinas to offer mobile money services, the BSP was willing to hear their case and work closely with them to understand the service so it could test and learn. Satisfied with the experience and soundness of these non-banks, as well as the management of security risks, the BSP Monetary Board granted preliminary approval letters to Globe, the non-bank, to launch the service with conditions around reporting, reconciliation of the float, and supervision. In 2001 and 2004 respectively, Smart communications launched SMART Money in partnership with Banco d Oro and Globe Telecom launched Gcash. In 2009, comfortable that no major risks had materialised, the BSP codified its approach, permitting both banks and non-banks to issue electronic money. Via Circular 649, it offered guidelines governing the issuance and operations of electronic money in the Philippines. E-money is not a deposit, is redeemable at face value, and is compliant with the Anti Money Laundering Act. There are monthly limits on the total accumulated cash value. 25

26 Case study: Philippines The outcomes: Although there are an estimated 7million+ mobile money clients in the Philippines, only 4.2 per cent of Filipino adults have a mobile money account. The presence of other FSPs, such as pawnshops, remittance agents, money changers, e- payment service providers, mobile banking agents and NSSLAs reduce the percentage of underserved municipalities from 36% to 12%. (NSFI 2015) On the frontier of mobile money: both Smart and Globe are evolving their mobile money service offerings to grow the ecosystem by offering merchant payments, companion cards and connections with transport payments. In late 2015, the two operator-led mobile money schemes are moving towards account-toaccount interoperability, The role of non-bank providers is recognised by the BSP, evidenced by participation in the ongoing National Retail Payments Strategy and the National Financial Inclusion Strategy (2015) 26

27 The regulatory architecture Service Channel Outsourcing rules? Who can be an agent? Who can use agents? What conditions? Payment Instrument Who can be an issuer? What conditions? Processing location? Use of mobile? Rules for cards? Store of Value Where are funds held? Which entities? What legal treatment? Consumer Mobile Money MNO Mobile money platform Processing platform Agent Mobile Money MNO Risk-based Know Your Customer (KYC)? Remote account opening? Combating Funding of Terrorism (CFT) Anti Money Laundering (AML) Redress mechanisms? Disclosure requirements? Consumer Protection Source: BFA 27

28 The regulatory architecture Indicators In most circumstances, the store of value account will most likely be held by a third party trustee, escrow or bank providing trust or custodial services Ultimately trust or escrow accounts held in licensed banks Accounts can either be funded by individual bank accounts or e-money accounts issued by banks or other non-bank financial institutions 28

29 The regulatory architecture Indicators Conditions are specified for the issuance of the instrument Interconnection is prioritised as a necessary condition for retail payment systems Specifications exist around which entities and where transactions can be processed Specifications exist around where, and by whom, clearing and settlement can occur 29

30 The regulatory architecture Indicators Non-bank agents may be appointed to register new customers and to provide cash in and cash out services Agents are able to perform Customer Due Diligence/Know Your Customer 30

31 Key regulatory principles Open and level playing field Interoperability and ecosystem development Store of value and safeguard of funds Key regulatory principles Consumer protection Customer due diligence Distribution and outsourcing 31

32 Principle 1: Open and level playing field To unleash the potential of mobile money, regulators must create an open and level playing field that allows both banks and non-bank providers to offer mobile money services. Regulation should thus be FUNCTIONAL: designed by type of service or by category of products (not discriminatory) PROPORTIONATE: calibrated according to the risks that each service poses 32

33 Advantages that mobile operators have Mobile operators have a significant advantage over any other player in the digital financial services space because they possess key assets. Distribution Channel Mobile money users can cash in and cash out at a network of independent agents, leveraging existing airtime distribution channels Proprietors of the Mobile Channel Mobile operators can put mobile money applications directly onto the customers SIM card, or use their USSD channel, to enable customers to securely send money, pay bills, save etc. Trusted Brands The prevalence of mobile communications, even in the most rural areas, has meant that mobile operators possess brands that customers are familiar with and trust a huge asset for the introduction of financial services Investment Incentive Mobile operators have the right incentives to invest in mobile money because of potential churn reduction and savings in air-time distribution 33

34 Principle 2: Store of value and safeguard of funds The risk of mobile money customers losing the money they have stored in the system is mitigated if: 100 per cent of the cash backing mobile money is held in trust in a fully prudentially regulated institution, such as a bank or an monetary financial institution (MFI), or in more than one institution (depending on the stage of development of the deployment) the non-bank mobile money provider does not intermediate the funds customer funds are isolated from the issuer s funds and protected from claims by the issuer s creditors 34

35 Principle 3: Customer due diligence Proportional anti-money laundering (AML) and combating the financing of terrorism (CFT) regimes, as well as simplified risk-based customer due diligence (CDD) requirements are crucial for customer adoption of mobile money. Financial inclusion and financial integrity FATF Ministers stated that financial exclusion represents a real risk to achieving effective implementation of the AML/CFT recommendations. This formally recognises that for FATF, financial inclusion and AML/CFT pursue mutually supportive and complementary objectives: the application of measures which enable more citizens to use formal financial services will increase the reach and the effectiveness of AML/CFT regimes. Bjorn Aamo, former FATF President 35

36 Proportionate AML/CFT regulatory regimes examples Philippines: uses differentiated ID Fiji: entry level accounts require no ID; a letter from a chief is sufficient Sri Lanka: accepts SIM registration data as sufficient for entry level accounts Kenya: M-Shwari bank partner leverages on SIM registration data but required to independently verify ID 36

37 The FATF 2012 risk-based approach The Financial Action Task Force (FATF) recommendations outline measures that countries, financial institutions, and certain other businesses and professions should adopt to counter money laundering and the financing of terrorism. 37

38 Comparative analysis of risks of mobile money versus risks of cash Vulnerabilities Compensation measures Risk factor Risks of cash Risk factor Anonymity: customer identity is unknown or not verified Transactions are linked to a unique mobile number Location data of SIM available Transactions time stamped and recorded Data available to law enforcement to assist with investigations * Anonymous. No unique identifier and not traceable *** Elusiveness: ability to disguise amount, origin and destination Transactions are linked to a unique mobile number Location data of SIM available Transactions time stamped and recorded Data available to law enforcement to assist with investigations * Elusive. No unique identifier and not traceable *** Rapidity: real time transactions allow for rapid layering Lack of, or poor oversight: poor oversight may make the service attractive for money laundering and terrorism financing Real-time transaction monitoring Limits on transaction size and account balances Data available to law enforcement to assist with investigations ** Mobile money providers are directly or indirectly (through bank partner) regulated or supervised * Slower than mobile money ** No oversight. Cash transactions lack oversight *** 38

39 Principle 4 Distribution and outsourcing (agents) Agents operate on a prepaid model, eliminating risk What are mobile money agents and why do they matter? Agents facilitate the important cash-in and cash-out transactions (at a minimum) by converting physical money to e-money and vice-versa. In over the counter services they also facilitate other transactions. In many cases, agents also perform registration of users in the first instance Agents are also key for branding and education, as they reinforce marketing communications and help with the customer journey Agents are also the human-face of the mobile money network and provide the reach necessary to give the service vast geographical coverage. This is because mobile money agent networks can encompass thousands of agents. 39

40 Why do agents matter? Liquidity management Shape customer opinions Customer education Brand equity and below-the-line marketing Human touch 40

41 Agent due diligence and supervision Agent due diligence is an ongoing process, necessary to track and monitor agent networks as they develop The agent risk profile should inform the due diligence, or Know Your Agent (KYA) strategy Risk Profile Step 1: Identify risks associated with agents KYA Strategy Step 2: Ensure that due diligence procedures address the risks Agent management and supervision Step 3: Develop a framework for a riskbased tracking and monitoring system 41

42 Principle 5: Consumer protection Tailored guidance from the regulator can help mobile money providers to improve transparency in their relationships with customers: Clear and accessible terms and conditions Language of instruction used by majority Display of pricing tariffs Customer redress mechanisms Protection of customer funds Fraud prevention 42

43 Principle 6: Interoperability Mobile Money Services Mobile Money Interoperability Policymakers should enable market-led solutions, ensuring that interoperability brings value to the customer, makes commercial sense, is set up at the right time, and regulatory risks are identified and mitigated. Individually-driven mobile money services Common payment standards 43

44 Interoperability: what does it mean? Wallet to Wallet Wallet-to Bank Account Wallet to POS POS debit from Wallet Wallet to ATM Cash-in at off-net Agents Cash-out at off-net Agents Common APIs for third parties 44

45 Interoperability and industry collaboration Number of live and interoperable mobile money services, by country (December 2015) One mobile money service Two mobile money services Three or more mobile money services Interoperable markets 45

46 The role of policymakers in building an interconnected mobile money environment Be the facilitator Assess and understand appropriate timing Identify regulatory risks Foster healthy competition 46

47 Market Readiness When is a market ready for interoperability? Conducive regulation Enabling (functional and proportional) Stable Market Maturity (quantitative indicators) Customer activation Quality of the distribution network Competition Readiness Provider(s) Maturity (quantitative indicators) Customer activation Quality of the distribution network Provider(s) capacity/willingness to Priotitise Interoperability Against Other Issues e.g., OTC to wallet migration Implementation of other A2A partnerships Platform migration Market Readiness Mandated interoperability without considering market readiness often leads to withdrawal of investment in the mobile money business as has been noted in some markets Grey: Actual ability of the provider(s) to commit the necessary resources to the interoperability process 47

48 Lessons from A2A interoperability in Tanzania Bank of Tanzania did not mandate interoperability Marketing (publicity) exponentially increased awareness and uptake in all directions 48

49 The digital financial services ecosystem 49

50 Ecosystem development The industry is still dominated by narrow use cases (P2P & airtime). Global product mix by volume and value (December 2015) Transaction volumes Transaction values P2P transfer Bill payment Bulk disbursement Merchant payment International remittance Airtime top-up 50

51 Cross border mobile money transfers 51

52 Enabling factors for cross-border transfers Dialogue Harmonisation of practices, rules and limits Governance transparency Viable business case 52

53 Mobile money access channels Mobile phone apps are now the second most common access channel after USSD. Comparing bank access to smartphone adoption, by country (2015 vs. 2020) Country with at least one provider offering an app Country where no providers currently offer an app Country with at least one provider processing more than 15% of volumes via app 53

54 Economic impact: evidence from Kenya 27.7m subscribers transacting $72.1m per day Mobile payments in comparison with overall payments 80 per cent of transaction volumes 7.4 per cent of total value 54

55 Micro economic impact of mobile money Mobile money reaches the poor The share of poor households who have M-PESA went from 28 per cent in 2008 to 51 per cent in Rural households with an M-PESA account went from 29 per cent to 59 per cent. Unbanked using M-PESA went from 25 per cent to 50 per cent. 41 per cent of Easypaisa s users live on less than $2.50 per day. Number of users living on less than $1.25/day (outside Nairobi) increased from 20 per cent (2008) to 72 per cent (2011) and it helps them weather financial shocks Share of unbanked who used M-PESA rose from 21 per cent (2008) to 75 per cent (2011) M-PESA users were able to fully absorb large negative income shocks without any reduction in household income whereas statistically comparable non-users saw consumption fall on average by seven per cent. 55

56 Impact on monetary policy 1 2 The evolution of the velocity depicts different regimes financial development and less cash changing hands. 3 4 Source: CBK 56

57 Impact on monetary policy Money multiplier has been rising The declining velocity and the unstable money multiplier imply that the money demand is unstable this has implications for the monetary policy framework. Source: CBK Prof. Njuguna Ndung u, former Governor, CBK 57

58 Impact on monetary policy A declining ratio of currency outside banks to M3 and Reserve Money (RM) has been observed this has improved efficiency of monetary policy. Changes in behaviour of holding cash - people are keeping less and less money outside of banks. 58

59 Impact on monetary policy Kenya s financial depth has been rising with increasing financial inclusion 59

60 Impact on monetary policy Does mobile money portend any risk to overall financial stability? 60

61 Other evidence of economic impact Consumption Certainty Opportunities for employment Growth in tax revenue Efficiency gains Ability to weather economic shocks Case study on efficiency gains: UMEME, Uganda 99.1% revenue collection rate in 2014 attributable to increase in mobile money payments 61

62 In conclusion 62

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