When consumers install software on their devices, they often perform some sort of risk evaluation, even if they don’t consciously realise it. They might consider who provides the software, whether it is from an app-store, what social media says, and whether they have seen any reviews. But what if once a piece of software had been installed, the goalposts moved, and something that was a genuine software tool at the time of installation turned into a piece of malware overnight.
This is what happened to approximately 300,000 active users of Chrome ad blocking extension Nano Adblocker. You see, at the beginning of October, the developer of Nano Adblocker sold it to another developer who promptly deployed malware into it that issued likes to hundreds of Instagram posts without user interaction. There is some suspicion that it may have also been uploading session cookies.
I recently had the pleasure of “attending” theLendIt Fintech – Europe 2020 virtual event. Now, much of the content covered banking services for Small and Medium Enterprises (SMEs), an area that personally I’m not particularly familiar with, but one that is gaining more focus in the news of late. One thing that struck me was the potential disruption of traditional business banking brought about by open banking.
The new administrations in the UK and USA are apparently planning to work together to create a new transatlantic America First / Buy British trade alliance. This will, it seems, include financial services.
A deal to reduce barriers between American and British banks through a new “passporting” system was being considered by Mr Trump’s team
Now what this passporting might mean is anyone’s guess, since this is just a newspaper story based on gossip, but I think it might be a little more complex to arrange than it seems at first because of the nature of banking regulation in the United States. If a British bank were to get a US banking passport this would presumably be equivalent to the implicit granting of a national bank charter and state regulators do not seem enthusiastic about the granting of more national bank charters. We know this, because at the end of 2016 the US Office of the Comptroller of the Currency (OCC) said that it was going provide a new national bank charter for fintech companies.
“The OCC will move forward with chartering financial technology companies that offer bank products and services and meet our high standards and chartering requirements,” said Comptroller of the Currency Thomas Curry
The reason for wanting to do this is obvious: right now, if I want to create a competitor to Venmo or Zelle, I have to either have to be regulated as a payment processor and have regulated banks involved or go and get regulated by 50 different state regulators under 50 different regulatory regimes, most of which remain rooted in a previous, pre-internet age. This seems anachronistic. Surely an American company should be able to a get a licence and get going. Well, the OCC’s proposal is attracting a lot of negative comment.
A turf war is brewing between US state and federal regulators over oversight of the financial technology sector after New York’s top watchdog sent a stinging letter to the Office of the Comptroller of the Currency (OCC), telling it to back off plans for a national bank charter for fintech firms.
Now I saw a few comments about this and other responses from state regulators that cast them in the role of Luddites standing in the way of progress but I have to say I agree with them. I mean, I am not a lawyer or anything, I don’t really understand US banking regulation and I couldn’t make any sensible comments on the proposals myself, but I think that the US regulatory environment is broadly speaking unfit for purpose and might benefit from at least a cursory examination of the direction of regulation in one or two other jurisdictions including Europe, for example and India.
The fundamental problem with the OCC proposals to my mind is that they are about a national charter for banking as a whole. They do not distinguish between the payments business and other parts of the banking business. Hence the charter means extending systemically risky credit creation activities in new directions. I don’t see any immediate problem that this solves. And the state regulators may well be right that it potentially makes the problems associated with banking regulation much worse.
Connected to this is the worry that a national charter would encourage large ‘too big to fail’ institutions – a small number of tech-savvy firms that dominate different types of financial services simply because they are able to get a national charter.
Whatever you think about Facebook they are not too big to fail. If Facebook screw up and lose a ton of money and go out of business then that is tough luck on their employees and their shareholders but it’s nobody else’s problem. That’s how capitalism is supposed to work. But if Facebook obtained a national banking charter they would immediately become too big to fail and no matter the greed or incompetence of their management, the government will be on the hook to bail them out just as the Roman senate was forced to bail out the banks there two millennia hence.
(In case you are curious, in 33BCE the emperor had to create 100 million sesterces of credit (a trifling couple of billion dollars in today’s money) through the banks to save them from collapse. Plus ca change, as they didn’t say in Ancient Rome).
If you look at what is happening in other jurisdictions, what you see is a separation of payments and banking so that the systemically less risky payment activities, which many people see as somewhat less than optimal in the world’s largest economy, can be reinvigorated while the systemically more risky credit business and investment banking business are left alone. In the European Union there is the regulatory category of the payment institution (PI). In Europe, Facebook is therefore a payment institution and not a bank. They don’t want to lend people money, they want to facilitate buying and selling and for that they need access to core payment systems and that’s all to the well and good. Similarly, in India, the regulator created the new category of payment bank (PB) so that mobile operators and others could start providing electronic payment services to what will soon be the world’s most populous nation.
The reasons for going down this path are entirely logical. If you leave innovation to the banking system then you end up in the situation of India as was or Nigeria as it is. A huge population, phones everywhere, talented and entrepreneurial people, huge and unfulfilled demand and… Nothing happening. I’m sure you’re all utterly bored with me reminding you, but the key innovations in technology in banking do not originate in banks. That’s the nature of the beast. The four digit PIN code was invented by a Scottish engineer. The payment card was invented by New York lawyer. M-PESA was invented by a telco. Bitcoin was invented by… Well, for all I know, it may well have been the head of Citibank or programmer number 2216 in the North Korean army, but you get my point.
This is why I think that the OCC should leave the regulation of credit institutions where it is now and propose instead a new national charter for payment institutions amalgamating the European PI and Electronic Money Institution (ELMI). Allow these American Payment Institutions (let’s shorten this to APIs to avoid confusion) to issue electronic money but not to provide credit, allow membership of payment schemes (e.g., the UK’s Faster Payment Service, Visa and so on), ensure customer balances are held in Tier 1 capital and so on. This way, Apple and Verizon can apply for a national charter and start providing competitive payment services that will benefit businesses and consumers and the existing banks will just have to suck up the loss of payment revenues for the greater good.
The passporting of such institutions should be much less controversial than the passporting of credit institutions. Surely it will be to everyone’s benefit if the “fintech” passporting agreements give UK and EU payment institutions the right to operate nationally in the United States, in return giving recipients of my proposed American Payment Institution charter the right to operate in the UK and EU? This would allow innovation and competition in the fintech space without creating yet another financial time bomb that bankers will inevitably trigger.
A few years ago, I wrote that when it came to the regulation of payments, America could do worse than adopt something along European lines. By “European lines”, I meant that a regulatory framework which separated systemically risky operations such as lending people money from systemically unrisky operations such as low-value payments would benefit all concerned.
The US has no equivalent of the EU’s Payment Institution (PI) licence, but this would be a practical way to allow new entrants access to the infrastructure needed to deliver great new products and services.
These special limited-purpose national bank charters (I can’t think of a snappy name for them yet – I want to call them “near-banking” licences because they allow you to do some of things that banks do) mean that fintech companies can apply for a national licence instead of having to apply for licenses in every state. So if you want to offer some form of payment service, you will no longer have to apply for 50 (different) state money transmission licences.
Fintech firms that can apply for an OCC charter must offer at least one of three financial services: make loans, pay checks or receive deposits. The OCC is currently developing guidelines for a fintech bank charter that will be based on the comments received from the proposed paper.
Were I to comment on the proposed paper, I would focus on the first of these financial services. It is the provision of credit that is the systemically risky service and it is this service that requires strict regulation. I make no comment on the issue of whether this should be dealt with at the federal level or state-by-state, but it does seem to me that if the proposed special fintech banking charter were to exclude this activity then it would create a regulatory category that is much more like the European Union “payment institution” or the Indian “payment bank”. I don’t know what other people think about this but I think that the European Commission’s general drive to separate regulation of payments from the regulation of banking makes a lot of sense and is founded both in sound regulatory strategy and economic theory. It’s the right way to go.
we can see a “back to the future” roadmap where banks go back to savings and loans and the “pooling” functions needed to support a modern economy, non-state actors provide money and — and most importantly in the short term — third-parties provide payment systems. In Europe, the regulatory wind is already in these sails.
To begin with an obvious example, Facebook recently obtained licences in Europe to operate as a Payment Institution (PI) and as an electronic money institution (ELMI). The regulatory burden of complying with these licenses is very limited compared to complying with a full banking licence, which is good for both Facebook and its customers who will be offered innovative new services through the platform (sending people money using Facebook as a front-end to national and international payment networks, allowing people to carry stored value accounts in Whatsapp and who knows what else).
The notion of a special-purpose charter has also drawn concerns from some consumer groups who want to ensure all of the banking and fair-lending laws apply to fintech firms and banks that fear they would lose business to fintech if they had to compete within the same banking system.
I am not an expert on consumer lending but I would have thought that the concerns of consumer groups in this area are perfectly reasonable and that the simplest way to satisfy those concerns is to keep the provision of credit with existing institutions that are tightly regulated in that regard. Therefore I would comment to the OCC that if they want to encourage more competition in lending it should be through a separate kind of special charter.
But back to the rest of the special-purpose charter. As to the concerns of the banks that they will lose business, well, tough. The purpose of the financial services regulatory environment is not to maintain the status quo and to defend incumbents against competition of all kinds across time. If some banks are concerned that the new special-purpose charter “banks” will be able to deliver payment services at a much lower cost (which I sincerely hope will be the case) then the rather obvious strategy is for these banks to form a subsidiary to handle payments and to have that subsidiary regulated through the same special-purpose charter as their competitors.
This may not be enough to save them, by the way. Thomas Watson Jr is often quoted as saying in 1943 (*) that there was a world market for five computers. It turns out that he was right: they are Apple, Amazon, Facebook, Google & Microsoft and everything else is just a window into those. (I think Thomas was wrong – he didn’t forsee WeChat or Alipay – but you get the drift.) When these “internet giants” get their special-purpose charters, they will control both the customer interface and the financial system interface. Why will I ever come out of Facebook and run my bank app ever again? If my Mac’s “Messages” application can send money to your WeChat, what will happen to Transferwise? If I google “PayDay Loan” and the money arrives in my gmail account before you can say “where is the 21st century anti-trust legislation” what will happen to competition in the lending space? What happens why Microsoft asks you add to your bank account to LinkedIn and can then offer both “request to pay” and instant payments on the platform?
On final note, most of the commentary I read about this over the weekend focused on the ability of these “Internet giants” to obtain these charters and deliver payment services. There are, however, plenty of other types of organisations that might want to obtain one of these charters in order to provide financial services that either compete with lazy and fat incumbents or deliver innovation into new or underserved niches. AT&T could get a licence and launch USA-PESA. NetFlix could get a licence, join Visa and then issue its own credit cards. But if I were to grab my crystal balls and get all Nostradamus on your asses, I’d say keep an eye out for the retailers. If I was Walmart, I’d be thinking about getting me one of those special-purpose charters myself so that I could operate my own payment services without having to have a joint venture with banks (e.g., its partnership with GreenDot) or go through the expensive process of getting a subsidiary regulated as a bank.
In the late ’90s and early ’00s the company made numerous attempts to get into banking after it argued that the 1999 Financial Services Modernization Act allowed nonbank commercial operations to acquire financial services companies and operate their own banking operations. It failed to acquire a bank in Broken Arrow, Okla., in 1999, and its attempt to acquire a bank in California led to the state legislature to pass a bill specifically outlawing what is arguably permitted by the controversial banking deregulation bill signed into law by then-President Bill Clinton.
As I said back in 2011 when someone asked me who might become the Walmart of payments, I said Walmart. The OCC move brings this one step closer! My reasoning was obvious: the customer interface. Retailers are where the customers are and is where they make their payments. Right now if you want to use Walmart Pay you have to register a card, but there’s no reason why Walmart Pay couldn’t, as a bank, instruct the transfer of funds directly from your bank account.
Who knows what the result of the OCC consultation process will be, but on the whole I think that the notion of the special-purpose charter that makes it easier for non-banks to come into the space and compete is a good one. With Venmo up and running, the big banks launching Zelle, NACHA going to same day, The Clearing House launching instant payments and others, I’m sure, just around the corner with their blockchains and cybercurrencies and so forth, we are about to see the US landscape transform, much to the benefit of the users of the payment system.
(*) He never said this, but let’s not spoil it for all of the management consultants who like to put this on a slide about innovation.
I’m in Frankfurt for the annual PayComm MEETS Europe, my chance to catch up with practitioners from the continental card markets. It’s really hard to keep up with all of the change in the market, driven primarily because of the regulation rather than new technology. The pace of regulatory change seems relentless. A few years ago, I took part in an panel discussion about payments and regulation and innovation in Brussels. I remember it quite well because of my excellent fellow panelists and because of the nature of the discussions that followed. The panelists and topics, not that they are terribly relevant to the rest of this post, were:
Dave Birch, Consult Hyperion: Conditions of consumers acceptance of e- and m-payments Roy Vella, Mobile services advisor: Potential of mobile technology in the area of payments Alice Enders, Enders Analysis: Monetising digital content: electronic and mobile payments as means to reach the consumer Katarzyna Lasota Heller, EDiMA (European Digital Media Association): Online retailers view on consumer expectations towards e- and m-payments Stacy Feuer, US Federal Trade Commission. US regulatory perspective
In those discussions, I put forward a suggestion taking from Norbert Bielfeld’s superb December 2011 Working Paper “SEPA or payments innovation: a policy and business dilemma” [PDF] for a five year “legislative holiday” around payments to let the effects of the Payment Services Directive (PSD) and so forth settle down, so nothing would change until around now. That never happened, of course, and the Commission pressed forward with a regulatory agenda, one significant part of which was the reform of the card payment market in Europe. Now, setting to one side that I have always favoured a competition agenda and regard interchange caps as inappropriate and counterproductive price-fixing, these reforms are beginning to impact the market.
How? Well, I remember that when he was speaking at this event last year, Peter Jones from PSE gave an excellent presentation on the impact of the new European card regulations on the different players in the payments game. You won’t be surprised to hear that I agree with his fundamental conclusion that the regulations represent a victory for merchants over banks and demonstrate the importance of having a concerted and coordinated lobby. He went on to say, and I hope my scribbled notes on this are accurate, that the commission don’t fully understand the impact of the changes that they have made. (I might be tempted to add that I’m not sure that any of us really do because of the chaotic nature of the changes.) These changes will inevitably have some unexpected consequences and it is part of the fun in the industry at the moment trying to guess what these consequences might be. I had not, for example, realised at that time that the reform of licensing on a pan-European basis means that Amex and Diners will have to restructure their franchise models.
I won’t take you through a detailed analysis of the changes that occurred last year and the final set of changes to come into place this month except to say that they will trigger have started to change the structure of the European cards industry. This is not inherently bad for everyone, of course. Chaos is a ladder, as they say, and Peter’s presentation alluded to opportunities that might arise from the enormous changes that will take place. Peter for example, said that he could see to pan-European “common carrier” real-time networks evolving from the impending separation of brand and processing for the international card schemes and suggested that with good strategies the debit portion could emerge into a pan-European immediate settlement system.
However, this year I want to focus on two of his conclusions that I think were both correct and of tremendous importance. I think that they might not have been recognised as such by some stakeholders who were focusing on the reorganisation of the card business rather than the larger context. These conclusions are entirely congruent with the strategic perspectives that we shared with our clients and, as I down to PayComm 2016, I think it’s worth opening them up for discussion again.
As we have long advised our clients, a working push payment infrastructure (ie, smart devices and an immediate settlement network) means that a lot of day-to-day payments will shift to the infrastructure).
The first is that the heavy regulation of interchange-based card products will mean energy, investment and imagination being directed into non-card credit products, a driver that I have referred to before as the “push to push”. It is hardly a surprising prediction that banks and others will want to develop businesses that offer higher margins. As the margins on the card business are regulated down the ability to offer rewards, cutback, loyalty and other services is necessarily restricted. If mobile-centric account to account payment services can deliver better functionality and more attractive propositions to customers then the merchants will have to take them and pay more than for card products.
The second is that the payment services directive provisions on open access to payment accounts that we have discussed several times before on the blog will mean that (unless they are totally insane) banks will compete to offer what our Australian cousins call “overlay services” in order to compete with non-bank overlay services. Such value added service providers will use the account information service provider (AISP) APIs and the payment initiation service provider (PISP) APIs to deliver services to their customers. Now this has a number of strategic problems for banks to wrestle with. Banks are naturally concerned about third-party access to accounts relegating them to the role of commoditised, utility pipes for money because “over the top” players such as Facebook, Apple, Google and the other usual suspects will form a layer between the banks and their customers. But of course some banks might move aggressively to form the layer between other banks and their customers by providing better API services to those over the top players or they might decide to specialise in particular areas of the business and make themselves more attractive to customers in those niche is.
During the excellent PayComm workshop on instant payments, led by Andy Makkinje from Equens, a couple of people touched on the impact of these two trends (i.e., the push to push together with API access for PSPs) together. A working instant payment infrastructure, that is opened up because of the API access to banks, is very likely to become the dominant retail payment system, certainly for e-commerce (which is where all of the card fraud is in Europe). It will be the simplest, cheapest and most pervasive solution to the payments problem, and it’s nearly here. If you look around Europe the trend is unstoppable. The reform of the card market may well be the end of the card market as we know it.
Well. The lovely people from FinTechStage, principally my old friends Matteo Rizzi (who was one of the co-founders of SWIFT Innotribe) and Lazaro Campos (who used to run SWIFT), persuaded me that Consult Hyperion’s more technological perspective on the potential for shared ledger technologies (SLTs) in financial services might be of interest to the delegates at FinTechStage Luxembourg in February. So off I went to dinner with, amongst others, the Minister of Finance for the Grand Duchy of Luxembourg, Pierre Gramenga. Indeed, I found myself sitting next to Pierre who, it turns out, is a very smart and interesting person. Unlike our own Minister of Finance, he is actually an economist and he spent a decade as the Director General of the Luxembourg Chamber of Commerce so he understands the relationship between regulation and business very, very well.
Since I’d been chatting to Pierre, when I was asked to give a few words about the potential for SLTs to the assembled CEOs I decided to put my prepared remarks to one side and talk instead about the way in which Ministers of Finance can change the course of history. I used the example of the Golden Horde to make my point.
When Genghis Khan took control of China in 1215, his fiscal policy was confused. His pacification plan was to kill everyone in China, no small undertaking since China was then, as now, the world’s most populous country. Fortunately, one of his advisors, a man who ought to be the patron saint of Finance Ministers everywhere, Yeliu Ch’uts’ai, pointed out that dead peasants paid considerably less tax than live ones, and the plan was halted. Under Pax Mongolia, China prospered. In 1260, Genghis’ grandson Kublai Khan became Emperor and with his financial advisors determined that it was a burden to commerce and taxation to have all sorts of currencies in use, ranging from copper “cash” to iron bars, to pearls to salt to specie, so he decided to implement a new currency.
A paper currency.
This must have been as shocking to contemporaries as the idea of digital currency is today. It was certainly a shock to Marco Polo, who wrote about it in his travels (I expand on this in a piece on Medium).
I explained to the Minister and the CEOs that Kublai’s monetary policy was refreshingly straightforward and robust. If you didn’t accept his new paper money, he would kill you. Naturally, in a short time, the new single currency was established and paper money began to circulate instead of gold, jewels, copper coins and metal bars. I wasn’t suggesting that Luxembourg institute capital punishment for those refusing to accept Bitcoin, but I was suggesting that a juridiction such as the Grandy Duchy might want to explore creating new kinds of financial markets founded on shared ledger technologies and the ambient accountability that will, as my colleague Salome Parulava puts it, dissolve the boundaries between auditing and compliance to the form a better, cheaper and safer market for asset management, transfer and settlement.
I think it went down OK.
Dave Birch gave one of the the most hilarious and original talks I ever listened to.
Matteo is much too kind, of course, but it was a fun event. One thing I particularly enjoyed (and this is a genuine sentiment) was disagreeing with my old friend Chris Skinner. Chris gave a thought-provoking presentation around his new book “Value Web”
Using a combination of technologies from mobile devices, wearables and the bitcoin blockchain, fintech firms are building the ValueWeb regardless
Chris’ thesis is that out of the blockchain of bitcoin will come a new shared database on the internet that banks will use that will be far cheaper and more geared to real-time than the proprietary structures they use today, but I think I disagree. Whether the blockchain is either instant or free I will leave as an exercise for the reader, but in my presentation on SLTs I chose to focus on a different set of emergent properties around transparency. My point was that even if the blockchain, to use Chris’ example, isn’t cheaper or more real-time than current asset transfer, clearing and settlement systems, it delivers a win-win-win for customer, service providers and (crucially) regulators. I made similar point when I was invited to take part in Lazaro’s panel with Simon Taylor of Barclays and Jon Matonis, formerly of the Bitcoin Foundation.
We didn’t agree about everything either. I think audiences get bored with bland backslapping on stage. Personally, I learn more from seeing smart people disagree about something than I do from sitting through a bunch of marketing slides. So, as you can imagine, I was delighted to be invited by Chris to take part in tonight’s Financial Services Club debate.
For the past year, banks have become really excited about blockchain technologies. The claim is that these technologies will allow banks to create instantaneous exchange over the internet for near free. But is this true?
Under Chris’ guiding hand as chairperson, I’ll be debating the issue with Jon and trying to convince the audience that financial services organisations should be learning about, playing with and planning for SLTs whatever they think about the speed or cost of the blockchain (or, indeed, a blockchain).
I’ve written before about the Indian environment and what the Reserve Bank of India (RBI) called its “calibrated” approach to mobile payments, beginning with strict regulation back in 2009, and how it failed to unleash the latent demand from Indian consumers or the inherent enterprise and creativity of Indian businesses. We are familiar with the stories of mobile payment use in, say, Kenya or China. But India has been lagging, and I have always thought that it was the regulatory environment that was to blame.
In India, where 22 percent of the world’s unbanked reside and over 900 million mobile phone connections exist, 0.3 percent of adults use mobile money.
That is not to say that nothing is happening in India! That’s not true at all (and in fact a Consult Hyperion team was in Mumbai last week working with a client in the payments field). But I think it is fair to say that India has not yet fulfilled its potential in mobile payments. In fact, a couple of years ago it was clear to many people that the India was missing out because of this and that something would have to be done to allow the multiple benefits of mobile payments to spread in the country. Mobile payments have a key role to play in financial inclusion and this is vitally important to India, so the lack of progress was becoming a social and political issue. Back in 2013, there was an article in the New York Times titled “Mobile Payment Startups Face Reluctant Indian Consumers” that I suggested at the time should really have been titled “Mobile Payment Startups Face Reluctant Indian Regulators”! I never thought the sticking point in India was the lack of consumer demand.
In their book “Financial Inclusion at the Bottom of the Pyramid”, Carole Realini and Karl Metha look at the issue of financial inclusion in India in some detail. They note that the previous approach towards national financial inclusion there was to use “business correspondents” (i.e. banks were to use third-party non-bank “BC” agents to deliver services) and have an interesting case study on Eko, one such BC. I couldn’t help but notice that the most widely-used EKo services is domestic remittance, which is a payment application in my eyes and not really a banking application at all. So while, as Carole and Karl note, India may have relatively few bank accounts but a lot of mobile phones, it is not in my view the natural corollary to imagine that getting people to open bank accounts and then access those bank accounts using those mobile phones is a way forward. This isn’t just my opinion: the figures show that it is not the optimum route to inclusion. More than half of the 160m bank accounts created in the Indian government’s most recent account opening drive have never been used and at cost of $3-$4 to open and maintain, that’s a lot of wasted money. Most consumers, most of the time, need payments not banking.
Unbanked, as we say, is not the problem and banked is not the solution. Therefore I was very happy to see the steady relaxation of the Indian mobile payment regulations. This culminated last year in the decision to create a new category of finanicial institution (similar to the approach adopted in Europe) and issues licenses to these new “payment banks”. I am sure that the competition and innovation that these non-banks will bring to the Indian market will lead to a pretty rapid increase in the use of mobile financial services there. Payment banks can:
Accept deposits from individual customers with a maximum limit of Rs. 1 lakh (around 1,300 euros).
Issue debit and ATM cards for transactions but not credit cards.
Allow transactions through Internet and leverage technology to offer low cost banking solutions.
Importantly, a key to overall systemic risk evaluation is that a payments bank cannot undertake any lending activity. This makes it possible to expand the systemically less risky payments business while keeping the systemically risky core banking credit activities under control. Anyway, news has now arrived to the effect that the RBI has now granted the first 11 licenses in this category to a variety of fintech, tech and telecoms companies and consortia.
Among the successful bidders are telcos Vodafone M-Pesa and Bharti Airtel, tech firms Fino PayTech and Tech Mahindra, the Department of Posts, and Vijay Shekhar Sharma, the founder of m-commerce outfit Paytm.
I think this is unreservedly good news. The Indian market will now grow and Indian entrepreneurs will create services to deliver across the social spectrum, the Indian mobile payments industry will expand and a new non-bank financial services industry will grow up innovating around products and services.
The UK’s new Payment Systems Regulator is now open for business. I imagine that their highest priority work stream will be around access to payment systems, because this is what “challenger” banks need in order to create the more competitive environment that the UK Treasury wants.