A New Wave of E-Money in Latin America
For a region where the banking sector is highly rooted in the economy, to think about non-bank issued electronic money is almost heretic. In this part of the world, money is the business of banks. Banks think so. And most regulators think so too. But things are changing fast.
Sustained economic growth in Latin American economies has led to the development of retail and telecommunications industries with large number of access points and significant cash management infrastructure reaching deep all across segments and geography. Because banking penetration, though high, is focused in middle and upper urban class, the prospect of reaching many poorer, unbanked citizens away from large towns remains the promise of this alternative infrastructure beyond the banking system.
One of the key changes that might accelerate this “second wave” is enabling non-banks to issue electronic money (eMoney). This will allow a non-bank company to offer an electronic wallet (in many cases associated with mobile) where a person could store money, pay and exchange money with others, similar to how a banked customer uses a current account attached to a card. Although today, even without eMoney regulation, a number of bank-telco partnerships are out there with live products in a number of markets, partnerships across large players with seemingly different interests and market strategies are hard to cement and often lack the nimbleness needed to penetrate the market effectively.
Three markets are leading the pack allowing non-banks to issue eMoney – Bolivia, Perú and Brazil. Three other countries have prepared drafts for this and are already into the process of consultation – Colombia, El Salvador and Paraguay. México does not seem to have specific plans for this, but has provisions within the banking law that in practice could regulate non-bank eMoney issuers in a way that is similar to how they are regulated in the other LAC countries.
Three distinct forms of regulating electronic money seem to be emerging:
- In one extreme, electronic money is considered a bank deposit and can only be issued by banks, but a provision in the banking law allows the creation of specialized banks with “lighter” regulation. For example, in Mexico, non-banks can acquire a special banking license for issuing payments instruments, under which less capital is required and less reporting burden than what is required from banks. The benefit of this “payments bank” is that it integrates naturally with the rest of the banking infrastructure (card/ATM switches, EFT), and “inherits” the rest of the regulations on AML/KYC/CFT and the use of agents.
- In the other extreme, electronic money is not considered a deposit, and is issued by a third party under a license from the financial sector authority. Perú and Brazil follow this model. Given that it’s a new figure, the regulator has the ability to define in a more specific and targeted way the details of regulation applicable to all aspects of the business.
- In the middle between (1) & (2) above, electronic money is considered a deposit, but can be issued by a licensed institution that is not a bank. Since it is considered a deposit, it is subject to deposit insurance and can accrue interest.
These definitions lead to different schemes under which eMoney may or may not be able to accrue interest, and be covered or not under deposit insurance. Beyond that, another key aspect associated to eMoney is “fair access” to the mobile channel. In a market where a telco can issue its own mobile wallet, banks need assurance that they will gain access to the mobile channel on equal grounds. The reverse is also true – telcos need provisions to have access to existing bank-based cards infrastructure on equal grounds.
The chart below shows the different characteristics of the regulatory frameworks adopted in some of these countries.
Surprisingly (or maybe not), it has not been the telcos in all of these countries who have jumped at the opportunity, but third party payment aggregators and agent network managers who see in this the possibility to monetize the value of their significant footprint and cash management infrastructure by throwing a mobile proposition in the mix. In all of these countries, aggregators seem to be preparing to expand further up in the branchless banking value chain. A lower customer acquisition cost, and the possibility of compliance with a lighter set of requirements applicable specifically to these payment schemes makes one wonder whether this will finally unleash the power of mobiles in the region.
--------- The author is part of the Technology Enabled Business Model Innovation Team, and the regional manager for Latin America at CGAP.
Photo Credit: Fernando Gonzalez