A draft set of Guidelines were issued for comment in June, but are still in development. RBI signaled several times in the prior year that it planned to look in earnest at mobile financial services.

CGAP’s Notes on Regulation of Branchless Banking in India took stock of the situation earlier this year.

Know your customer (KYC) requirements on financial institutions have received increasing attention by governments in their anti-money laundering and combating the financing of terrorism (AML/CFT) initiatives. AML/CFT regulations introduce specific obligations on account opening, including, at the very least, checking the customer’s identity. This poses a particular challenge to branchless banking for two reasons. First, the absence of branches means that banks need to find alternative ways of conducting face-to-face interviews or identity checks, where those are required. Regulations may allow banks to “outsource” this function to a third party (perhaps the cash-in/cash-out agents) , but it remains the bank’s responsibility to ensure KYC procedures are performed adequately. In the Philippines, the growth of rural agent networks has been limited because all agents need to take a Central Bank-supervised training course in Manila before they are allowed to operate. Many agents find this required training to be too costly and disruptive. Second, to the extent that branchless banking targets poorer and more remote customers, it may be more difficult for these customers to show proof of identity at all.

On the other hand, AML/CFT risks associated with branchless banking initiatives can be mitigated by capping account sizes, account functionality, and transaction volumes. As governments’ interest in access to finance grows, they are becoming increasingly pragmatic about KYC requirements, allowing for simplified procedures where risk is limited. In South Africa, the Reserve Bank permits remote account opening for certain types of accounts; this has allowed WIZZIT to undertake KYC procedures through a network of roving “WIZZkids”—often previously unemployed youths.

For branchless banking to develop, governments need to continue to work with providers to find flexible solutions that meet policy and business requirements. It is unlikely that there will be a one-size-fits-all solution. Instead, governments will need to be responsive to proposals coming from providers and to evaluate these proposals based on the risks involved.

Mobile banking raises security concerns. In principle, security concerns over mobile banking are more manage able than that of Internet banking, because they happen on a more trusted—or at least a more tightly controlled—network. On the other hand, security concerns over mobile banking are bigger than for traditional ATM or POS devices, which are more directly specified and controlled by the provider.

We still do not know the tolerance threshold for errors and fraud for both users and providers in the mobile banking context. Because the mobile banking service is intangible, it is likely that customers will react negatively to (real or perceived) security risks of mobile banking more quickly than to the risk of loss or theft of physical cash. We suspect that customers will not be very tolerant of security lapses, and therefore the security track record must be impeccable.

Security can always be tightened, but that often results in higher demands on the user (more complicated password procedures) or a less favorable customer experience (reentry of PINs, SIM swap). We do not know the extent to which the benefits of mobile banking will be sufficiently appealing to cause customers to put up with increasingly frustrating security measures or, indeed, to develop a higher tolerance for errors or fraud. The industry will need to find ways to offer sufficient security to manage risk.

Of fraud or violation of privacy, without making what is already a precarious customer experience (because of very limited user interface capabilities of mobile phones) a hopelessly frustrating one.

Most MFI-led branchless banking initiatives have been small pilots or have had only limited success. Even though MFIs have strong local knowledge, product development acumen, and the ability to manage small loans, most lack the stable core banking systems and specialized technical skill to implement branchless banking models or tap into existing platforms.

In the Philippines, an initiative to let customers of rural banks use G-Cash instead of cash to make deposits and repayments has been constrained in part by the poor quality of banks’ core banking systems. Based on interviews with experts in the field and observations from our own visits, CGAP estimates that the vast majority of the approximately 750 rural banks will need an IT overhaul or major upgrade to participate. In Kenya, an MFI that substituted group loan cash repayments with repayments in M-Pesa found a different problem. Group loan borrowers made fewer on-time repayments under the new system. Customers no longer attended the group meetings that had helped to keep up repayment pressure.

On the other hand, those relatively few MFIs that have the financial resources and skills to deploy branchless banking have been among the first movers. Microfinance banks, including Tameer Bank in Pakistan and Xac Bank in Mongolia, are developing their own mobile banking channels and are partnering with mobile operators to reduce delivery costs and to reach unserved urban and rural areas.

Another way MFIs may get involved is  as partners for banks seeking to expand their market among the unbanked. SKS Microfinance in India has developed a mobile banking initiative in partnership with Andhra Bank, in which customers use designated SKS banking agents to deposit money into Andhra Bank accounts and use a mobile phone to repay SKS microloans. Small MFIs and local community-based organizations can also play on the other side—as correspondents for other, larger banks. This ensures them a steady revenue stream in a synergistic relationship with the larger bank, as long as they target different population segments. An interesting case is the intent of the Andhra Pradesh State government in India to use up to 30,000 village organizations (local federations of self-help groups [SHGs]), to act as a cash agent for payment of social services, for SHG members under their umbrella, as well as for local banks.

Finally, MFIs are also tackling branchless banking as a group to overcome their individual limitations. In Ecuador, for example, the Red Financiera Rural association of MFIs and cooperatives is planning to contract a technology provider to build and maintain core banking systems and branchless banking channels on behalf of the group to minimize up front costs and the expertise needed inside each member organization. This sharing of technology costs and expertise has perhaps the highest potential to bring MFIs onto payment networks and allow them to take advantage of mobile banking and other delivery channels they cannot implement alone.

Having examined several branchless banking ventures around the world, it appears that less than 10 percent of all branchless banking customers are poor, and new to banking, and are using these channels for financial services (or activities other than paying bills, purchasing air time, or withdrawing government cash benefits). In its study in Pernambuco (a particularly poor state in Brazil), CGAP found that only about 5 percent used a banking agent at least once a month for anything more than paying bills or receiving government payments, were previously unbanked, and were considered poor by Brazil’s standards. Similarly, of about one million mobile banking customers in South Africa, CGAP estimates that fewer than 100,000 fall below South Africa’s poverty line, did not have a bank account earlier, and now use mobile banking for more than payments or transfers. And in Colombia, typical cash transactions through agents are in the range of US$100–200, which suggests that they are not being used by the poorest.

While disappointing to organizations that aim to expand access to finance, this is a fairly natural outcome in the early stages of development of a market following a major innovation. Providers experimenting with a new technology or business model typically seek to reduce risk by focusing on known markets (avoiding the “double gamble” of new business model and new customer segments), and within those on likely “early adopter” subsegments (i.e., those more naturally predisposed to try the new offering).

Indeed, a provider that focuses branchless banking on customer segments it already understands and knows how to market to will find it easier to try out services, assess customer and service profitability, and tailor propositions and market communications messages. For instance, in the Philippines, SMART and Globe Telecom originally advertised their mobile banking services mainly to up-market consumers. SMART combined its mobile prepaid account with a Maestro debit card that can be used at any store that accepts a traditional debitor credit card. SMART’s customer base at year-end 2006 mainly included segments it knew well: four million subscribers had signed up for SmartMoney, and of the 900,000 active users, nearly all were businesses distributing SMART’s prepaid air time.12

Globe Telecom’s GXI Inc., which offers the G-Cash mobile wallet service, estimates that nearly all of its 500,000 active users are individual subscribers in urban areas.13 In fact, the company moved beyond the pilot phase of registering outlets to accept or dispense G-Cash in rural are as late as early 2007. To date, just over 100 agents are registered in rural provinces, compared to the 3,000 air time resellers that Globe Telecom has signed up nationwide directly and the 700,000 airtime resellers hat buy and resell Globe air time.

Most customers are also just dipping their toes in the water. In 2006, CGAP conducted a survey of 515 people in areas served by WIZZIT. Even within the more directly enabled markets—among people who have both a mobile phone and a bank account—the study found, not surprisingly, that those who took up WIZZIT’s mobile banking service on average had a higher income and higher education levels and were more often formally employed, urban, and older. Early adopters were, in general, customers with more sophisticated banking requirements.

That poor people are not usually early adopters of technology can be explained by personal experience (they are likely to have had less exposure to technology and have less access to information about new offerings) as well as the fact that they are less attractive to providers.

This makes the job of governments and donors who are targeting poor people with financial services much harder. Government programs in India, Russia, Malawi, South Africa, and Brazil distribute social protection payments to customers through branchless banking channels. These have been found successful at opening bank accounts for millions of poor customers in some cases (notably Brazil), but have not led to regular use of those accounts to spread expenditure over time—balances tend to be withdrawn in full as soon as payments are received. More research is needed on how poor and excluded clients view their relationship with banking agents and their willingness to trust providers.

Here is a report from the Business Standard on the move. Excerpt:

The wait for rolling out mobile banking seems to be over, with the Reserve Bank of India’s (RBI) issuing draft operative norms for such payment system. Now, RBI said, it will be easier and safer to use mobile phones for carrying out a gamut of banking transactions.

Banks can offer mobile-based services only to their own customers. Banks should have a system of registration before commencing mobile-based payment service to a customer, RBI said.

That said, who will pay for interoperability? If I am a service provider, why should I subsidize/pay for the infrastructure that could benefit my competition?  Visa/Mastercard and the like were not interoperable at first, and we might well expect the same in the mobile banking space. So initially, it makes sense that the field of mobile banking is developing the way it is.

This week our team has been in Cairo for the first ever Mobile Money Summit. Organized by CGAP, DFID, IFC and the GSM Association, 429 delegates from 67 countries gathered to hear from telecom CEOs, banks, microfinance organizations, solution providers, and regulators. GSMA tells us that delegates were more or less evenly comprised of these four groups: telecoms, financial service providers, vendors, and the NGO/government/donor community.

In between powerpoints and conversations in the exhibition hall, some common threads have emerged:
-an awareness of the need for developing domestic financial services and systems, not just international remittances;
-a real emphasis on the vital role played by banking agents, who conduct the cash-in and cash-out function on behalf of a service provider;
-seeing poorer customers as a big opportunity.

As noted in a recent CGAP Focus Note, mobile banking won’t automatically benefit poorer people. There’s a need for the development of interoperable payments platforms, practical and risk-based approaches to regulation, as well as shared networks of cash-handling agents. There is also a need for product development that overcomes the lack of human interaction and reliability concerns that may hinder customer adoption today.

Those challenges are evident in places such as Kenya. Andy Chung of Vodafone spoke about M-PESA, which today boasts 2.3 million customers and is expanding in Afghanistan and would like to expand into even more markets. But are those customers poor people? Would M-PESA automatically reach poor people?

“Any new product penetrates from the top-down. This is the early adopter model that we see with all technologies,” said Chung.  Only with active engagement and perhaps subsidy from development organizations would the people making less than $2 a day begin to take on such services.

Is this discouraging? No. It just means that for mobile banking, it is really early days. The  Mobile Money Summit has been billed as the world’s first global mobile banking conference, and that’s true. It would have been difficult to convene a gathering of this size and shape even one year ago. Now seems to be just the right time to convene this sort of gathering.

What is next? Will industry momentum continue? Will poor people be served by ever
more providers? What will the status of industry be one year from now?

Watch this space.

But only for banks… This shouldn’t be a surprise. SBP’s policy paper on branchless banking (last year) was clear on this point: a nonbank model “may be allowed at a later stage after we have sufficient experience in mitigating agent related risks using bank led model and need to think about mitigating only e-money related risks.” So for now, mobile phone companies are still waiting for the door to be opened to them as well, test the waters without clear permission and detailed guidance, or find a JV with a bank. For those with deep pockets, buying a bank outright might be an option, too.

Kenya’s banking law and regulations look all too familiar: if an institution accepts deposits and uses this money for lending or investment, it needs to have a bank licence. And banks can only transact through their head office or branches. Full stop. But the Central Bank of Kenya has realized that operating through full-fledged branches, which are subject to detailed regulatory requirements, is a very expensive proposition. If the huge gap of banking services in remote and rural areas is ever to be closed, alternative delivery models will be required. Branchless banking models such as mobile phone banking (pioneered in Kenya by M-Pesa, which is run by a mobile network operator and not a bank) and the use of retail agents will be low-cost alternatives allowing for increased rural penetration. The Central Bank Governor, Prof Njuguna Ndung’u, has now pledged to institute necessary regulatory changes allowing banks to offer financial services outside bank branches.

Early registration closes April 1. CGAP encourages you to register with a discount code: CGAPMMSVIP to receive a $100 discount. For questions, contact Jim Rosenberg, CGAP Communications Officer.

Mobile Money Summit 2008 is two-day conference designed for senior executives from financial services institutions, mobile network operators, development organizations, solutions vendors and regulatory and policy makers. The inaugural event will provide for the first time a comprehensive demonstration of the addressable markets, showcase new solutions, and share key success factors and learnings from around the world. The goal of the Summit is to stimulate greater understanding and collaboration between all stakeholders — globally, regionally and locally. Most importantly, Mobile Money Summit 2008 will better equip participants to develop and deploy their own Mobile Money portfolio effectively, efficiently and at scale.

At this highly interactive event, you will learn:

• How Mobile Money can drive top-line growth and customer value in both financial services and telecommunications
• How Mobile Money solutions can drive economic growth and financial inclusion for individuals, communities and countries
• Best practices in the market today, and key innovations coming to market
• Strategic, operational, regulatory and market challenges to effective deployment and scale
• Key propositions for various customer segments in different markets.
• Rationales for partnership between financial services institutions and telecom companies to deliver converged mass market Mobile Money.
• Where and how to kick-start activity most effectively.