The challenge of bank card interchange
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The Challenge of Bank Card Interchange. Steve Mott Principal, BetterBuyDesign December 2005. The Burning Questions. Where are we now, and how did we get to this point? What was the original rationale for interchange? What’s the rationale now/how has that changed?

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The challenge of bank card interchange l.jpg

The Challenge of Bank Card Interchange

Steve Mott

Principal, BetterBuyDesign

December 2005

The burning questions l.jpg
The Burning Questions

  • Where are we now, and how did we get to this point?

  • What was the original rationale for interchange?

  • What’s the rationale now/how has that changed?

  • Does the new “value proposition” hold water?

  • What new issues are forced into the open by the emerging economics of interchange?

  • How are merchants and consumers reacting?

  • What are the resulting opportunities and challenges?

1 where are we now l.jpg
1. Where are We Now?

Attacks on bank card market power and interchange have been piling up since 2002

  • Antitrust suits (allowing Amex et al to enter market)

  • Wal-Mart suit settlement

  • Merchant groups formed (Merchant Coalition, Merchant Payment Roundtable)

  • International challenges (Australia, EU, UK)

  • May 2005 Fed conferences (KC & Chicago)

  • Summer 2005 American Banker articles

  • 4 of the 6 rumored interchange lawsuits this year have been filed

  • Congressional Inquiry in wake of Katrina/gas price hikes

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Banking’s Personality Challenges

In many respects, these challenges play upon some inherent weaknesses

  • Banks tend to be terrible at communicating with one another

  • We’re worse at communicating to the outside world (e.g., “ID theft”)

  • We let the card networks do their talking for us

  • We don’t know our own costs

  • We don’t understand their own economics (e.g., direct mail solicitations, charge-offs, etc.)

  • We rarely price on value, so most products drop quickly to cost-plus pricing

  • We won’t talk about interchange

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Now it’s “Winner-take-all” Consolidation

On October 20, 14 interchange cases were consolidated by the same court (and judge, John Gleeson) which certified the Wal-Mart suit against Visa and MasterCard as a class action (Feb. 2002); 21 other “potentially related” suits would be treated as “tag-along actions)

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Scene After the Wal-Mart Suit Settlement

The Wal-Mart suit settlement was seen as a violent shock to the industry

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Was the Court Satisfied with the Results?

But the results were disappointing to many—big retailers got the benefits, but no structural change resulted

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Guide to Some of the Key Lawsuits

Four of the six big interchange lawsuits rumored for this year have been issued; these suits strike at the heart of interchange policies and practices

Wheels of justice go flat l.jpg

Anti-trust suit permitting banks to sell Amex & Discover products

$3.2 billion settlement of “Wal-Mart” suit, rejecting the “honor-all-cards” dictum of the card associations

Encouraged Visa/MC to raise interchange to “compete” with Amex rates

Top 200 retailers got to negotiate discount rates, but smaller merchants got stuck with more increases

Wheels of Justice Go Flat

While these developments might bring cheer to some, for those who look for both fairer rates AND equanimity in marketplace, the courts have proved somewhat disappointing

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Bad News from the U.K. products

Defense of signature card interchange is going badly in other parts of the world

  • INTERCHANGE FEES TAKE ANOTHER HIT: The United Kingdom's Office of Fair Trading, the government consumer protection agency, today issued a preliminary ruling against Visa's member banks, saying that the interchange fees banks charge to process transactions are anticompetitive. The OFT said Visa's multilateral interchange fee, which is applied to consumer credit cards, charge cards and unduly high fee being paid to card issuing banks by merchant acquirers on every Visa transaction deferred debit cards in the UK, leads to an "." The cost of these fees is being passed on to retailers and ultimately to consumers,” the OFT added.

  • In a statement, Colin Grannell, Visa UK's managing director, said the card association does not believe its interchange fees are unduly high. The preliminary finding wasn't unexpected in light of the OFT's preliminary ruling last month that interchange fees set by MasterCard's UK members were too high.

Source: Cardline, 2005

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The Specter of Australia products

Now, more than ever before, the specter of a fundamental change looms in the U.S. If it goes the way of Australia, change could be massive and consequences huge

  • RBA concluded that credit card usage was artificially high due to loyalty programs and interest-free credit—which were paid for by merchants

  • So interchange rates were halved (to .55%), with unexpected consequences:

    • Issuers shifted to Amex and Diners; charge-card growth surged

    • Consumers got hit with surcharges for credit-card use

    • Only a couple of new participants (Virgin Money, GE Money) appeared

    • Issuers lost $300 mil. in interchange, but profits went up 16% at ANZ, versus the 40% drop they feared

    • Merchants saved US$300 mil.; Australian CPI dropped 0.2%

  • RBA has now set its sights on setting debit cards at par (free), but large merchants—who receive interchange from issuers on some EFTPOS transactions—are fighting this new effort

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2. The Original Rationale products

Credit cards are widely acknowledged as the most successful consumer financial service product in the past half-century; the original rationale addressed important societal goals

  • Supported widespread, non-collateralized lending to qualified consumers

    • At efficiency levels better than merchants could provide (including lower cost of money)

    • With ability to use credit at any accepting merchant

    • And get instant gratification for purchases

  • Facilitated more efficient electronic purchases

    • Provided merchants with guaranteed payment

    • Provided end-to-end electronic processing

    • Moved consumers out of cash and checks

    • Reduced fraud and NSF risk

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The Basics of Interchange products

The idea was to compensate transaction parties for the work they did

Source: Diamond Cluster, 2005

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Original Structure of Interchange products

Although little is publicly available about interchange, it is possible to piece together some cohesive theories on the original rationale and structure; the structural components had clear purposes:

  • Compensate issuers for costs of lending

  • Compensate acquirers for merchant vetting and processing tasks

  • Recover costs of network development and operation

  • Manage costs of fraud, given guarantees provided

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Key Premise: Support Electronic Purchases products

With signature-based cards, consumers could afford to make a purchase right away, or make a bigger purchase than they otherwise would be able (or want) to make with cash or a check; the first merchant who accepted the card would stand to benefit from the resulting incremental sales opportunity by accepting the cards

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Original Premise: Mission Accomplished products

So it’s easy to conclude that the original rationale for interchange has been fulfilled

  • 5 million accepting merchants

  • 65-75% of consumers with at least one card

  • Cards now produce a third of consumer purchases

  • Fraud is well-contained and efficiencies of electronic processing accrue to many

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3. What’s Changed products

But so much has changed since signature cards were introduced four decades ago—especially in the past 10 years; although the card networks have tried to morph these cards to fit all applications, there’s no doubt that they’re getting long in the tooth—along with many of their most loyal users

  • Market maturation

  • The shift to rewards to keep growth going

  • A force-fit for online commerce

  • Changing consumer behavior and merchant needs for different ways to pay

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Maturing into a Convenience Play products

Consumer use of credit cards for lending has been flat for a decade, while spending continues to rise

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Interchange More Important to Issuers products

Merchant-side business is now producing a better return than the cardholder side—naturally shifting emphasis to interchange

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Credit Cards Leverage Rewards products

Bernstein Research estimates that 1% of interchange goes to financing cardholder rewards—which mostly go to affluent non-revolvers; Visa recently reported that 40% of cards would have rewards by next year

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Primary Purpose of Cards Drives Use products

A large, but aging core group of credit card users regards rewards as their primary motivation for paying with cards; debit card users—a rapidly growing, younger group—want REAL pay-as-you go control

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Characteristics of Changing Consumers products

New, emerging consumers are different than today’s transactors, and will be extremely receptive to debit account products that they can access from anywhere

  • The 18-34 age group is demonstrating a decided preference for debit payments over credit (Forrester, 2004)

  • 65% of college students have credit card debt; 50% charge them to the limit; but a Nellie Mae study in 2004 reported that outstanding balances had dropped 7% (from 2001) to a seven-year low of $2,169 per card, as students weaned themselves from this product

  • This demographic is highly-evolved toward Internet use (e.g., 60% are online bankers), and expect debit account access wherever they transact

  • 92% of high school graduates are Internet literate; Growing numbers are registering for new payment types (e.g. PayPal web site reports nearly 80 mil. accounts)

  • A new population “bubble” is moving through the marketplace with unprecedented willingness to shop their primary debit account to institutions who “get it” and offer the Internet and wireless services and access they demand

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Components of Debit Migration products

Underlying the shift to electronic payments is a major migration to debit- account products, away from the heretofore credit-card centric consumer economy, to the tune of 40% of all payments by 2010

Shift to



Sources: Nilson Report, Dove/ABA Study, BBD estimates

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Debit Account Users: New Lifestyle products

Debit card users are growing in number, and have clearly different patterns for purchasing behavior—avoiding debt as much as possible

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4. New “Value-Proposition” products

The card networks have evolved their arguments for fostering signature card use and keeping interchange high to a new set of “value propositions”

  • High interchange fosters innovation

  • Providers are delivering new services, such as charge-back protections for consumers

  • Interchange pays for incentives to usage

  • There are costs for guarding against fraud

  • Payment guarantees can’t come free

  • Use of electronic processing provides valuable information

  • End-to-end service can be cost-free (once interchange is paid)

  • The number of merchants accepting continues to grow

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Innovation Track Record? products

The bank card industry is not necessarily regarded as the seed-bed of innovation; but then again, a BAI research study in 2001/2002 determined that there were only three “disruptive innovations” in retail financial services in the past 40 years (monoline credit, mortgage brokers and credit-scoring)….

New services charge back protection l.jpg
New Services: Charge-back Protection products

In the model of disruptive innovation, established market participants tend to add services that users don’t necessarily need in order to keep value (and prices) rising; in the case of zero liability and other charge-back protections, the industry has trained a generation of “free-riders” who routinely repudiate transactions—more or less at will—at exactly the moment that the industry needs to encourage more consumer responsibility and accountability for online security

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Network Operations Costs products

Certainly, the costs of running the payment card networks has continually come down with the benefits of digital technology

  • Visa just finished a two-year upgrade of the Direct Exchange Network, which can do real-time authorizations for less than $.05

  • Network costs through Private NetworkVPNIP evolution have reportedly dropped by more than one order-of-magnitude

  • Fraud costs are at an all-time low

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Fraud is at an All-Time Low products

Card fraud in the banking systems continues to drop, and bank costs for risk management are stable; so this factor doesn’t drive interchange, either

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High Cost of Sig-Card Risk Management products

Saddled with the liability for fraud, online merchants manually review 1 in five transactions, and block 4-5 good orders for every bad one—on top of fraud and charge-backs (especially “friendly” fraud); the situation for smaller merchants who can’t afford elaborate risk management systems is much worse

Source: BBD Projections from RTD Business Model

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Back-Shop Costs = 2 x Interchange products

The net result is that even the best and most competent online merchants are paying twice what they pay in interchange just to risk-manage anonymous signature card transactions

Source: BBD Projections from RTD Business Model

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Meanwhile, Charge-offs Have Soared products

In fact, true fraud pales in comparison to the industry’s somewhat self-destructive penchant for extending credit beyond the logical ability of incremental users to pay

Source: Bank Technology News, March 2004

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Merchant Vetting? products

And poorly-vetted merchants fuel charge-backs while generating high


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Competing Merchants Forced to Accept products

With so many merchants accepting cards in today’s environment, competitors are forced to join-in or risk missing sales


Result higher cost of doing business l.jpg
Result—Higher Cost of Doing Business products

The result is all merchants face a higher cost of doing business

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5. Economics Force the Issues products

Meanwhile, the economics of bank card usage are forcing serious examination of the underlying cost structure and pricing rationale

  • Interchange only goes up (unless you’re a national retailer with negotiating leverage)

  • But other digital processing businesses demonstrate the value to society of open competition

  • Signature cards are decidedly the most expensive way to transact in the merchant space

  • High interchange accrues mostly to the benefit of Issuers (not Acquirers)

  • Industry concentration has polarized relations/bifurcated strategies

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Interchange Rates Trends products

For most merchants, interchange just keeps rising; for select merchants with negotiating power, some relief came in early 2004

Source: Visa, MasterCard, Corporate Reports and Bernstein estimates; BBD additions

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Bank Card Interchange Rates products

Rising interchange has been a fact of life since the early 1990s; in a

recent report, Morgan Stanley predicted an average rate of 1.85% by 2010


Source: Nilson Report, May 2005

Telecommunications counter example l.jpg
Telecommunications Counter-Example products

International calling prices dropped from $1.34 a minute in 1980 to $.21 in 2003, spurring a hefty increase in demand

Source: FCC

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Telecommunications Counter-Example products

Basic long distance services are experiencing normal declines in price expected for a maturing service


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Enormous Stakes for Merchants products

It takes unusual market power to keep interchange rates rising in a period of digital network efficiencies; for the world’s largest retailer the stakes are enormous—about $750 million in 2002 and more than a billion by 2007 that would otherwise drop to the bottom-line

Source: Bernstein Research

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Credit Cards Provide the Bulk of Fees products

It’s easy to see why the card industry is so protective of interchange; credit cards generate the vast bulk of merchant fees paid to FIs vis-a-vis all other payment types

Sources: FMI, Paymentech, NDPS, Nilson

Report, ATM/Debit News, PiperJaffray, BCG

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Total Costs for Each Average Ring products

Factoring in all the transaction costs, signature cards remain the most expensive way to transact

Sources: FMI, Paymentech, NDPS, Nilson

Report, ATM/Debit News, PiperJaffray, BCG

Proportions of each ring amount l.jpg
Proportions of Each Ring Amount products

And when ring amounts are factored in, the signature debit card product emerges at even more expensive than credit cards




Sources: FMI, Paymentech, NDPS, Nilson

Report, ATM/Debit News, PiperJaffray, BCG

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Bank Card Revenue—2002-2004 products

Looking at bank card revenue components from an industry level, interest remains the big driver—although merchant interchange is becoming more important

Source: Credit Card Management

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Card Revenue vs. Demographics products

Between 40-60% of revenue—mainly in the form of penalty interest rates and fees—is derived primarily by saturated marketing of cards to the next-to-lowest quintile—who can least afford them

Penalty Fees









qualify for


Source: CCM, plus BBD projections

Bank card expenses margin 2002 2004 l.jpg
Bank Card Expenses/Margin—2002-2004 products

Meanwhile, charge-offs vastly eclipse fraud and other typical

network costs; and the costs of cardholder rewards (part of “operations/marketing”) and billions of unproductive direct mail solicitations generate the bulk of industry costs

Source: Credit Card Management

Card costs vs demographics l.jpg
Card Costs vs. Demographics products

A substantial portion of marketing expenses now go to rewards, which mainly go to non-revolvers; charge-offs of debt mainly accrue to the next-to-lowest quintile, who now use credit cards for day-to-day living







qualify for






Source: CCM, plus BBD projections

Non revolvers get a free ride l.jpg
Non-Revolvers Get a Free Ride? products

Non-revolvers tend to produce the lowest profits for Issuers, and are mainly relied upon to drive interchange revenue; but merchants don’t see benefits from serving these customers—particularly at premium-card interchange rates—since they can afford to pay by a variety of means

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Industry Revenue/Income by Participant products

By far, the vast portion of industry revenue and profit accrues to the Issuers; in fact, acquirer margins have been regularly squeezed

Sources: FMI, FirstData/Concord,

EFT Report, PiperJaffray, BCG

Smaller merchants foot the acquirer bill l.jpg
Smaller Merchants Foot the Acquirer Bill products

SMEs generate the bulk of revenues and fees for acquirers

  • Nat’lLocalTotal

  • Txns (bil.) 11.3 7.5 18.8

  • $ Vol ($T) $0.71 $0.47 $1.18

  • All-in fee 13bp 60bp 32bp

  • Proc’g/txn. 2.5¢ 11¢ 6¢

  • Sales/svc. $0.06 $0.27 $0.14

  • Source: Bernstein Report 4/2003

    Concentration in the card business l.jpg
    Concentration in the Card Business products

    Concentration in issuance has growth markedly; today, eight FIs control 92% of transactions; so the debate over interchange mainly affects a handful of institutions—but threatens the entire industry

    Fi concentration online l.jpg
    FI Concentration: Online products

    The handful of companies that dominate credit cards don’t serve the entire marketplace, though--e.g., the online marketplace; serving this marketplace fully with the right products will require many participants

    Source: Various Research Reports

    The specter of cannibalization l.jpg
    The Specter of Cannibalization products

    Banks are frozen from moving to non-card payment innovations by the challenges of product cannibalization

    Financial impact of converting to:

    Source: Dove Consulting, from VISA Discussion Documents, Faulkner&Gray, Nilson Reports, NACHA, FDIC, BCC Study, Industry Reports

    Prisoner s dilemma l.jpg
    Prisoner’s Dilemma products

    From an enterprise standpoint, weaning an institution off of high interchange might make perfect sense—except to the card business units

    Merchant concentration online l.jpg
    Merchant Concentration: Online products

    In a similar vein, large merchant strategies conflict with small merchants

    Source: Various Research Reports

    6 consumer and merchant needs l.jpg
    6. Consumer and Merchant Needs products

    • Consumers are clearly shifting to a debit-account payment preference

    • Efforts to extend card usage to applications where they don’t fit (e.g., bill payments) are failing

    • Merchants have good reason to want additional payment options for their customers

    • So they are dabbling in alternative payments—looking for better product functionality at justifiable rates

    • Real-time debit alternatives appear to be the direction the industry is most likely to take

    Consumers need payment flexibility l.jpg
    Consumers Need Payment Flexibility products

    There is growing evidence that consumers are frustrated with today’s payment products, and are trying non-bank alternatives

    • Studies continue to show that more and more consumers want to pay for purchases with their ATM debit cards (or ACH equivalents) to get more control and pay-as-you-go option

    • Up to half of adults can’t buy a $250 basket on the Internet with credit cards (don’t have them, or are maxed-out)

    • Online billpayment continues to be horse-race between bank and biller models

    • Stored value demand for online loading, top-off and account management capabilities is growing rapidly

    • Micropayments users are constrained by lack of viable and cost-effective means of payment

    • Consumers—not just those living paycheck-to-paycheck—proving quite willing to pay $1-3 for convenience payment alternatives

    Merchants demand better options l.jpg
    Merchants Demand Better Options products

    Meanwhile, merchant demands for better alternatives to expensive signature-card payments online are reaching a crescendo

    • Groups like the Merchant Payment Roundtable (representing 56% of eCommerce revenue) are actively pursuing real-time, good-funds guaranteed payment alternatives for online purchases

    • The Merchant Payment Coalition is researching a merchant payment network for POS

    • A cottage industry of Billing Service Providers has arisen to help billers gain access to debit networks for payment (including PINless debit, STARChekDirect, etc.)

    • Stored value processors are rapidly plumbing-in eDebit capabilities for transactions—on top of loading and top-offs

    • Digital content providers are tweaking stored value and other debit-account solutions to get per-transaction pricing under $.20 sig-card minimums

    • Remittance and convenience payees are increasingly willing to accept account transfers, direct debits, PINless alternatives, and ACH to cut transaction costs and speed payments

    Merchants benefit from multiple options l.jpg
    Merchants Benefit from Multiple Options products

    Evidence is beginning to surface demonstrating the benefits of multiple payment options—led by PayPal and BillMeLater

    Paypal instant credit with interest l.jpg
    PayPal—Instant Credit, with Interest products

    By default, PayPal is offering very convenient online “banking” via

    an increasing array of merchants

    Instant credit online billmelater l.jpg
    Instant Credit Online-BillMeLater products

    Other “instant credit” models are gaining traction as well, producing

    both incremental demand and lower interchange costs


    Debitman model l.jpg
    Debitman Model products

    Debitman remains an interesting test of merchant experimentation blended with provider ingenuity; Pay-by-Touch is another vendor to watch

    Merchant interchange l.jpg
    Merchant Interchange products

    Debitman introduces the notion of “merchant interchange”, providing an incentive for solving the issuance challenge

    7 opportunities and challenges l.jpg
    7. Opportunities and Challenges products

    The movement to a debit-account centric payment society from a credit-account based one carries substantial political baggage

    • A contrarian’s view makes the case for more thorough examination, debate, and disclosure

    • The financial services industry itself appears ready to change—if only to avoid calamity

    • Industry polarization could thwart consensus to move forward with appropriate networks

    ? ? ?

    A different point of view l.jpg
    A Different Point-of-View products

    Aite principal Gwenn Bezard claims there are five ”misconceptions” about interchange that need greater understanding in this debate

    • Interchange is only one part of the total cost of acceptance—acquiring fees are the other big cost;

      • in countries like France, for example, where the debit interchange is lower, the acquiring fees make total cost about the same as in the U.S.

      • The merchant service charge (MSC) for credit cards is lower in the U.S. on average than in all but three countries surveyed (e.g., same as UK, but higher only than France and Denmark)

    • High interchange is not the result of a lack of competition

      • Multiple card networks in the U.S. (vs. single networks in many foreign countries) tend to bid up interchange as networks seek more bank customers

    • Issuer contention that interchange is necessary to develop networks and new products is “simply wrong”, however;

      • Most issuers make the most money on outstandings

      • Many debit card networks overseas have developed thriving networks with much lower interchange

      • Interchange is a negligible factor for exploding stored value card use

    Source: Aite, 2005

    A different point of view cont l.jpg
    A Different Point-of-View (cont.) products

    Further examination and scrutiny should go a long way to balancing out some of the furor

    • High interchange doesn’t foster innovation

      • Prepaid card markets are exploding, and interchange is a negligible factor (though FI pricing weighs against them)

    • Regulatory relief, such as interchange caps, haven’t worked completely as expected in countries that have tried it

      • e.g., Australia, consumers pay more though merchants have halved Interchange costs

      • rather than push for regulatory relief, merchants in the US> would be better off backing electronic networks they control (e.g., Debitman—a similar system in Germany now handles 53% of the debit traffic with NO interchange)

    Source: Aite, 2005

    Roadmap to the opportunities l.jpg
    Roadmap to The Opportunities products

    Those these recommendations are antithetical to the closed and defensive approach of the bank card associations, there IS a way forward

    • Acknowledge differences in strategies and stakes between the big card issues and all other FIs; ditto for merchants

    • Find an independent arbiter (Fed?) to referee examination of costs and value in-depth among ALL stakeholders

    • Debate the issue and positions openly and ingenuously

    • Start the process of rationalization before merchants abandon bank networks/products en masse, and pricing plummets

    • Return to making money the old-fashioned way: By earning it

    Consequences of the challenges l.jpg

    Amex civil suit plus 47 interchange suits products

    Possible interchange decline

    Absolute volume loss to merchant-controlled networks

    Exacerbated split between the big bank and all other FIs

    One estimate of the expected value of settle-ments/damages: $15.4 bil.

    $11 bil. out of $24 bil., if restructuring a la Australia happens (Morgan Stanley)

    Up to 20% of current card volume, or $400 billion

    “Big 8” lose support from rest of the industry; all other FIs support rival products

    Consequences of The Challenges

    The stakes of this debate have become enormous—most especially for the biggest card issuers, who far and away have the most to lose

    Potential reduction in interchange l.jpg
    Potential Reduction in Interchange products

    Lower interchange is probably inevitable, and the least of our worries

    Tragic irony fight over value pricing l.jpg
    Tragic Irony: Fight Over Value-Pricing products

    Ironically, this battle is over one of the few banking products that haven’t simply devolved to commodity, cost-plus pricing; “value” has conflicted with the notion of “market power” in this debate

    Value-Based Pricing

    Cost-Plus Pricing

    Checking Accounts

    Savings Accounts

    Investment Accounts

    Check deposits


    Commercial lending

    Prepaid cards

    Online banking

    Online bill payment


    Signature cards

    Wire transfer (SWIFT)

    Consequences of getting it wrong l.jpg
    Consequences of Getting it Wrong products

    So maybe, just maybe, the industry should seize upon the opportunity for getting the interchange issue right, and use that model for reexamining all other banking products—moving the industry toward a defensible balance of costs and value, toward a new era of customer relationships, where FIs are respected, rather than vilified, for the true contributions they make for secure transacting—before it’s too late…

    Steve mott s contact coordinates l.jpg

    dba CSI Management Services, Inc. products

    1386 Long Ridge Road

    Stamford, CT 06903

    (o) 203.968.1967

    (f) 203.322.1012

    (c) 203-536.0588

    email: [email protected]

    Steve Mott’s Contact Coordinates

    This presentation represents a portion of a growing body of research and analysis by BetterBuyDesign. Please don’t hesitate to contact BBD with any questions, comments or further interests!

    Steve MottBetterBuyDesign

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