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REGULATED LIABILITIES NETWORK: MAKING SPACE FOR DIGITAL CURRENCY WITHIN THE TWO-TIER MONETARY SYSTEM

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Marten Nelson, Co-Founder & CEO, M10 Networks

 

Here’s a good question: Can digital currency (DC) thrive within the two-tier monetary system that banks use the world over? After all, the current system has stood the test of time and is used by, well, everyone. Tearing it apart and trying to replace it with, say, a cryptocurrency makes little sense. How can we realize the promises of DC without throwing the baby out with the bathwater?

Earlier this year, Citi published a paper entitled “The Regulated Internet of Value” (the “Citi Paper”). In it, Tony McLaughlin, Head of Emerging Payments and Business Development at Citi’s Treasury and Trade Solutions, makes a case for settling the ongoing tug-of-war between proponents of stablecoins and those who favor central bank digital currency (CBDC) with a third option: the creation of a Regulated Liabilities Networks (RLN). As he explains: “Tomorrow’s money needs to be global, so we may envision a constellation of interoperable Regulated Liability Networks each founded on national currencies and supervised by local regulators.”[1]

Marten Nelson

McLaughlin is right on this account. If tokenization really is the best way to store and transfer digital value, as the Citi Paper suggests, it’s important that the regulated finance sector take a unified approach to avoid fragmentation and promote functionality. And perhaps, more importantly, to prevent transactions from migrating to the unregulated sector and putting our current system on the back burner.

According to the Citi Paper, pursuing tokenization in lockstep would allow central banks to expand beyond CBDC projects and include tokenization of all regulated liabilities. McLaughlin believes this would effectively “overcome a potential downside, which is the disintermediation of private regulated entities”. He suggests that this broader focus on regulated liabilities “brings the benefits of tokenization without the adverse consequences. It upgrades regulated money, which today only exists in account-based format.”[2]

What McLaughlin doesn’t appreciate, however, is that systems like this are already up and running in the pilot phase with banks around the world.

Several central banks (think: China and the Bahamas) have made great strides toward issuing digital currency on their own. Others have realized the value in embracing alternative ways to deliver the benefits of tokenization without actually issuing digital currency to residents. Afterall, if a central bank can avoid opening Pandora’s Box and still offer the benefits of CBDC, such as 24/7 access to banking services and fast, cheap, and easy cross-border payments, it will truly have located the Holy Grail. Emerging models for digital money make this possible – and are closer to bringing an RLN to life than McLaughlin might suspect.

The Citi paper rightly notes that maintaining a stable economic environment with sound monetary policies requires safe digital money that must be: “(a) regulated, (b) redeemable at par value on demand, (c) denominated in national currency units and, (d) an unambiguous legal claim on the regulated issuer.”[3]

Unlike cryptocurrencies such as Bitcoin, regulated liabilities include central bank money, commercial bank money, and electronic money since they all live on the balance sheet of the relevant regulated financial institution. An RLN would also allow stablecoins to be incorporated into the current financial system as regulated liabilities. By design, the transfer of money in a network of regulated liabilities will be in favor of verified legal persons, reducing the risk of financial crimes, and would be conducted through the transfer of tokens. These transfers are done through entries on a private ledger maintained by the bank, and not using bearer instruments. Consider the following definitions from the Citi Paper:

  • A token in a central bank wallet is a liability of the central bank
  • A token in a commercial bank wallet is a liability of the commercial bank
  • A token in an E-money wallet is a liability of the E-money issuer

“The legal meaning of the token is given by its location of the wallet in which it resides. When a token is at rest in a wallet controlled by an institution, then it is on the balance sheet of that institution as a liability in favour of the token holder.”[4]  By contrast, Bitcoin payments are conducted as a digital form of a bearer instrument.

Today, emerging models for digital money have harnessed the power of blockchain technology to express tokenized liabilities on the same shared ledger. This shared ledger represents the best of both worlds, creating digital money that is ‘always on’, instant and programmable, global in scope, but regulated by a sound banking system.

In fact, a shared ledger system enables both central bank money and commercial bank money to be tokenized. Furthermore, it allows transactions to settle instantly since banks on the system are transacting using tokenized central bank balances on shared ledgers. The platform would support multiple regulated liabilities. To address data sovereignty, there would be one ledger for each currency and it would host multiple types of liabilities for that currency. Banks can have positions on multiple ledgers. The ability for a bank to debit a position on one ledger and credit the balance on a different ledger enables cross-border payments.

And the best part? It all fits neatly within the two-tier monetary system.

The Citi Paper is an essential contribution to payments literature, providing the first public articulation of how an RLN can address the very real challenges of integrating digital money into our current financial framework. Yet, while McLaughlin states that creating such a network may seem like a “pipe dream,” at M10 Networks we’re already well on the way to bringing the vision to life for central banks and commercial banks around the world.

 

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Protean and Fino Payments Bank tie-up to expand PAN card issuance services in India

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Fino Payments Bank has tied up with Protean eGov Technologies (formerly NSDL e-Governance Infrastructure Limited), a market leader in universal, citizen centric and population scale e-governance solutions, to expand PAN card issuance services in India, especially in rural areas.

The association makes Fino the first payments bank to act as PAN Service Agency (PSA) of Protean and facilitate paperless PAN issuance services. The tie-up allows Protean to expand its reach in the interiors of the country through Fino Bank’s  phygital network of over 12.2 lakh merchant points.

At Fino Bank points people can apply for PAN card through Aadhaar based authentication, without the need to submit or upload any documents.

Further, applicants have the option to choose PAN card either in digital or physical form. The digital version or e-PAN, introduced recently, will be sent within a few hours of applying to the applicant’s email id. It is admissible as actual PAN card. Those opting for physical will receive their PAN cards at their Aadhaar mentioned address within 4-5 working days.

Mr. Rishi Gupta, MD & CEO, Fino Payments Bank said, “The association is a reiteration of our commitment to provide all financial related services under one roof. Our extensive pan India distribution network is best placed to provide efficient near doorstep delivery of G2C services. We are already facilitating disbursal of direct benefit transfer payments of various Government schemes and providing last mile access to banking services. We are pleased to partner with Protean towards their efforts to expand PAN coverage across the country and in the process ensure our objective of making every citizen financially secure is achieved.”

Mr. Suresh Sethi, Managing Director and CEO, Protean eGov Technologies, said, “We are delighted to partner with Fino Payments Bank as part of our strategy to contribute to a financial ecosystem that offers socio-economic benefits across all strata of the society. Our partnership will help to advance our shared vision of an inclusive and empowered India. This initiative is aligned with our mission to leave no citizen behind and bring the digitally excluded into the fold of formal financial economy.”

Since inception in 2017 Fino Payments Bank has been transforming the rural banking landscape with its extensive distribution network of over a million points. The convenience offered by the neighbourhood banking outlets has led to increased banking adoption and usage with more than 25 million customers visiting the points every month. With its innovative asset light model the transactions focused bank is profitable and as of today the only listed entity in its space.

Protean, which accepts and processes PAN applications on behalf of the Income Tax Department, Government of India, has played a pioneering role in laying down the basic e-governance infrastructure for the nation and providing citizen-centric services to the masses over the course of the last 25 years. Access and inclusion lie at the heart of any e-governance initiative and towards that the company has adopted and established a “Phygital” (Physical+Digital) model to ensure a truly inclusive service delivery paradigm.

As per Ministry of Finance, more than 43.34 crore Permanent Account Numbers (PANs) have been linked with Aadhaar till January 2022. That is around 36% of India’s population has Aadhaar linked PAN card. With more than 131 crore Aadhaar cards issued, there is immense scope for PAN card penetration, especially within those falling in income tax bracket.

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Cost of living: How to identify vulnerable customers

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Ellie Engley is account director at REaD Group

 

In the current climate, the cost of living crisis is a real challenge for financial services companies who need to be able to support their vulnerable customers. One in six (17%) of UK households (4.4 million) are now in ‘serious financial difficulties’, compared to one in ten (2.8 million) in October 2021 – an additional 1.6 million households – according to research from Bristol University, while it was recently reported that one in five adults across the UK – nearly 11 million people – have fallen behind with at least one household bill payment.

As a financial services provider, it has never been more important to be able to identify and communicate appropriately with vulnerable customers; those who, due to their personal circumstances, are especially susceptible to detriment. Not only that, but there are three different levels of poverty to be aware of: ranging from income below minimum income standard, not enough income and destitution.

As a financial service provider, then, it has never been more important to communicate sensitively to customers, price products appropriately and protect customers from fraud.

Identifying vulnerable customers

As a responsible brand, the first step is to proactively identify vulnerable customers to exclude from particular direct marketing campaigns, where additional credit or non-essential purchases could increase the pressure on their personal circumstances. This is an ethical approach to direct marketing which also sees companies increase ROI and improve campaign success.

Using both internal first party and third party data, it is possible to build up a detailed picture of customers in order to identify the existing vulnerable groups, as well as the emerging vulnerable groups within your customer base.

This data can identify vulnerable and potentially vulnerable segments of consumers, including self-declared vulnerability or that shared by a first party, such as a bank, on behalf of the consumer, along with high-cost short term credit applications; houses of multiple occupation (HMO data); and consumer vulnerability metrics. This latter employs a segmentation model which takes into account census data to provide information on demographics, such as age, income, housing, education, financial products, affluence measures; transient states such as health; market forces acting on the consumer and their susceptibility to those forces; and the individual’s market preferences.

Taken together this data will provide a rich and detailed understanding or levels and types of vulnerability so brands are able to work with their customers responsibly. Gaining a better understanding of differing vulnerable segments in a customer base helps drive effective communication strategies, while simultaneously ensuring fair treatment.

Other warning signs

Changes in transactions and behaviour are another way to identify vulnerability in customers. It may be necessary to identify different segments or groups of customers who are classed as vulnerable for different reasons. Those consumers who were once deemed ‘financially stable’ now feel financially stretched and are at greater risk of financial vulnerability through increased cost of living and rise in inflation.

The use of third party datasets can also support the identification of these groups which provide information on changes in personal circumstances, short-term finance requirements, loss of income or employment and changes to relationship or residential status.

Using external data variables helps companies make data-driven decisions on how to price products, reduce fraud, identify vulnerable customers and ultimately make more personalised decisions using data. Data can be used across different teams, including marketing, fraud and pricing, for multiple purposes and projects.

Being able to supplement the data they hold on a customer can help marketing teams to not only help identify risk but help define what their need state actually is, whether that’s saving, moving house or having children. Enhancing customer data helps companies make better informed decisions.

Keep it clean

On top of this, every financial services provider should be keeping their consumer data clean and accurate. Data that is up to date will help businesses make more informed and responsible decisions about how they communicate with customers and prospects.

Above all, financial service providers should be mindful of the many more people who are now vulnerable, and communicating with care should be a brand’s mantra for the foreseeable future.

 

Ellie Engley is account director at REaD Group, a Sagacity company, which uses its data products, insight and expertise to help its clients get closer to their customers.

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