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Cuscal12 March, 2019 1 Margaret St GPO Box 4720 TEL (02) 8299 9000 Sydney NSW 2000 Sydney NSW 2001 FAX (02) 8299 9600 12 March 2019 The Australian Payments Council Level 23, Tower 3 International Towers Sydney 300 Barangaroo Avenue SYDNEY NSW 2000 c/o Merric Foley Dear Merric, RE: Cuscal response to the triennial review of the Australian Payments Plan Background Cuscal Limited (Cuscal) appreciates the opportunity to respond to the Australian Payments Council’s (APC) triennial Review of the Australian Payments Plan. Cuscal is an end-to-end payments provider that services more than 100 established and challenger brand clients within Australia's financial system and payments landscape, including the majority of the mutual banking sector. We are an Authorised Deposit Taking Institution and also hold an Australian Financial Services Licence and Credit Licence Our services that we provide to our client institutions include: card scheme sponsorship, card issuing, card production services, merchant acquiring, ATM fleet management, digital and mobile banking platforms, and access to the New Payments Platform (NPP). We also act as settlement agent for many of our clients through our Exchange Settlement Account with the Reserve Bank of Australia (RBA). We process approximately 16% of Australia’s electronic transactions. For further information on services Cuscal provides, please refer to our website at www.cuscalpayments.com.au. We are at the forefront of payments innovation and we are investing for future development. As a founding participant and one of the primary architects of the NPP, we enabled 30 of our clients (40 brands) to participate in this important payments innovation on Day One, which is greater than 50% of the total number of participants. We are also an industry leader in the implementation of digital wallets including Apple Pay and Google Pay, having enabled nearly 40 of our clients with this technology. Cuscal also works closely with small and large fintech companies seeking access to the Australian payments ecosystem and has enabled the connectivity to clients, so they may provide innovative products, business models, and drive improved customer outcomes. We are experienced in developing API’s for our clients, and we are compliant with Payment Card Industry’s Data Security Standards (PCI-DSS). The secure handling and transmission of customer financial transactional data is therefore core to our business. Cuscal supports an industry environment that encourages competition, stability and innovation, and one that does not place unreasonable cost burdens on the industry. General Comments Our responses have been structured in line with the three key sections presented in the Consultation Paper and are formed from deep experience in the Australian Payments 1 System, the developments we see in domestic and global payments, and qualified comments from notable references. Australian Payments in Global Context 1. What are your views on the trends outlined on pages 4 to 8? Are there other factors or issues to consider? The trends outlined remain consistent with what Cuscal is observing in domestic, and global payments. Through the industry’s push for less-cash usage, and new digital innovations being rolled out, it follows that there will be be further ATM fleet rationalisation1. We remain confident further demand for digital payments will occur when the NPP rolls out future overlay services, including request for payment. Remaining with NPP, we note that the industry is preparing to facilitate real-time social welfare payments. We see this social service that will be provided by the NPP infrastructure to beneficiaries as a further example of how far payments technology can extend to. 2. What are some other interesting international trends? As global jurisdictions expand their capacity beyond domestic fast payments, we see the opportunity for global fast payments further connecting consumers seeking fast and seamless exchange of funds2. And bypassing conventional means that may take days before a beneficiary can receive their funds. As devices become more communicable, the Internet of Things will provide customers with more convenient opportunities to streamline their payments experience. Including smart refrigerators, for example, that allow customers to view grocery contents, and pay for new groceries, all from the screen of their smart refrigerator. We are seeing further advantages of distributed ledger technology/block chain pilots, where these classes of payments have extended beyond retail payments to international trade financing3. This highlights the benefits of removing traditional processes, and streamlining payments. Further, we are seeing more jurisdictions moving towards a standardisation of payments messaging type, notably, migration towards ISO 20022. The UK is a good example, and the Bank of England has moved from an industry consultation stage and is now determining the establishment of a panel aimed at streamlining the adoption of this messaging standard4. 3. Is digitisation changing the way we view payments? Cuscal clearly believes digitisation is changing the way payments are made. However, we also recognises that some customer demographics continue to prefer using established means of payments, including cards, telephone banking, ATMs, agency banking, and cash. As the Government and service entities increase the use of digital channels (e.g Digital licenses) and the issuance of virtual cards are further centralised to devices, this will further increase the demand and usage of digitisation. Also, as digital wallet providers advance existing service provisions including budgeting and spend tracking tools, and targeted offers, this will further drive customer reliance on digitisation. 1 Sydney Morning Herald - Banks cull ATMs as more customers ditch cash 2 SWIFT - global payments innovation (gpi) 3 Commonwealth Bank Completes New Blockchain-Enabled Global Trade Experiment 4 pmnts.com - Bank Of England Plans Panel To Standardize Payments Messaging 2 Objectives for the Australian Payments System 4. Within the four user groups (individuals, business, community groups and government), what sub-groupings have special needs or requirements that we should consider? We feel the four user groups adequately represent participants in the payments system, and suggest an additional inclusion by way of the following subgroup incorporated under Individuals: Group Subgroup Needs and requirements for consideration • Better educate and inform payments users that have displayed slowness, or reluctance to embrace new payment technologies. • While government agencies provide the community with financial literacy assistance, we welcome Slow adopters industry bodies to further distribute this knowledge across all communities. • Industry participants to consider further simplifying payments processes, to achieve stronger Individuals engagement in future rollout of payments innovation. • This includes parts of the community where there is insufficient infrastructure to facilitate mainstream payments • Access channels The community may not have in possession technological devices (e.g. smart phones, or computers), to enable payments, due to financial or geographic limitations 5. Do Resilience, Efficiency, Accessibility and Adaptability remain appropriate characteristics for our vision of an effective payments system? Generally, we believe these four key headings are appropriate. However, we would add the following construct to Adaptability. Characteristic Measure Added Suggestions Adaptability Openness • Should be extended to include new entrants into the payments system, as the current definition does not clearly make this distinction. 6. Should digitisation change our vision for an effective payments system? If so, how? Digitisation is further underpinning mainstream payments in Australia and abroad. Globally we are seeing growth rates in digital payments, which do not appear to be plateauing. Industry research further backs this with the increasing use of wearable technologies used by consumers to facilitate payments. As well as 87 per cent of the Australian population owning a smart phone. As reported recently, Australia’s transit network is being expanded to accommodate for open loop payments, which will also be facilitated using digital devices5. In light of the ever-expanding realm of digitisation, we believe APC’s vision should remain focussed on characteristics and other themes mentioned in the consultation paper, specifically resilience, security and trust. To further push uptake and innovation of digital 5 Australian Payments Network - The Digital Economy 3 payments, customers will need to maintain a level of confidence that the payments system is adequately fortified to withstand cybersecurity attacks, and other threats that can compromise the integrity of payment systems. Cuscal also recognises that with the ever growing technological payments infrastructure underpinning the Australian economy, payment systems incidents can significantly disrupt consumer payments, which may undermine Australia’s payments systems integrity. And this has been evident from highly publicised industry incidents that left customers unable to receive or make payments for several hours, and during peak payment times. Areas for Industry Collaboration 7. Do the identified topics represent appropriate focus areas for the APC, given our vision of an effective payment system? The focus areas identified by the APC cover a broad remit of strategic value in payments,
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