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Response to Discussion Paper by EFTPOS Industry Working Group

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Response to Discussion Paper by EFTPOS Industry Working Group Response to Discussion Paper by EFTPOS Industry Working Group Australian Institute of Petroleum 12 September 2002 Response to EFTPOS Discussion Paper Australian Institute of Petroleum Contents 1. Executive Summary.................................................................................................... 3 2. Introduction ................................................................................................................ 6 2.1 Background...................................................................................................... 6 2.2 Objectives ........................................................................................................ 6 3. The Oil Industry’s Role in EFTPOS ............................................................................ 7 3.1 Card Processing Infrastructure and Costs........................................................ 9 4. The Australian EFTPOS System .............................................................................. 11 4.1 Costs.............................................................................................................. 15 4.2 Efficiency........................................................................................................ 18 5. Process & Timeframes ............................................................................................. 20 6. Scope of Review ...................................................................................................... 21 6.1 EFTPOS and Scheme Debit Cards ................................................................ 21 6.2 Other Card Reviews in Australia .................................................................... 22 7. Overseas Schemes .................................................................................................. 23 7.1 Canada .......................................................................................................... 23 7.2 United Kingdom.............................................................................................. 24 7.3 South Africa ................................................................................................... 26 7.4 Germany ........................................................................................................ 28 7.5 New Zealand.................................................................................................. 29 7.6 USA ............................................................................................................... 30 7.7 Lessons From Overseas ................................................................................ 31 8. Interchange .............................................................................................................. 33 8.1 Impact of Changes to Interchange ................................................................. 37 8.2 Response to Working Group’s Options .......................................................... 37 8.2.1 Perceived Problems with EFTPOS Interchange Arrangements..... 38 8.2.2 Option 1 – Bilateral Interchange Arrangements............................. 39 8.2.3 Option 2 – Multilateral Interchange Fees....................................... 40 8.2.4 Option 3 – No Interchange Fees ................................................... 41 8.2.5 Multilateral Pricing Methodologies................................................. 41 9. Access...................................................................................................................... 43 10. Recommendations ................................................................................................... 45 11. Appendix 1 Letter re Timeframes and Process....................................................... 46 This document has been prepared with the assistance of TransAction Resources Pty Ltd 12 September 2002 2 Response to EFTPOS Discussion Paper Australian Institute of Petroleum 1. Executive Summary The oil industry has been an integral part of EFTPOS since its inception and has been crucial to its on-going success. The oil companies have made a considerable investment in EFTPOS infrastructure; they are major stakeholders in the EFTPOS system and must be part of any decision making process on its future. At the service stations of the four major oil companies involved in this submission, almost 300 million total card transactions worth some $11 billion dollars were made in 2001. 16% of all EFTPOS transactions in Australia were conducted at these service stations. The Review Process It is essential that any review of EFTPOS must be balanced, transparent and objective. The AIP does not believe these criteria are currently being met. The current structure allows an unrepresentative sub-group to control this review and make the final recommendations to the Reserve Bank. The Working Group should be reconstituted to be fully representative of the major stakeholders, including the oil companies. The EFTPOS Industry Working Group must outline a timetable for reform and a process for industry consultation. The scope of the review should be expanded to cover all debit cards. There is a trend emerging around the world where scheme based debit cards are replacing proprietary debit card systems, invariably with higher costs and usually with an ad valorem interchange fee. It is possible that the local EFTPOS cards could be switched to “scheme” cards in the future, thereby rendering impotent any outcomes of this review if it is restricted to only the local EFTPOS system. The Australian EFTPOS System The current system is world class with all transactions being PIN authorised and with on-line checking of the account balance. Mr Manuel Rio, an international expert on payment systems, has said: “It [the Australian EFTPOS system] is considered to be the best in the world in terms of quality, convenience, safety, technological advancements, overall cost, reliability, processing speeds and increased efficiency.” The RBA/ACCC study has shown that debit cards are the lowest cost card payment instruments in Australia. This is supported by data from the Australian Retailers Association which shows debit cards are the lowest cost method of payment at retail outlets and are cheaper than credit and charge cards, cheques and cash. The current interchange arrangements have been central to the success of Australia’s EFTPOS system. They have provided incentive for acquirers and merchants to invest in infrastructure. This has allowed Australia to have the highest penetration of points of access to banking services and highest penetration of EFTPOS machines of the 12 major countries studied by the Bank for International Settlements (BIS). In fact, the countries with the highest penetration of EFTPOS terminals (Australia) and highest EFTPOS usage per head of population (New Zealand) both have negative interchange - this is not a coincidence. 12 September 2002 3 Response to EFTPOS Discussion Paper Australian Institute of Petroleum The BIS, which is comprised of the major central banks around the world, including the RBA, defines interchange as a “transaction fee set by the network organisation and paid by the card issuing institution to the acquiring institution for the cost of deploying and maintaining ATMs and EFTPOS terminals.” In other words, the international banking body responsible for payments and settlements supports negative interchange for EFTPOS. There are a number of examples around the world where issuers make payments to acquirers in recognition of the investment made in providing the acquiring infrastructure. It should also be noted that when debit cards are used at an ATM, interchange fees flow from the issuer to the acquirer, not just in Australia but all around the world. There seems to be no logical reason why the flow should differ when the same card is used for EFTPOS transactions. This view on the direction of interchange fees for both EFTPOS and ATMs is supported by the Bank for International Settlements. The current arrangements allow merchants to receive income from acquirers in exchange for investment in payments system infrastructure the banks would otherwise have to provide themselves. The current interchange ensures “sustainability” of EFTPOS services over the long term and provides a justification for acquirers and merchants to continue to invest in new technology needed to maintain and upgrade the network. This is one of the key objectives of the EFTPOS Industry Working Group. Should the current interchange arrangements change, it puts future major investment by the oil companies and other major retailers at risk. The primary objectives of the banks when they initiated EFTPOS in Australia was to move customers from transacting at branches to using lower cost electronic transactions. This “branch replacement strategy” has been highly successful and has allowed banks to make substantial savings through large scale branch closures, reduction in over-the-counter transactions and reduction in paper processing and cheques. Any analysis of EFTPOS costs must take account of these savings that have accrued to the banks. An important element of the current bilateral interchange fee arrangement is that it allows for fees to be set as the result of normal competitive processes. The current interchange flow also adheres to the commercially sensible “user pays” principle. There is simply no evidence that there are any problems with the current EFTPOS interchange arrangements. In fact, to the contrary, there is much
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