The pivotal decision for merchants is how to recapitalize the anticipated saving from swipe reform and use that money as an incentive for consumers to choose a lower cost form of payment.  Many merchants, particularly in the petroleum and grocery industry are already actively competing for method of payment by offering ACH decoupled debit card programs (merchant issued debit) or cash discounts. For these merchants, and vendors offering alternative payments  like PayPal or National Payment Card Association, the Durbin Amendment is living up to expectations providing them with a strong tailwind to the merchant and consumer.

Merchants are understandably cautious as they approach payment.  While technology, investment and ramp time look like the heavy lift, the real challenge is to understand the economics.  Traditionally merchants have relied on the bank and card associations to deliver payments.  During the lead up to regulation one argument was that; “there was no competition for payment”. Merchants’ successfully argued this point, irrespective of the intense competition between banks for consumers. What was missing from the debate is that the reason consumers use one form of payment over another is often rewards. These rewards had been paid by the issuers of the card using interchange fees (as much as 50%), and now with regulation, that funding source has disappeared.  Therefore merchants can provide consumers with the same incentive to use a low cost form of payment by offering merchant issued rewards.

Finally, there is a saying “He who enrolls; controls”. Issuance or enrollment is a critical question for merchants choosing to compete for MOP using rewards. Assuming that the merchant chooses to offer rewards for a specific MOP, which MOP should it be, cash, PayPal, Google, or perhaps a merchant issued debit card.  The smartest strategy might be a flexible approach to payment where rewards are based on the costs associated with the method of payment, regardless of whether the rewards are paid for by the merchant, or a 3^rd party.

The phrase “Catch-22″ means “a no-win situation” or “a double bind” of any type. In the book, “Catch-22″, Joseph Heller describes the circular logic that confronts an airman trying to avoid combat missions by saying that his claim of insanity is the proof of his sanity. With the passage of Durbin, retailers are faced with the same circular logic. The Catch 22 of Durbin is that consumers must choose debit if retailers are to save on interchange fees, and consumers will only choose debit if offered rewards or to avoid bank fees. Today consumers choose debit in large degree to earn signature based debit reward or because PIN debit does not have bank fees as opposed to credit cards where there are annual fees and interest.  Durbin will change that paradigm as banks make up lost revenue by eliminating signature debit and adding fees to, or eliminating, pin debit cards. If those changes occur then retailers will need to fund consumer debit rewards to promote debit payment. Because merchant issued debit rewards erode Durbin’s potential cost savings, the potential is that total debit transactional fee may be higher than those during the pre-Durbin era…Catch-22.

Durbin’s challenge to Retailer’s is how to influence the consumer’s method of payment. Just because consumers are choosing Debit today, does not mean they will be choosing Debit tomorrow. The reasons why consumers choose one form of payment over another (Debit, either signature or PIN, cash, credit, check, prepaid etc.) are complex, but “Rewards” plays a large role in the process. In fact, nearly 50% of all interchange dollars are used to fund reward programs. A quick review of Bank advertising for Debit will show that Debit Rewards is tied to Signature Debit, not PIN Debit; “rewards are ” Pen, not PIN”.  Rewards for Signature Debit, plus “No Fee” PIN debit has created significant consumer demand for debit products. The banks loss of signature debit interchange fees means that these reward programs will disappear and consumers will begin paying fees for PIN debit. The result is that Durbin will change both the Debit and Payment Card market, not just the fees.

Look for these results:

1. Look for more pressure on retailers to install Pin Pads. Signature debit will go away as Financial Institutions will not longer offer signature debit. The whole point of signature debit was capture credit card like interchange fees. Debit rewards programs are funded by credit card like interchange fees and at Durbins mandated +/- 12 cents there is no “rabbit in that hole”. The reason retailer’s implemented PIN pads (3dez) were to move consumers from Pen to PIN. If Merchants are to win from Durbin, PIN Pads will play a large role in that success; otherwise there will be no debit at retail. Durbins “$10 Billion” exemption is a wild card. If smaller institutions introduce aggressive signature debit programs at the expense of larger institutions then Durbin will prove to have cost retailers more than they will save.

2. Financial Institutions will seek ways to replace lost revenue. The most immediate impact is likely to be fees on both dda accounts and perhaps the use of debit cards either as a transaction fee or monthly fee. Banks will discriminate against Debit making it less attractive. One of my associates added “Issuer’s already have plans to discontinue issuing debit cards and returning to ATM only cards.” He adds “other issuer’s are going to place a transactional cap on debit cards instead of taking them away.  They will only allow a transaction for $50.  If the transaction is $51 – then, another $1 transaction will have to run.”  Say good-bye to friendly debit transactions.

3. Watch for growth in closed loop debit card, particularly ACH Decouple Debit.

In the short term, Merchants will realize a windfall as consumers who use Debit maintain that method or payment. Debit usage will drop off unless Merchants introduce “Merchant Issued Rewards”. Merchant Issued Rewards are another name for loyalty. I can offer more on that if requested. The question retailers need to answer is: If you must offer rewards to promote debit, why not promote your own debit card? Durbin will increase the importance of loyalty rewards as merchants compete with FI’s for the consumer’s method of payment (i.e. PIN Debit).

4. Watch for more aggressive Credit Card and Pre-Paid card offerings with lower credit card fees, easier credit and more aggressive rewards. Pre-Paid is apt to be the next place the FI’s push for consumer adoption and fees. As the economy strengthens, and consumer debt drops the structural issues negatively impacting credit will lesson. Financial institutions can impact the consumer’s attitude towards credit by being more consumer friendly. The loss of signature debit will hasten this activity.

5. One “Wild Card” is the DOJ lawsuit on credit card interchange fees. There has not been a lot of press on this, but there will be soon.

Retail groups applauded Bernanke’s statements as a commitment to move forward and implement the rules set forth in the Durbin Amendment. One industry representative stating “This confirms the Fed’s commitment to putting forth a rule that has been thoroughly vetted” adding “there is no need for a congressional mandated delay.  

Meanwhile opponents of the legislation lined up for battle pinning their hopes on exactly that type of congressional mandated delay as Sen. Jon Tester attached the “Debit Interchange Fee Study Act” to the Small Business Reauthorization Act. Passage of this act would move Durbin into a two-year obscurity as quickly as it originally appeared.

The confusion now extends to consumers who are equally puzzled as more information on Durbin’s impact makes it into the main stream press. Last week a Time Magazine article by Bill Saporitio explained to consumers that they may see lower retailer prices as a result of lower fees while warning that free checking may also vanish along with rising bank fees. Hilary Shelton, Washington Bureau Director for the NAACP echoed the same concern when she testified saying “that Regulators should guarantee it (the rule) wouldn’t push poor and minority consumers out of the banking systems”. Consumers are left wondering, is this good or bad? 

(http://www.linkedin.com/in/peterguidi)

Thus far, the majority of interest in Durbin is focused on the impact of interchange fee regulation with little attention on the second aspect of the provision; network exclusivity and transaction routing. Durbin has two provisions, the second of which says “that neither the issuers nor network may restrict the ability of merchants to direct the routing of the transaction”.  The rule is intended to foster competition between networks. The concept being that when at least two unaffiliated networks compete for transaction routing, the price merchants pay will optimize.

The Board is requesting comment on two alternative rules prohibiting network exclusivity: one alternative would require at least two unaffiliated networks per debit card, and the other would require at least two unaffiliated networks for each type of transaction authorization method. Under both alternatives, “the issuers and networks would be prohibited from inhibiting a merchant’s ability to direct the routing of an electronic debit transaction over any network that may process such transactions.” Some have suggested that the answer to this question lies in the currently available least-cost routing selections available to consumers between PIN and Signature debit. In this scenario debit cross-routing is the solution to network exclusivity. One expert suggests that “one such solution would be Visa for signature debit and Maestro for PIN debit. They are not affiliated, and thus fulfill the requirements of the first alternative.” The existence of the second alternative makes it clear that the Fed has not yet decided whether signature and PIN debit are one market.”

The contradiction is between the intent of the regulation and the Boards’ rule making process.  The differentiation between routing based on a transaction or a card may delineate the type of routing available, but it does little to foster routing competiveness. The intent of the regulation is to foster competition between networks.  Allowing the Issuer to choose the second network by pitting the PIN and Signature networks against each other is a weak proposal. On the other hand, if merchants choose the second network from a multitude of routing options competition will emerge, but how does that work? In order for the merchant to have a choice between a variety of networks, Issuers would have to support routing on all networks. In this scenario merchants might choose different networks on a location or regional basis? Implementing this type of network routing matrix will mean substantial changes in the infrastructure and business rules. The time and effort to create such a system is currently unknown. If competition between networks is the congressional goal this seems to be the correct interpretation.

The alternative interpretation is for the Issuer to offer the merchant a choice of two networks. In this case every Issuer would be forced to offer two networks for processing a transaction.  As an example, Visa and MC may have to route each other’s transactions. The merchant would be able to choose which of the two available networks to route the transaction.  Presumably, creating competition. As a result the merchant would choose the cheaper of the two. However, this scenario does not assure the merchant choice and adds the possibility that the Issuer could offer a second network with higher fees. In this case the second network would be the more costly option resulting in no opportunity for merchant savings.

How a two-network solution is allowed under the final version of the regulations remains unknown. It does seem that merchant choice fits congressional intent more clearly than Issuer choice, even if the technical challenges and costs to develop such a system are currently not contemplated or that the rule making process appears to miss the point.

(http://www.linkedin.com/in/peterguidi)

The Blog-Health-o-Meter™ reads This blog is doing awesome!.

Crunchy numbers

The Leaning Tower of Pisa has 296 steps to reach the top. This blog was viewed about 1,000 times in 2010. If those were steps, it would have climbed the Leaning Tower of Pisa 3 times

In 2010, there were 22 new posts, growing the total archive of this blog to 35 posts.

The busiest day of the year was October 27th with 27 views. The most popular post that day was Competitive opportunity in a post Durbin world: richer debit rewards as the unintended consequence of the $10 billion exclusion..

Where did they come from?

The top referring sites in 2010 were linkedin.com, bigextracash.com, twitter.com, pymnts.com, and WordPress Dashboard.

Some visitors came searching, mostly for closed loop payment system, open loop payment system, coalition marketing, peter guidi, and reasonable and proportional.

Attractions in 2010

These are the posts and pages that got the most views in 2010.

Competitive opportunity in a post Durbin world: richer debit rewards as the unintended consequence of the $10 billion exclusion. October 2010
2 comments

What decision factors should retailers use when choosing between an open-loop vs. closed-loop alternative payment solutions? April 2010
2 comments

Does regulated debit “Swipe Fees” mean the end of cobranded debit card programs? June 2010

“Reasonable and proportional”, is issuance and the cost of reward programs a part of the “incurred payment processing costs”? June 2010

Orwellian market principals; is legislation regulating interchange fees a harbinger of greater merchant acceptance of government control over industry? March 2010

NRF Senior Vice President and General Counsel Mallory Duncan said. “The combination of reducing rates and allowing retailers to offer discounts will go a long way toward stopping the current scheme where big banks take a bite out of consumers’ wallets every time they use a debit card.” He goes on to say that the NFR “will work closely with the Fed as these regulations are finalized to ensure that the reduction in fees – and the amount of money retailers can offer customers as a discount – is maximized.” And so it seems that the stage is set for retailers to offers consumers discounts if and when they use a debit card to pay for their purchase.

In a recent article published in PYMNTS, Katherine M. Robison of O’Melveny & Myers LLP says that “while the Board says it understands and appreciates the importance of debit cards to consumers, it is disturbing how little the interests of consumers entered into its justification for the Proposal”.  She goes on to say that “The debit card market is a two-sided one, with merchants who accept debit cards on one side and consumers who use them on the other.” Her point being that in this two-sided market an action that may decrease consumers’ demand for debit (say by making debit transactions less appealing to them) will ultimately decrease the utility of debit to merchants.  Further, if Banks add fees to the checking account or the use of the debit card while eliminating reward programs consumers will also find debit less appealing. She adds “So while lower interchange fees may encourage more merchants to accept debit cards, at that point there may be fewer consumers who want to use them.” Enter the role of merchant issued rewards.

Consumers could benefit from a rewards battle between merchants and banks for their method of payment. On one side will be the issuers of credit cards, on the other will be the retailer and the winner could be consumer as they rack up rewards by choosing either credit or debit. Their choice will be simple, choose to use a bank issued credit card and earn rewards like airline miles, or choose a debit card (either bank or merchant issued) and earn retailer funded rewards. The decision will be based on which offer the consumer finds more attractive? 

Over the last five years a variety of alternative payment providers. Like National Payment Card Association, have brought forth payment technologies like merchant issued debit cards designed to circumvent the traditional payment processing network delivering a lower cost transaction to the retailer. Now with the Fed’s proposed interpretation of the rule, bank issued debit cards will carry similar fees and so the retailers will face an analogous implementation challenge. How does a merchant motivate a consumer to use a lower cost form of payment? Merchant rewards are the obvious answer. And so the question is; will retailers recapitalize the cost difference between a traditional credit card transaction and the new debit fee and use the savings as a reward? And if not, why would the consumer choose to use a debit card rather than a credit card? Retailers will face a variety of challenges leveraging these new fees to their advantage.  Most notably is that the possibility that a debit transaction with merchant funded rewards may actually cost more than the original bank fee for a debit transaction. 

(http://www.linkedin.com/in/peterguidi)

Retailers can avoid the “rush to the bottom” by focusing on “Customer Engagement”. Customer Engagement is about strengthening the emotional and psychological affinity a customer has with a retailer. Consumer loyalty is the best measure of current and future customer purchasing behavior. The most effective way to increase a consumer’s engagement with a retailer is by stimulating the consumer’s loyalty. Retailers can change the consumer engagement paradigm by utilizing a loyalty platform to create and leverage “network effects” to drive affinity.

Customer Engagement typically refers to the engagement of customers with a retailer rather than a brand; a loyalty platform can change that paradigm. When retailers add vendor supported incentives to a loyalty program, the program develops network effects. Network Effects are in play when consumer’s access brand (and retailer) supported benefits through the platform. The retailer, who owns the platform, experiences the value of the network effects when consumers shop in their store. Proprietary loyalty programs are closed loop platforms that leverage network effects to drive customer engagement. Coalition point based programs like “Air Miles” is an example of an open-loop loyalty program that exhibit network effects. Like all platforms, loyalty programs require two different parties to adopt the network to be viable; in this case it is either the vendor or retailer offering incentive on one side of the loyalty platform with the consumer and their desire to enjoy the incentive on the other side.

Loyalty platforms are the tool retailers can use to create the customer engagement needed to compete and win in this new social, technological consumer market. Creating an engaging dialogue with consumers and motivating their loyalty with the retailer is the key to driving both sales and margin. (http://www.linkedin.com/in/peterguidi)

Under Durbin’s “reasonable debit fee requirement,” there is an exemption for banks and credit unions with assets under $10 billion (this includes 99% of all banks and credit unions). This means that Visa and MasterCard can continue to set the same debit interchange rates that they do today for small banks and credit unions.  Those institutions would not lose any interchange revenue that they currently receive; in fact they could receive even higher rates. Many experts writing on Durbin have concluded that this exception will be meaningless because the networks will be unable to accommodate multiple fee structures and as a result, while exempt, interchange fess on those financial institutions will suffer along with their larger brethren.

The argument is that the required costs and effort, such as network IT changes to accommodate multiple interchange fees, make this outcome unlikely. The recognition that business pressure from small banks and credit unions on the networks, Congress or the Fed could leave the networks with little choice but to develop a two tiered fee structure may alter this conclusion. A few weeks back, TCF, an issuer whose business is above the $10 billion exemption, filed a lawsuit stating, “the thousands of banks exempted from the amendment will be free to continue to charge retailers the current debit-card interchange rate and recover all their cost plus a profit. This will result in an irrational competitive disadvantage for banks like TCF that are subject to the new regulations.” It appears from TCF statements that the idea of 7000 smaller financial institutions issuing a new class of richer debit reward cards seems not only plausible, but probable, and a real threat to their business. The focus on the challenges associated with creating a network pricing schema that allows for multiple interchange rates, rather than discussing the market dynamics, is missing the business opportunity.

The reason this will happen is that the payment card industry is a two-sided market. Durbin treats the payment industry like a utility, but this analysis is mistaken. Durbin and its proponents have argued that the payment card industry lacked competition. This falsity, propelled by an active merchant lobby, found resonance in Congress. In reality, the payment card business is a highly competitive marketplace. It just happens that the competition is between financial institutions fighting for a larger share of the consumer market. The result of this competition is higher fees to those wishing access to the market.  Durbin seeks to upset this market, ignoring the two-sided market economics driving consumer demand.

Consumers will move their purchasing to whatever product provides the most incentives. Merchants will accept the business from any large group of consumers, and Durbin does not allow merchants to discriminate by issuer on a network. What this means is that smaller financial institutions will introduce richer debit rewards programs attracting larger shares of consumers who will then shop at retail locations using those cards. Retailers will not turn customers away because payment method would be become a factor in the consumers choice of retailers, something no marketing department will allow.  This is the result of network effects, and they are the unavoidable economic reality driving the industry. The resulting competitive dynamic is in play: issuers will want to try to drive up fees on the merchant side of the market, delivering greater rewards on the consumer side. Consumers will look for low-fee banking services and richer rewards that are supported by these programs. As a result, millions of consumers will gravitate from the 90 or so issuers affected by Durbin to the 7000 who are excluded. This looks like opportunity.

The real question is how long it will take the networks to code the system to handle multiple prices for issuers. I’d be surprised if the work was not already well underway and available not long after the Fed sets its rates. Durbin will have closed the door on the top 90 issuers, essentially putting them at a competitive disadvantage. But in closing that door, the way has been cleared the remaining 7000 financial institutions to develop their debit rewards business. In many ways Durbin did for the network what they could not do themselves; i.e Durbin eliminated the power of the major issuers and opened the market to the smaller financial institutions.

The TCF lawsuit has been both ballyhooed and scoffed at.  No matter the outcome in court, the case will have an impact on the industry. If Durbin passes all of its legal challenges, the irony may be that the consumer will benefit as a result of richer rewards programs from smaller issuers, and merchants will see card acceptance costs rise taking no comfort knowing that they won a battle but lost the war.

The second school of thought has a different perspective on pricing and strategy. These retailers believe that consumer’s make purchasing decisions for a complex set of reasons and that their behavior can be motivated by incentive. In this model the customer’s loyalty is critical to business success. The concept is to track, measure, and then provide specific incentives to individuals based on their demonstrated purchasing behavior. This science is the most effective use of marketing budgets and is focused on increasing business with each current customer. This is the rifle shot, one bullet for each customer.

At the end of the day it’s all about profit. Profit is the difference between success and failure.  When it comes time to pay the bills, or dividends, the only number that matters is the “bottom line”, you either earn a profit or you go out of business, “no margin, no mission”. Regardless of strategy, every program, and every effort must have an ROI. The objective is to make money; buy low, and sell high. It’s hard to make up a loss on volume!  Successful retailers negotiate for the best price, terms & conditions and then set prices and launch promotions that will motivate more profitable customer purchasing thus, maximizing profit. Earning a profit is the battle you fight with yourself as you pick the right price point to execute your sales strategy.  It takes cunning and courage to set solid price points, avoiding the traps of promotional discounts that erode margin simply to increase “top line” performance. Does your sales strategy drive more profitable sales, or is your strategy to be the low priced retailer turning over inventory for increased sales?

In every contest there is a moment when the game is decided. A touch-down or goal is scored, a home run hit, or a competitor’s doors shuttered. Retail is a lot like sports. Taking the lead and then winning the contest is about momentum and emotion. Employees and customers must be engaged, excited and motivated to participate. Success is defined as both top-line and bottom-line growth. Company strategy needs to set realistic goals designed to achieve long term success. Retailers use incentives to motivate employees and engage customers.  Incentives without loyalty programs are simply discounts.  Discounts erode margin. Loyalty programs increases both top line growth and increased profits. 

(http://www.linkedin.com/in/peterguidi)

There are numerous types of loyalty programs, clubs, instant discounts and others. In the c-store space, one of the most significant questions being asked is: what type of loyalty program to launch? The more sophisticated loyalty programs are based on “platform” economics and work to develop networks of consumers and retailers. In the c-store/petroleum space there are two popular programs available; “Coalition and Community”

Recently, the industry has been “a buzz” with news of “Community” loyalty programs linking major oil companies and gargantuan grocery chains together in “cents off per gallon” promotions. In these programs the c-store/petroleum retailers are a “redemption center” for the program. The question is; are “Groceries for Gallons” a good deal for the c-store retailer? The answer requires an understanding of the difference between coalition and community programs. The importance of this distinction is critical.

In a community program, the retailer is a “redemption depot”, storing the reward (gas) while the grocer sells groceries by giving away gas. These programs move a lot of gallons, but how do they motivate the consumer to purchase other products from the c-store?

In a coalition program the c-store is the owner of the alternative currency (points) both “issuing and redeeming” the currency. In a coalition program, the c-store is “selling” points to coalition partners. Each point is sold at a profit. The c-store earns a profit when the point is sold, rather than redeemed.

Coalition programs put the c-store at the center of a powerful marketing program designed to build profit for all members. Coalition programs motivate consumers’ to purchase more products with greater frequency from both the c-store and the coalition members. 

Summed up, in a Community program the c-store retailer is building someone else’s business, with coalition programs the c-store is building their business. The choice seems clear; coalition is the path to growth and profit. (http://www.linkedin.com/in/peterguidi)