1 ICBI Operational Excellence What do Banks Really Need to do to Address the Issues of Business and Operational Excellence? How will the Long Arm of Regulation Continue to Impact Banking Operations? September 2010 BOB LYDDON – IBOS ASSOCIATION 2 The Payments business is not on a convergence trend ● Harmonisation within the EU / EEA has hit the buffers Politicians’ stated aim Cut 2% GDP off cost of payments Direct Payments Status Only 4% migration to SEPA instead of the critical mass that should, by end of 2010, have made migration irreversible (SEPA Roadmap 2004) Fewer Interbank events Layered Market XML no longer integral to ISO20022 or SEPA More room for national flavours ● Maxi-SEPA, universal usage of XML are not “just around the corner”…. 3 Impact of latest regulations Reg 924/2009 - partial abolition of CBR - reachability for SEPA Core Direct Debit - no MBPs after 2012 PSD - float income reduction - increased responsibilities and risk - new entrants with passports SMED - mandatory adoption of SEPA schemes - but with many safety valves - national variations/”niche” schemes More complexity Lower price Latest “Industry” developments SWIFT - standards co-existence - no retirements dates for MT - E&I and n92, 95, 96 co-exist beyond 2012 SEPA - SEPA does not mean XML any longer - “essential requirements” discussion - permits national variations/data formats - Credeuro (XCT) is SEPA-compliant - “niche” schemes formally excluded (RIBA) Standards convergence no longer on the agenda Proliferation and complexity Very low migration to SEPA instruments so far (see Appendix with STEP2 statistics including for Credeuro) 4 EU Vision for future market structure: away from Vertical to Horizontal Integration VERTICAL = BANK Acquisition Customer Access Systems Processing Operations and data centres 5 HORIZONTAL Direct SWIFT Access Bank-owned Channels Mobile Social Networks Activities requiring Banking Licence or Payment Institution Licence Processors of non-licensed activities Communications Own backbone Clearing & Shareholdings Direct memberships Sub-memberships Settlement Correspondents SWIFT PEACHes ISPs ACHs BT Radianz Net Settlement Systems Banks Final Settlement activities: ● Direct RTGS membership ● Banks Only two areas of activity are the unalterable preserve of Banks: Activities requiring a full Banking License (as opposed to a PI or eMI) RTGS clearing membership EPC Design Model for Card Schemes (Source EPC) Cards market model is already layered EPC design encapsulates this 6 7 EPC Design Model for Payments (Source EPC) Layered – big change from status quo More layers and more complex than for Cards In principle a lot of space for non-bank “horizontal” players 8 Cards vs Payments Cards Payments Schemes Concentration of volume on Visa and Mastercard Distribution over many CSMs to avoid duopoly Standards Rigid definitions from the centre Space for community-defined variations in the form of Additional Optional Services and Value-Added Services Performance High speed, high volume, interoperable Bigger message size (XML) and usage of SWIFT (which runs on the lines of Equant etc) could compete with public internet usage Message size x line capacity x routing facilities >> quick response time 9 SWIFT Standards Co-Existence IR 535 IR 535 approved at SWIFT’s June Board Meeting is a major change of position: Migration to XML is non-mandatory: no end dates for MT ISO20022 does not automatically imply XML as the physical layer The UML level (actors, data, process) is the fulcrum By extension any Scheme that fulfils the EPC Rulebooks and the UML models can be SEPA-compliant – it does not have to use XML 10 Industry Utilities Layered market should create many opportunities for industry utilities For activities not needing a banking licence Should banks lead this? What is the track record in collaborative, self-regulatory ventures? What activities and tasks could be delegated to industry utilities? What would be the hand-offs to them as Inputs to their Processes, and how would their Process Outputs be re-integrated into the banks’ processing flow? 11 Simple Outsourcing Model (Source PW) Critical Non-critical Core Do-It-Yourself Volume processer: Cheaper if output is commoditised Non-Core Professional service expert: more expensive Don’t do it at all So which actions in the payment processing flow can be outsourced and who to? Complicated in banking by the banking licence issue + VAT + no proof that the service itself is becoming harmonised. 12 Linear & Sequential Process - Amazon Enquiry Acquirer Logistics Company Fedex Warehouse Carrier Stock Check Payment Order Fulfilment Payment and Logistics are Non-Core but Critical. What about Fedex? Is there room here for a cheap volume processor? End of core activities 13 Payment Process Banking Controls PSP activities Cash / Collateral position information Choice of routing Queue Outsource Activities Communications & Security Data & Content Validation Prepare accounting entries Release Sporadic “Core and Critical” actions all the way along PSP must retain decisions on credit, routing and liquidity. Outsource does the legwork that does not require a banking licence. Multiple hand-offs during the flow Outsourced work is VAT-able towards the PSP: can the PSP reclaim it? Correspondent / Clearing 14 ACH models – direct + indirect submission Vocalink acts as an effective outsource for UK banks It prepares files of accounting entries There is no “choice of routing” for UK Credit Transfers and Direct Debits as Vocalink is the sole system Banking controls are done upfront by the posting of credit limits by system members for corporates + other FIs (who are not direct members) Those other FIs in turn post limits for their customers Three rings: not equal access for all, as required by PSD Title 2 15 ACH Payments – Credits and Debits: Submission direct to clearing DR/CR ACCOUNT Client Accounting system File upload into EB Accountholding bank Clearing System OTHER BANKS OTHER BANKS OTHER BANKS BENEFICIARIES/DEBIT PARTIES’ ACCOUNTS ACH Payments – Credits and Debits: Submission model through the bank Client Accounting system DR/CR ACCOUNT File upload into EB OTHER BANKS Account holding bank OTHER BANKS Clearing System OTHER BANKS BENEFICIARIES/DEBIT PARTIES’ ACCOUNTS 16 17 Is Cloud Computing the answer? Cloud computing is internetbased computing, whereby shared resources, software and information are provided to computers and other devices Is this the way the hand-off to Outsourcers is effected? What is the certainty that the computing resources at the Outsource remain superior to in-house ones? How nimble is this set-up when requirements change and what are the costs of change? 18 What about Blade Computing? A blade server: houses multiple server modules ("blades") in a single chassis (rectangular, usually steel frame). Used in datacenters to save space and improve system management. Massive increase in power and flexibility. Enables datacentre consolidation and shrinkage. Game-changer – allows processes to be run in much smaller scale without normal penalty of poor scale economics. What’s the environment we are going into? Proliferation of processes defying achievement of scale economics Variations in data and service level Learning from other industries: o Banking processes are not linear and can be hard to fully automate o Activity has to be strictly standardised with rigorous data and banking checks applied upfront o The Cards business and a utility model like Vocalink for UK BACS follow this line o That is not the SEPA environment as it appears to be unfolding 19 SEPA environment unlikely to be 6σ compliant Bank A SEPA Compliant ACH R-message STEP 2 Too many players Too many routing choices Expandable data requirements (VAS, AOS..) May work in small volumes to begin with As more players come on and more volumes, standard deviation moves away from the mean over time Many instances then fall outside Upper/Lower Specification Limits which are only 2σ away from the mean Not 3.4 Defects Per Million Opportunities (6σ) but 000s of DPMO non-STP rate in 15-20% range SEPA Compliant ACH R-message PEACH Bank B Account Blocked 20 What happens when more volume is brought onto SCT and the normal assumed movement of 1.5 occurs in or over time? 8 LSL μ USL Curve is7 same shape but μ moves by 1.5σ Hardly 6any instances below LSL 5 4 3 2 1 0 -3σ -2σ -1σ μ +1σ +2σ +3σ μ moves by 1.5σ because μ itself moves or σ widens 21 But huge numbers – 45% - fall outside USL Non-compliance / not STP Proliferation of official Schemes (Core, B2B..) Annual Scheme upgrades AOS 22 Conclusions The emerging environment is one of divergence, not convergence Detailed management of inputs and outputs becomes a Core and Critical function of a Transaction Bank That means “do it in-house” Whether the IT configuration can include Cloud will depend on line capacity and contention with public internet usage Blade seems to be a better bet: higher power in one place and more flexibility >> lower costs and a change of scale economies 23 Appendix EBA STEP2 Volumes as a proxy for SEPA migration: STEP2 frequently used a bridge between other CSMs Credeuro (XCT) statistics are steady SEPA Credit Transfer (SCT) statistics show steady increase: o Higher average value than XCT o Higher average value than national payments Volumes are therefore: o Cross-border payments o Corporate payments Virtually no Direct Debit volumes migrated to the SDD yet – key date is 30th November when all Euro-in banks must be reachable 24 APPENDIX: STEP2 SCT Average daily volume Average daily value July 2010 663,259 3.84 bio. euro June 2010 653,925 3.77 bio. euro May 2010 604,561 3.55 bio. euro April 2010 594,092 3.53 bio. euro March 2010 553,841 3.13 bio. euro February 2010 466,026 2.76 bio. euro 25 APPENDIX: STEP2 XCT Average daily volume Average daily value July 2010 189,292 841 mio. euro June 2010 192,439 822 mio. euro May 2010 189,131 805 mio. euro April 2010 202,067 852 mio. euro March 2010 193,253 789 mio. euro February 2010 195,586 778 mio. euro 26 APPENDIX: COMBINED STEP2 SCT & XCT Average daily volume: Average daily value: XCT + SCT XCT + SCT July 2010 852,551 4.681 bio. euro June 2010 846,364 4.592 bio. euro May 2010 793,692 4.355 bio. euro April 2010 796,159 4.382 bio. euro March 2010 747,094 3.919 bio. euro February 2010 661,612 3.538 bio. euro