Mount Gox tumbles off the learning-curve

This week, Mount Gox, a very large provider of bitcoin services, couldn't live up any more to its services agreements with bitcoin users. It provided exchange and storage services for bitcoins, but due to a technical implementation flaw, the bitcoin holdings of users were compromised. Essentially it wasn't clear who really owned the bitcoins. The website went black and users can no longer claim their bitcoins.

Tumbling off the learning curve
I view the failure of Mt Gox as a logical consequence of the learning curve that bitcoin holders and bitcoin companies face. The bitcoin, although considered decentralized, is just as centralised a system as any other value transfer mechanism. However, for ideological reasons, the developers chose to only describe the technical heart of the system (the algorithm) leaving the rest up to the market.

This open source code approach has some advantages, among which a very speedy development of applications. Yet, we are for some time now witnessing what it means if systems lack a central authority or scheme manager. There is no entity taking responsibility and chasing users or companies because they don't abide by:
- usage conditions (demanding user identification),
- security requirements and certification of tools,
- specific legal frameworks.

As a result we have seen a whole community of interested companies and users climbing up the payments, banking, investments and monetary learning curve. The inevitable consequence is that those who do not get it right, will pay a price, while the others continue to learn. Due to the digital nature of bitcoin, these developments unfold rapidly, allowing us a compressed overview of lessons from financial history.

Frijda's theory of money (1914)
The essential lesson at stake is that the usage of any value transfer mechanism does not just rest on its acceptance by users, but just as well on the rules and regulations that underly the value transfer. In 1914, the Dutch lawyer Frijda analysed this topic in his dissertation on the theory of money. At that time discussions emerged on the nature of banknotes. Did they have value because they were exchangeable for bullion, because they were defined as legal tender or because the public used and accepted it?

Frijda pointed out that the underlying legal framework that safeguards property in a society constitute a necessary precondition for the use of payment instruments. Without such safeguards, people will tend to stick to other stores of value rather than attaching value to local bank notes. Until today this effect is clearly visible: consumers tend to hold and use foreign cash or commodities if they live in country with a lot of curruption, a weak system of justice and an instable monetary climate.

Trust is built by institutions and markets
What makes money tick is a solid institutional basis, upon which trust can be further developed. The latter part can be done by a combination of regulation (supervision) and self-regulation (market action). Which brings us back to the Mt Gox case.

Following the events of this week, a statement was released by the bitcoin companies Coinbase, Kraken, BitStamp, Circle, and BTC China. The industry leaders committ to safeguarding the assets of customers, to applying strong security measures, to using independent auditors to ensure integrity of their systems and to have adequate balance sheets and reserves to be able to ensure continuity.

In sum we can now see both a gradual development of both the institutional framework for virtual currencies and the market-driven self-regulation. This reflects the fact that - whether you like it or not - trust for financial services is always built on institutions, regulations and self-regulation.

The bitlicense: current state of thinking in New York

A week ago, the New America Foundation organised a meeting (Cryptocurrencies, the new coin of the realm) on the topic of virtual currencies and regulation in New York. Some news bulletins picked up on the meeting and the future New York Bitlicense regime. The good thing is that the New America Foundation has streamed the whole event, so it allows me (and you) to listen first hand to the speech by Benjamin M. Lawsky, Superintendent of Financial Services, New York State Department of Financial Services (DFS).

I will outline some of the highlights of his contribution below as I think that the New York discussion represents a good example of the issues at stake when it comes to regulation of Bitcoin. I expect to further touch on those issues in my contribution to the Bitcoin Pre-conference expert session of the EPCA-summit in Brussels (March 12-13).

Open source code currencies and open source code regulation
In his speech, Lawsky outlines the current remit of the NY department of Financial Services. It acts as the supervisor for money transmission companies in New York. The DFS-starting point is therefore that in some instances dealing with virtual money may effectively constitute money transmission, which needs to be regulatred. This is similar to the approach in the FINcen guidance of one year ago.

The New York regulator chose to emulate the open source code approach of virtual currencies. And thus, Lawsky refers to the DFS-approach as 'open source code regulation': regulation based on a public exchange of thoughts, allowing the best insights to be used. Given their current remit, the main idea is to see where the money transmitter rules need to change in order to suit the nature of virtual currencies.

As for the further process in 2014, Lawsky explained that the DFS will move towards further regulation this year and will most likely hold a  market consultation for the proposed regulatory framework for companies that want a so-called 'bit-license.'

What will the bitlicense be like?
When listening to the speech, my impression is that the core fundamentals of the bitlicense will be:
- very strong customer disclosure, requiring companies to outline that transactions are irreversible and that the digital currency may be very volatile,
- a strict adherence to know-your-customer requirements, essentially demanding that anti-money laundering rules are adhered to,
- a robustness/capital requirement, ensuring that the company will be able to withstand some of the market shocks that may occur when dealing with volatile digital currencies/commodities,
- safety and soundness requirements, ensuring a certain quality of operations and consumer protection.

As for the nature of capital and collateral requirements, the DFS is still wrestling with the concept of virtual currencies. This has to do with the angle and object of regulation. While it is easy to require capital safeguards for banks that deal with attracting and lending money, this is harder to apply for companies that issue, distribute or redeem virtual currencies.

Similar questions arise when defining the scope of transaction monitoring. Should only the purchase and redeem-transactions be subject to rules or does the supervision extend to a full transaction logging of all transactions with the virtual currency? Should those transactions be in a public ledger and to which extend can they be anonimized?

Step-up regulatory approach with a safe harbour
Although the DFS is still contemplating its exact licensing regime, I expect it to also contain a safe harbour provision. This would allow companies that comply with customer disclosure and know-your-customer rules, to continue to operate, while further obtaining the full bitlicense. Such a regime would assist in lowering the barriers for virtual currency platforms/traders/exchanges and create an easy entry towards the proper regulatory regime.

Lawsky outlined that the regulator prefers companies to be in his state and regulated, rather than driven off-shore. A safe harbour rule helps achieve that and fits a model where a light-weight, low-barrier entry model is developed to prevent legitimate providers from leaving the jurisdiction, while creating a sufficient barrier for the illegitimate players in the market. This is also a realistic approach considering the alternative channels for illegitimate behaviour: cash and banks. In the words of Lawsky:

Let's be frank: a lot more money has been laundered through banks than through virtual currencies'

Boldly go where no man has gone before?
I commend the DFS for their open minded approach to the topic of regulation of virtual currencies. I do disagree however with one of the remarks of the Superintendent. He outlined that regulators are in new and unchartered waters when it comes to virtual currencies.

I don't think they are.

Since day and age, people have used all kinds of symbols, coins and means of representation of goods that worked fine for transferring ownership of property. We created a number of laws and institutions to ensure these property rights and a fair treatment of parties to certain contracts. In doing so we were able to move from coins to paper-based money to deposit accounts. At the same time we created digital representations of shares, bonds, IOUs and agreed that ledgers at private companies and government institutions could officially represent a claim on goods, services, bits of land, anything.

Then, when it comes to new forms of money, we also have recent experience. In the late 1990s we witnessed a very similar type of discussion on bank supervision and specialised supervision regimes for new forms of 'electronic-money' as it was called in those days. It took some time and deliberation to get to grips with pre-paid digital representations of fiat-currencies, but we found our way in the end.

The challenge: finding the right regulatory framework
The true challenge is to first consider the fundamental nature of virtual currencies and then determine the appropriate regulatory framework. In essence, the DFS is doing the reverse as their starting point is their existing legal competence as supervisor of money transmitter businesses. While there is a lot of logic to it, it might be useful to reconsider alternative types of regulation that exist.

It's my hunch that perhaps an exchange/trade oriënted regulatory framework might make more sense as the basis for regulation, than the money transmitter framework. So that is what I will explore in my next blog.

Towards a more flexible approach of authentication

In July last year, the European Commission published a proposalfor a revised Payment Services Directive (PSD). The proposal draws on the work of the SecuRePay forum of supervisors and requires ‘strong customer authentication’ when a payer initiates an electronic payment transaction.

Strong authentication
Strong authentication is defined as a procedure for the validation of the identification of a natural or legal person based on two or more elements categorized as knowledge, possession and inherence. These elements are independent, in that the breach of one does not compromise the reliability of the others and is designed in such a way as to protect the confidentiality of the authentication data.

The concept of strong authentication is in itself nothing new. What is new however, is its appearance as a detailed regulatory requirement. So far, both the Payment Services Directive and the Electronic Money Directive contained a more generic requirement for licensed operators to demonstrate that their governance arrangements, control mechanisms and procedures are proportionate, appropriate, sound and adequate. This allows for a system wide supervisory review of risks and security measures.

The current approach in both the envisaged PSD and Recommendations of the supervisors in Europe is however to take out and stress one element of the risk/security puzzle. This approach may turn out to be counterproductive and be an impediment to achieve retail payments that are as secure, efficient and as frictionless as possible.

Different market approaches to customer authentication
Traditionally the banking sector and card schemes have played a major role in the payments industry. For a long time they acted as the main channel through which new technological developments were introduced. In this process, strong authentication in a range of countries became a standard for use in payments. Further security measures for use in transactions over the Internet were then being developed as an add-on to the basic design.

More recently, Electronic Money Institutions (EMIs) and Payment Service Providers (PSPs) have entered the payments value chain using the Internet as their basic transaction processing initiation channel. As a result, their approach to payment security tends to be based on a variety of methods, to be able to counter a range of attacks associated with this inherently unsafe environment. PSPs have had to move very quickly up the e-payment security learning curve and found out that they must remain vigilant with respect to new threats. PSPs are consistently using additional information (geo-location information, IP address matching, IP address pattern detection, industry blacklists, comparison against a customer’s existing “profile” etc.) to validate the interaction with a user.

There is still much to gain by combining the expertise of both the “classic” and more recently-established providers of payment services. Customers will be using all kinds of devices as a service entry point; this requires a flexible approach to authentication. Rather than two-factor authentication we could speak of multi-factor authentication, which would include the specific user-payment service provider interaction context. But that is not all.

Stuck with two-factor customer authentication?
The analytical flaw that underlies the SecurePay recommendations is its strong focus on too detailed a part of the business and security process: customer authentication. Of course this is quite an important element of the transaction process, but the overall security of (mobile) retail payments is always achieved by a proper combination of security measures.

Customers, devices, processes and issuers should all be authenticated properly. And any risk control structure does not just rest on authentication but on a wide array of logical and functional controls. These controls may sometimes be labeled: 'fraud detection' but the quality of the risk prevention that they achieve can be just as good as one of the classic factors, that are not in the definition of strong authentication.

It is evident that new authentication measures and security challenges are being used and developed to achieve a level of security in retail payments which is contingent on the risks that are relevant in the user-transaction-device context. We can witness this in the bank, card, Internet and mobile payment domain. As these developments occur, it is unwise to freeze one detailed building block of security measures into a regulatory requirement. This will skew the market into less efficient and more cumbersome customer experiences, while technically not necessarily safeguarding a strong level of security.

In particular the mobile domain allows for a wide array of additional capabilities to achieve the security levels that supervisors desire. It would therefore be wrong to make the low-value threshold of the PSD the dividing line between strong and alternative customer authentication measures. A better approach is to link the degree of authentication to the degree of risks and the further security measures that are in place. This will allow the market to develop solutions that achieve both ease of use to the consumer and the desired level of security.

A more future-proof approach
It is not unlikely that the envisaged inclusion of a detailed requirement on strong customer authentication may distort the current market developments rather than allow for further innovation and market development. A more future-proof approach is desirable.

In my view such an approach would be to allow for a broader 'multi-factor authentication' which includes authentication based on the user-interaction context. In addition it would be good to recognise that the quality of some of the security measures which are often labeled: 'fraud detection' may have become such that they achieve a similar level of security as the traditional authentication factors.

We should also allow alternative authentication mechanisms to be used, dependent on the risk involved, rather than a certain value threshold. It would then be up to the supervisors to make the context-based and risk-based assessments on the whole array of security measures as a part of their supervisor reviews.

This approach should ideally be complemented by excluding todays specific definitions of strong authentication from the wording of the Payment Services Directive and replacing them with a generic reference to the relevant security recommendations.

The result would then be that we will have a clear and flexible security requirements framework in Europe that sets the boundaries within which the market can futher innovate and develop.

Is a 'democratic' crowd based cryptocurrency just as fair as the traditional ones?

Having gone through my daily portion of Bitcoin-reads (and being somewhat sceptic), it struck me that one of the compelling arguments of collective currencies: 'money to the people' is highly flawed. It is the strong resentment against governments and financial institutions that makes many people believe that it would be good to take the power of money-creation out of governments' hands. But what would happen if we would indeed forget for a moment about the governments?

Crowd based currencies: exclusive and leading to private gains
As nice as it appears, these new currencies will then not be as evenly spread as the current ones in existence. There is quite bit of knowledge and expertise involved in obtaining, developing and working with new crowd-based currencies. So the 'democratic' nature of these currencies is not as democratic as we may think. The amount of people that may vote and can use cash is considerably wider than the amount of people able to use or make virtual currencies. 

We should realise ourselves that in essence, any currency, whether it is a government-owned or private in nature, leads to a certain distribution of value and wealth for the issuer and among the user base. And the question that is not being asked, at present, is whether the new crowd-based currencies will distort the distribution of value and wealth in society? Nor do we ask ourselves the question if we would prefer to be subject to the consequences of behaviour of (collective) private entities, manipulating a currency while we can't influence them, instead of a government structure (however flawed it may appear).

The redistribution of value that can occurs with these new currencies may look democratic, but that is a wolfe in sheep' s clothes. Effectively the new currencies are and will be the domain of private individuals trying to seek private gain rather than anything else. And there is no guarantee whatsoever that this constellation will have the interests at heart of all people in society. It will be Darwins' survival of the fittest all over again, which will exclude certain groups of citizens from participating fully in society. As democratic as a crowdbased currency looks: you will still be a puppet but on a different string, with unknown gains being made by unknown players in the value chain of this collective currency.

Currencies should be as fair as possible
Thus, the claim that crowd-based exchange mechanisms or digital currencies are more democratic than the existing ones must be strongly rejected. They are not and they lead to a very uneven an undemocratic redistribution of value in society. The central question in this debate should be which institutional design prevents the most harm from being done. 

Despite all the existing flaws that may be present in our governments or current monetary situation, the truly democratic currencies and those that may do the least harm are those operated by the governments that we can vote in or out.

Bitcoin legal classification in Germany: much ado about ... ?

These days I noticed an interesting discussion in my Twitter time line and on the web on the fact that the German government has 'recognized' Bitcoins (even as legal tender, as cnbc reported for some time). There were many reports on the matter, outlining that Bitcoin is apparently gaining further acceptance among regulators. But as the reports were a bit confusing I felt it would be good to track the sources.

German MP Schäfflers enquired about tax-treatment for Bitcoins
It turns out that a German MP, Frank Schäfflers, has been asking his Ministry of Finance how the taxation rules applies in situations where people use Bitcoin as an instrument of trade/payment. And later on he asked a follow up question whether or not the use of Bitcoins as a payment mechanism would be exempt from VAT (as is the case with German legal tender). Here is the link to the source documents.

The German Ministry of Finance outlined in its response that:
- commercial transactions where bitcoins are being used for payment, have the tax regime on the basis of the transactions' commercial nature; so the use of bitcoins doesn't disturb the regular taxation rules,
- goverment agencies are still discussing how to tax the value increase of bitcoin holdings over a year,
- bitcoins are not legal tender, nor e-money, but a form of private currency which classify as 'Devisen oder Rechnungseinheiten': under the German supervision law (article 11, sub 7).

The Rechnungseinheiten can be translated as unit of accounts, but the explanation of the German Ministry of Finance is that this definition covers - amongst others- all private currencies or units of accounts which are not based on legal tender. Essentially is a catch-all definition to capture any sort of privately agreed payment mechanism that can be used in multilateral clearing or settlement.

The regulatory logic: classification rather than recognition
While to the observer it may appear that the German regulator is leapfrogging into the modern world by outlining the status of bitcoin, the reality may be less exciting. The German Ministry of Finance merely outlined how, given the existing rules on taxation and payments, bitcoins qualify under their supervision law. This is rather a technical exercise and it can be seen that only for income tax issue (what to do with bitcoin holdings that change in value), they haven't yet got an answer.

So yes, the bitcoin has a legal status, but then again: any new development, instrument or technology already is subject to the law book. The fact that the Ministry has now pinpointed the article of the law book where they think the object fits, may therefore not be so spectacular.

If we look at the Netherlands, a similar situation appears. Anyone is free to determine whether to exchange services by paying for them or by using other forms of payment. . I could buy a bread in exchange for washing a car. And if the bakery would accept bitcoin rather than washing their car, it would work as well. The use of bitcoin can be considered payment in kind. Given this regulatory payment mode, our legal system is already recognising alternative forms of payments.

The same holds for the taxation part. The VAT rules on services do not change if the payment leg of my transaction is different. And the income tax rules don not change either. The Dutch rules state that if you hold something which has value, it must be registered on the tax declaration. In this declaration, the bitcoins in a wallet thus show up as the money in my bank account does.

As for the legal tender part of the discussion: I view that as an overrated concept. While in earlier times, the concept of legal tender meant that the other entity in a transaction had to accept the notes and coins, this obligation has been struck out of our Dutch law book many years ago. But it still lingers in the mind of many people and may of course in some other countries still be more relevant.

Future developments
What I find most interesting about the news is the quick and fast coverage that new forms of payments and regulation get in the media and with the public. We can see that the developments are positioned as the story of the recognition of bitcoin by the regulator or as the coming of age for bitcoin. Regardless of the angle of these reports, it is clear that things are happening and moving in the area of private, digital, distributed currencies. And it will be interesting to see this area develop further.

The proposed EU-directive on Bank Accounts: wrong tool

Today, the European Commission will announce a proposal for a Directive on Bank Accounts that covers the following areas:

- comparability of bank account fees: the aim is to make it easier for consumers to compare the fees charged for bank accounts by banks and other payment service providers in the EU;

- bank account switching: the purpose is to establish a simple and quick procedure for consumers who wish to change from their current bank account to a different one, with the same or a different bank or other financial institution;

- universal access to bank accounts: the aim is to allow all EU consumers, irrespective of their country of residence or financial situation, to open a payment account, which allows them to perform essential operations.

 

With the proposal the Commission continues its standard policy towards the financial sector: ride the road of regulation as long as the sector is still unpopular with the public. It has done so with regulation 2560 (on fees) which had to motivate banks to speed up intercountry payment processing in Europe and it has in a similar vein used the regulatory process for the Payment Services Directive. Repeatedly we see the banking sector respond with initiatives to improve operations and just as repeatedly we see the European Commission and Parliament find that this was not sufficient and move forward with regulation.

 

At face value, the goals of the Commission with this Directive seem laudable. But what would interest me most is the degree with which the Commission has done its regulatory homework. Quite some time ago, there were EU-initiaves and rules on 'better regulation', which meant that a solid cost-benefit analysis would be required by the Commission before proceeding with further regulation. In the process of discussing switching cost, the Commission did not follow these rules however (see blog).

I remember that at the time I was amazed by the ease with which the Commission bypassed the work done by an EU expert group on user mobility in bank accounts (of which I was a member). The consequence was that, without having proper data as to the degree of problems experienced, the nature of the problems in different countries, the discussion remained a yes/no discussion. So I was quite interested to see if in the mean time there is more hard evidence on the table to determine the nature of the problem that needs to be solved (and to see if it is a European or a national problem).

A quick look at the impact assessment tells me that not much has changed. It is essentially a fast forward reasoning towards the norm that unless everyone in Europe switches bank accounts quite a lot, the market is evidently failing and thus regulation is necessary. Furthermore there is a blind eye as to the different types of service providers: the document assumes all players to be banks with a full service package. In terms of analysis, it is skewed as it misses one alternative explanation for low bank switching rates. That explanation could be that, from a consumer budget point of view, it is more economical and rational to use the scarce time to chip off a small percentage of other purchases (mortgage or lending percentages, tablet-purchases or mobile phone subscriptions) than to spend a lot of time comparing and switching banks and earning very little revenue in the process (see also the presentation here that discusses which assumptions lead to which regulatory preference).

Seeing the current state of discussions (a directive proposal) it seems hard to imagine that the plan would be withdrawn or modified seriously. Still, it would be useful if the Commission had done their homework a bit better and at least had chosen a proper regulatory tool. If indeed the provision of bank accounts accross the EU is a concern, why not choose Universal Services Obligation as the regulatory mechanisms, that is most suited?

We used this mechanism before in Europe, to designate the amount of public telephone's that had to be available to the public. And setting it up for banking isn't hard to do (read this Tilburg University Report) but it does require one thing: a better cost/benefit analysis:
Furthermore, designating all banks to take care of the product dimension of a Universal Services Obligation (e.g., consisting of only a basic bank account service) may be the most effective way of implementing it, provided that the USO has a minimal scope. However, with regard to the geographical dimension of a USO, designating all banks leads to unnecessary cost duplication, so that it is worthwhile to consider other options, such as self-regulation and a franchising mechanism in combination with an auction. In addition, technological developments in a sector are very relevant when assessing the need or desirability of universal service obligations. By interfering in these processes without having made it clear in advance that there is a problem, such developments may be distorted; hence the importance of carrying out a cost-benefit analysis as a starting point.

I think the citizens of Europe are best off with goverments that only regulate when the facts are evident and the tools of regulation are properly geared to the problem at hand. At this point in time, with this Bank Account Directive, I believe we are heading for another emotion-based, cost-increasing all-in Eu-wide regulation, which underlying problems (if any) could have been solved much cheaper and easier by using other more appropriate regulatory tools.


PS. The post is updated at 1823 to include some of the impact assessment data.
 

The ECB-report on virtual currency schemes: some reflections

The last month, the ECB published a report on virtual currency schemes. I have been reading this with great interest as it signals the involvement of the central banks in a new area: virtual currrencies. The relevance of this report must therefore not be misunderstood. We should remember that in 1994, the EMI-report on pre-paid cards signalled the start of the regulation of prepaid-cards and electronic money products. And in a similar style, this report may become the starting point for regulation of virtual currencies.

In general, central banks are to be commended for monitoring the developments in the area of money, retail payments and near-money products. If you're a central bank, an institution that is responsible for true money, than it it always good to know what other forms of money are in circulation. And as such the report of the ECB demonstrates that the European central banks are alert.

Analytical basis could improve
I must say however that I was also somewhat disappointed. The analytical framework presented in the report is a bit shaky in my view.  It does not rest on the nature of the subject discussed (virtual tokens and currencies), but on how they are 'regulated'. As an approach, I find this little convincing. Furthermore I noted that 'unregulated' is not defined. Does it mean that central banks or supervisors are not involved or that no regulation applies at all?

As an alternative I would point out the possibility of using frameworks suchs as this one (taken from the American Law Review):

It is interesting to note that the empty box in this table can now be filled with: Bitcoin as an example of a system where money can circulate freely without returning to a central mint.

Which electronic tokens are currency of money and which are not?
The ECB distinghuishes between three virtual currency types, in terms of openness of the systems involved.

Type 1 is a closed link system in which the digital tokens are only usable in the system itself. The example the ECB provides is the World of Warcraft Gold. And although the picture suggests that there is no link to the real economy, the ECB notes: However, there seems to be a black market for buying and selling WoW Gold outside the virtual currency scheme. If Blizzard Entertainment discovers any illegal exchange, it can suspend or ban a player’s account. 

Type 2 contains systems where users pre-pay services of a supplier in the form of private issuer tokens such as facebook credits. And type 3 systems are open systems of privately issued tokens/currency that can be bought and sold. It is in this category that bitcoin and Linden dollars are placed.

What is lacking in this model, is the Type of model 1b where there is no formal buying or selling of tokens, but there is a relation to the physical world. It is the world of loyalty points and tokens, which can be earned and redeemed, but never exchanged for money itself. The ECB places these under the category II.

It appears to me that in doing so, the ECB doesn't distinguish sufficiently between loyalty tokens and payment tokens,which each have a different role to play in the business model of their issuer. An alternative table might have been:

	User cannot buy tokens at all (loyalty-type)	User earns tokens and can buy additional (hybrid of loyalty/payment)	User buys and sells  tokens (payment-type)
Tokens used in digital issuer-domain only		World of Warcraft	World of Warcraft Lynden Dollar
Tokens used in digital or physical issuer-domain only	Starbucks	Nintendo Points -Digital Payment loyalty schemes for single retailers
Tokens used at other entities than the issuer	Frequent Flyer Programmes	Frequent Flyer Programmes	Bitcoin, e-money on mobile phone's

The missing element: mobile money
What intrigues me is that the digital money on mobile phones is not a part of the discussion. It is by its definition (an exemption in the e-money directive) an unregulated form of digital money. Yet, the ECB has been so long accustomed to the strange sequence of events that made the European Commission decide that money on antenna's of MNO"s is not electronic money, that they forgot to include it in the analysis.

The reputation argument.....
Finally I noticed that the ECB finds, that if these virtual currency schemes (however defined) grow too much, they might give rise to a reputation issue for the central banks. Here again I think the analysis is a bit too strongly worded. Central banks can simply outline their scope of work and responsibility by stating that they  are not in any way responsible for money that they didn't issue and supervise. By clearly and repeatedly informing the public of this fact, the public can then choose to take a risk with the virtual currencies or stay out of them.

Yet, I wouldn't be surprised if this reputation argument (or a comparable public policy objective: transparancy) becomes the main angle from which future supervision of these schemes will be justified.

Use twitter to create banknotes: the punkmoney concept

This year in May, I was visiting the 15th Digital Money Forum (well organised as ever, by Dave Birch and his team at Hyperion), and ran across a very elegant alternative payment concept, that makes use of Twitter as a technology. The concept was called: Punkmoney and its developer Eli Gothill explained on the forum the workings and background of the concept (see the presentation here and read an interview with Eli on the background here). With the concept, he took a step back in time, skipping to the times before money was used widely.

In these early times, we can imagine societies to be local communities in which the economy consisted of exchange of services and committments. The scale of the village/community was limited and thus a trusted network of users would exchange services, goods or favours, knowing that either directly or over time, the service or favour (helping in building a house) would be returned. Later on in history the concept of money took over, so that the chain of exchange would become longer. A favour or service would then be paid for with money, that could be used to buy a service or good elsewhere.

Now, what Punkmoney does, is to use Twitter to re-create the old 'favour/gift-economy' in which no money existed. In order to print your own banknotes on Twitter, all you need to do is use your existing account and the hashtag #punkmoney. In English you might call these: Twitnotes or in Dutch: Twitbiljet. So let's see what a Twitnote looks like in real life:

As you can see, this is a promise from me to Occupy Amsterdam (@potbanging_NL) to deliver a brief talk on the financial history of Beursplein. As I used Twitter, it is a public statement that everyone can read. As such it is also read by the Punkmoney tracker, which makes a record of the statement. This central database registers all promises made on Twitter with the hashtag #punkmoney and thus serves as a register in which you can see which promises were made.

Now back to the Twitnote. My Tweet says NT at the end, which means that it is non-transferable. Another option might have been to state: TSA, meaning: Transfer Subject to Approval. In addition, my promise is quite exact in that it specifies specific moment in time when I will deliver a brief presentation (13 October on  a global noise manifestation). Alternatively I could have left out this specific time and have noted: expires in 2 years/months/days.

Of course there's a lot more technical details to be told on how to transfer and redeem notes. But the important thing to note here is that anyone who is seeking alternatives for money in its current form, can easily use the punkmoney concept in his/her community to start exchanging goods/services by using Twitter.

As I understand from Eli, he is going to be presenting his Punkmoney system/concept to the banking community on the next SIBOS (a very important banking conference for all companies, banks, central banks etc. in the world). And I truly hope that the delegates there will recognize the elegance and beauty of his design.

Google Wallet roll out.... without Google Bucks

It's about five years ago that I discovered, by accident and curiosity, that Google Payments Limited had applied for an e-money license at the FSA. Ever since, people have been wondering how Google would enter the payment space. Would they offer a wallet with virtual cards or would they issue their own new virtual worldwide currency (googles, googlets or gees)?

In good tradition, Google started out doing field tests with the wallet (which would sit in the mobile phone) and announced this in May 2011. The wallet was to contain your credit-card cards as well as a google-pre-paid card. And payment was possible with Paypass while the wallet would also facilitate the savings of loyalty-points. The card information was stored in the Secure-SIM-element in the phone and they experimented quite a bit since then.

So where do we stand now?

Well, the Google Wallet is now being rolled out and the Google development team sent out this video to further explain the wallet concept and roll-out. The most important change is that they decided to move the card-information to the cloud. This allows the Wallet to be used both via Phone and via the Web, with all your card details and important digital documents (ID's, transit pass etc) residing in a safe digital environment. So their distribution model for the application is now changing to making APIs available so that merchants and issuers can easily integrate the Wallet in their site/services.

As such, we can thus see Google moving into an integrators role, rather than a payment instrument issuer role. In fact, at some point in time, the company thought about issuing Google Bucks, according to Eric Schmidt, but abandoned the plan. The concept would consist of a “peer-to-peer” money system by which users seamlessly transfer cash to each other via a hypothetical application. However, various laws about currency and money laundering in different parts of the world made this too complicated to realize.

For now, the peer to peer payments in the Google Wallet are no longer on the agenda. And from a historical perspective (see my other blog) I think it is a good choice. Yet.... one of the developers did mention on this subject: it's impossible for now, but stay tuned for some announcements in the future.

So, are we still in for a surprise here?

Bit instant to introduce 'bitcoin'-card...

As you may know I am somewhat sceptic about the underpinnings of Bitcoin (see my previous posts), but the system does keep innovation going. Bit-instant for example is a company that helps consumers convert money into bitcoin and vice-versa. And such services are surely helpful in bringing more reach to the system.

Bit-instant is apparently now planning to bring a debit-card on the market, in two months time, that marries the bitcoin and money world even more. In this article here you can find a link to an IRC chat with Bit-instant, in which it announces its plans. It also provides a link to the picture of the card, showing a QR code that can be used to quickly deposit bitcoins residing in other applications to the card-account.

Now as I understand it, it is a regular worldwide ATM/Payment card. And it looks like it allows bitcoin to be deposited on the card balance. But essentially the bitcoin holder can ask Bit-instant for a conversion of some bitcoins to money and this money will then be deposited on the card balance for payment. By also printing the bitcoin identification on the card the concept very much looks like bitcoin is entering the card-market. And certainly to the user it will feel/look that he can pay with his own minted bitcoins.

In reality this is a very smart introduction of just another card in the market. It's a variation of the regular co-branded card where now we don't see a soccer club, automobile club, but the bitcoin club appearing. Still, it's another innovation worth exploring, so let's see where this card will take us.

The art of Reserve Banking (at the Zuidas Amsterdam)

Reserve Banking is an art. While Draghi and Bernanke are highly qualified and professional economists, they must also master the art of performance. As true actors, they use their voice, their remarks, eyebrows and somewhat vague statements to provide hints and indications that the market then swiftly responds to. It is something you can't learn from the books. It's an art that can only be mastered in practice.

Since this year, the Zuid-As in Amsterdam is also home to the art of reserve banking. But it's a bit different. I heard about it yesterday, when visiting the Holland Financial Centre. From high up in the nearby Symphony building I looked down onto a small rectangular area of the Art Reserve Bank, well fenced, with cameras and three small office buildings. One is the minting press, the other is the teller and the third one was hard to identify. It looked like this:

The Art Reserve Bank: an experiment
What happens there is a unique experiment. A group of artists have set up, without any monetary funding, a so-called Art Reserve Bank. The plan was there for some time, but as the financial crisis came along, it became easier to convince sponsors to join a project that questions the value basis of money. The main idea is that there is far too much money circulating in the world and that the crisis demonstrates that we need a new approach towards money and debt. And in the experiment, art (or: the intrinsic value of human artistic expression) becomes the money. And thus helps to freshen up or minds and stimulate us to re-think our concept of money.

The idea is that for a period of five years, each month 400 coins are minted. These are 4 series of 100 coins per week, costing 100 euro each. For each month: a different artist is asked to design the coins, which all bear the same backside with the motto: ARS PECUNIA MAGISTRA: Art is the teacher of money. A nice motto and also a tongue-in-cheek reference to the Amsterdam Zoo that bears the motto: Natura Artis Magistra (Nature is the teacher of Art).




Anyone can buy coins and thus becomes a member of the Cooperative Art Reserve Bank (Kunstreservebank). All holders of the coin are thus the collective owner of the bank. Of the 100 euro costs, 90 % is used to pay for the operational cost of the experiment and 10 % is withheld as a 'cash reserve'. Should a buyer not appreciate his/her work of art, he can return it to the bank and get the original value back with a 10% interest fee. There is also a dealing room on the site of the bank, for those who wish to buy or sell their coinst. And at the end of the five years, all owners of coins can collectively decide what will happen with accumulated capital (if there is any and if the bank stil exists).

Money, dreams and art
The experiment challenges one to consider: what is happening in our world of money and value?

For me, the Art Reserve Bank made me realize that there may now be so much difference between their coins and the official legal tender in circulation. Both coins are the product of our imagination, dreams and creativity. Which is quite clear for the Art Reserve Bank currency, but may be less clear for the euro. So let me try to explain.

What happened over decades is that we moved from a mentality of: save first, spend later, to a mechanism of: spend first, repay later. If your story about the future would be probable enough (having a job, education etc) some bank would lend you money. And the same thing was true for businesses. Essentially this is a mechanism where tough choices are made. If you don't have the job or a solid story explaining how you can repay in the future, you don't get money. Which all sounds very realistic.

Fact is however, that with hindsight we can now see that banks, consumers and companies have on a large scale lived in dream worlds with expectations of future income, growth that were not realistic after all. Money was created, lent on the basis of these dreams and imagination. And part of that money is now in our pocket. And we also know that some of the debts are definetely not going to be repaid in the future.

So wouldn't it be fair to state that some of our euros are just as much the result of our imagination, as the Art Reserve Bank coins?

Outsider ideas in the payment space.... seldom really new..

One week ago Rabobank Nederland announced that it might de-activate the possibility to use their debit-card outside Europe, in an effort to eliminate fraud. And today the Financieele Dagblad has an article in which it becomes clear that an entrepreneur claims that this is actually his idea and not Rabo.

He's written the idea of functional/geographic application controls (including de-activation for certain geography) down as his idea, sent it to the Rabobank. And some time later he even spoke with Rabobank. And now that he discovers that Rabobank will in practice block geographic use, he claims that Rabobank has stolen his idea. It appears that he's in full swing with preparation of a court case.

I think this court case may not be effective. Application and functional controls in the payment area are around since ages. There can be checks and limits on payments via certain channel, with certain amounts, to or from a geographic area, number of times of use, branche-codes and what have you. And we have seen these developing over the years. In a planned talk on this issue in 2004 I already mentioned the user control of these application controls.

In this particular case (blocking a geographic area for card use), it was clear ten years ago that there would come a time that EMV-debit-cards would be blocked for use in countries that hadn't fully migrated to EMV. And that the amount of fraud would essentially determine the timing.

Now I do understand the serendipity-element in this story. It must be frustrating for an outsider to think that he has found the golden idea in payments and observe one bank (that he spoke to) introducing 'his' idea. However, this was certainly not a unique idea, but an inevitable, already foreseen consequence of technology migration and fraud.

Debit card usage influenced by the news...

Today, the Dutch central bank published a report that debit-card usage is affected by news articles on fraud. On average, the number of daily debit card payments drops by a little over 2% on days that newspapers report on POS terminal fraud and by some 3% when skimming at ATMs is in the news. The news has the largest impact when it makes the headlines. Furthermore the news-effect increased after 2007, when fraud incidents more often happened and made it to the headlines.

DNB remarks that other factors also influence the payment intensity. Rainy days create a drop in shopping and thus in transaction traffic. And they also noted that the payment pattern returns to normal after one day, so the news-effect on payments doesn't last long.

Digital Money Forum 2012... 15th anniversary and lively as ever

The Digital Money Forum is an event that this year reached it's 15th anniversary. And a special event it is. My previous visit to the Forum was probably some ten years ago, when everyone was pretty much into the e-money way of life. But technology, money and society continue to develop and that's where Dave Birch and his team of Consult Hyperion come in. In setting up the forum they provide for a lively and thought-provoking event where money is dealth with from all different angles. And as before, it was a pleasure to participate.

So this years event was special in many ways. We all got a better look at the evolving phone payment landscape, delved into possible future scenario's for the world and money, we spoke about the future and death of cash, about social inclusion and lots, lots more. And, quite fascinating, I got to issue my own currency, PunkMoney, via Twitter, by promising the developer, Eli Gothill, two beers and a financial history tour in Amsterdam.

A bit more on the principles of Punkmoney (as I understand them). If we look at money it is an invention to facilitate transactions in society. But before the official money we had mutual obligations and trust relations in society. I would help my neighbours out with building their house, assuming they would do the same for me, in time. And so on. So there was this web of mutual obligations and promises that cemented the relations in society.

Now what Punkmoney does is to leave all the monetary issues and digital money aside and elegantly replicate this web of promises. With some rules as how to form proper messages, Twitter as the carrier and a software enige that scans twitter for any promises of Punkmoney. And when it finds one, it registers it and there you have it. Not the real money, but something even better: real promises. Just as trustworthy as... yourself.

After Punkmoney, we moved on to another kind of money. Monopoly money, sitting on a Samsung phone (with an application neatly developed by Easan).

Six teams on six tables started playing and as for me personally, I was literally quite lucky. I landed on 3 airports in the beginning of the game, won some lotteries and eventually turned into a big shot property owner. I turned out to be the winner of the competition, with an awesome price: this incredibly beautiful banknote (an official German forgery of a UK 20 pound note; part of the Bernhard operation):

Some more on that will follow on my financial history blog later.

Fed-study about mobile payments.... mobile phone heralds the return of the cashiers...

The federal reserve has yesterday issued this study on Consumers and Mobile Financial Services. And it shows that mobiles are a game-changer, due to their ubiquity. The people that have bank account don't use the mobile that much, but those without a bank account (the unbanked) make quite some use of it. So it turns out that in the US you can see a double usage pattern: on the one hand the signs of a developed market, moving slowly. And on the other hand the pattern that we know from countries in Africa, with heavier usage of mobile phones as the main banking/payment infrastructure.

Of course there's much to read in the study but it's interesting to note the banking paradigm that the Fed uses in the study. It sees the mobile phones for unbanked as a possible first step towards a sort of  'true banking', for those customers. That could be a possibility of course. But I think we may wan't to revisit this approach: couldn't we also see the mobile phones as the new digital shape of the former cashiers? And couldn't the cashiers just be the cashiers of any shop as well?

Well, that's my penny's worth of thought this morning and I'll be happy to elaborate a bit more on it at the 15th (!) Digital Money Forum in two weeks time.

New card design by Rabobank marks migration to international POS-scheme

As many of you may know, the Netherlands are now in a final stage of migrating from the Dutch POS-system PIN to the international card scheme Maestro. And as a part of this migration, Rabobank has changed the looks of the card. Given the fact that chip-terminals require a dip of the card, Rabo has moved its cardholder from a landscape to portrait design. In addition it has put the IBAN number on the card, so that customers always have their SEPA-oriented account number nearby.

ING Banking a bit wobbly lately

This sunday I wanted to order a cd and sheet music by Jules de Corte. Whereas usually this is just a matter of seconds, using iDeal, I now had to circumvent it to do electronic credit transfers via e-banking. It was clear that the ING database had some glitches, but after a couple of tries I succeeded in transferring the money.

While I could just repeat the exercise, others couldn't. The glitch turned into a major failure of ING-e-banking in the last couple of days. Today however, everything seems to be up and running again. And ING will once more regret using Oracle as the back-end database of an online payment system.

Fotograph your bill and pay it... new stuff from Denmark

With all the new apps, technology and stuff, you can just build any payment produkt you like. It appears there is a Danish bank that has developed an app that lets you photograph your bill, send it to the bank and they will transfer the money to the proper account. And for those that master the Danish language: see the instructions of the Danske bank here.

I am not entirely sure if this application will really be a killer-app that fullfills its consumers' needs. But it's interesting to see that nowadays the development burden for banks is lower than in the mainframe-days, allowing for test-trials in the field rather than extensive market research.

The euro-note now ten years in circulation...

This new year brings us a bit of a memory: ten years ago we started using the euro bank notes. For many people in the Netherlands, this was a step back in terms of quality and design. And we also notices how prices were quickly moving up. At first all economists and the central bank heavily denied this, but later research (in 2005) showed that in the first year of the euro, inflation was 3,6%, of which 0,5% due to the introduction of the euro.

In their efforts to deny the experience of the public, economists coined the term: 'experienced-inflation' ('gevoelsinflatie') to outline a situation in which the perception of price rises differed from reality. This helped the economists at the ECB discover that price rises in regularly purchased items could lead to a consumer perception of inflation that was higher than their scientifically produced price-index basket. Again a demonstration of the fact that economic models need to incoporate bounded rationality rather than assume a rational consumer.

As for the future of the euro: many experts now predict its demise in 2012 and paint a gloomy picture. When listening to those 'experts' I have the impression that it's increasingly fashionable to doubt the future of the euro. And although the politicians last year didn't do their best to help out, I do think that the future may be less bleak. With the ECB lowering cash reserve ratio, widening it's collateral policy and throwing in almost unlimited amounts of liquidity the bazooka is already out there, but some fail to recognize it as such.

So I think those ugly euro-notes will remain in circulation for quite some time to come.

Looking back on 10 years of blogging.....

These days it's about ten years ago that I started blogging: I set up the blog Retail Betaalgedachten to voice my views on the retail payments issues in the Netherlands. At that point in time a friend of mine had a personal blog, but I started to use blogs for my consultancy work, thus being one of the very early business bloggers in the Netherlands. So here's the bottle to celebrate...:

Blogging has been with me ever since those first days. The Retail-betaalgedachten became: Linkdump on Retailpayments that you are now reading. And of course, when setting up 11a2.nl, a representative organisation for e-money issuers in the Netherlands, I chose the blog as the main landing/reading platform of the website. And in addition I set up a personal blog on jazz in the Netherlands.

And now, last year marks the beginning of yet another blog, this time on the financial history of amsterdam/netherlands. It's a spin off of my passion to always take a historical approach towards analyzing todays issues in society and industry. So as of this year, every now and then you can read my views on euro-crisis, financial sector and payments on that blog.

And on that note I wish all the readers a very good new year !!

Six Pack becomes fivepack: T-mobile leaves NFC-consortium of Dutch banks and telcos

Tweakers net today reports that T-mobile is leaving the consortium of banks and telco's in the Netherlands. The sixpack consortium is also delayed in its plans (from mid 2012 to beginning of 2013) given the considerable market share that both the banks and telco's have. So they will go to Brussels to aks for exemption of competition rules.

Costs of fraud by phishing at banks doubles in 2011

The Dutch Bankers Association today starts a campaign to increase awareness of consumers that they shouldn't fall for the numerous phishing mails that flood their inbox. The reason is the fraudnumbers in banking. After the first half year of 2011, the fraud by onlinebanking had already succeeded that fraud over 2010 (9 million euro). And similarly, the number of phishing incidents in this first half year amounted to 2418 while over the whole year 2010 this number was 1383.

The NVB has also renewed the website VeiligBankieren.NL; a website that I personally helped come into existence in 2005, as it was clear that awareness on the risks of e-banking required timely communication. This still is the case and thus the campaign/trailer below was developed. It will air extensively the coming days. The commercial shows the physical equivalent of phishing and warns consumers not to open fake-mail from their bank.