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ESSAYS ON ISSUES

THE FEDERAL RESERVE BANK
OF CHICAGO

SEPTEMBER 2011
NUMBER 290a

Chicag­o Fed Letter
Exploring the new face of retail payments
by Katy Jacob, business economist, and Anna Lunn, associate economist

At the Chicago Fed’s 2011 Payments Conference, held on May 19–20, participants discussed
how changes in consumers’ behavior in the wake of the financial crisis and recession can
translate into opportunities and challenges for both traditional and nascent payment
providers. They also focused on the impact of payment innovations and new consumer
protection regulations.

At this year’s conference, retailers,

Some materials presented at
the conference are available
at www.chicagofed.org/
webpages/events/2011/
payments_conference.cfm.

consumer advocates, bankers, academics,
and technology experts discussed how
consumers have changed their payments
behavior while facing a weak economy
with high unemployment. Consumers’
new payments behavior may lead to
opportunities for traditional payment
providers—like large financial institutions and card networks—as well as new
nonbank ones—like technology firms
and retailers. Partnerships between
traditional and new payment providers
are leading to innovations that may be
better suited for some in the current
economic climate. For instance, technology firms (some focusing on mobile
technology) and social media projects are
offering new ways for payment providers
to reach consumers with and without
traditional bank accounts. The financial
crisis and recession have prompted not
only consumers to change their behavior
but also lawmakers to enact new payments
regulations to protect them. Historically,
the U.S. has had a market-driven approach
to payment services, but recent economic
forces and a greater call for consumer
protection have made regulation a more
salient factor for the payments industry.
Consumer preferences

In his keynote speech, Richard Oliver,
Federal Reserve Bank of Atlanta, stated
that during the late twentieth century,

the payments industry was in an environment where banks faced little competition for consumers; the pace of
innovation was slow; the government
did not intervene much; and consumers
did not require a lot from their payment
providers. However, over the past decade,
that environment dramatically shifted:
Nonbank players began to aggressively
compete with banks to provide payment
services; the pace of innovation accelerated as new technologies emerged;
government regulations became stricter;
and consumers demanded more from
their payment providers. Oliver explained
that all of these changes were reinforced
by the recent recession. Consumers got
used to relying on payment services that
cost them little to nothing. Conference
participants noted that as fees for payment services rose recently, consumers
felt slighted. Banks and other payment
providers raised their consumer fees to
reflect the costs of making improvements
to their payment technologies and security measures. They made these improvements to keep up with market innovations
and comply with new government regulations and industry guidelines.
Katy Jacob, Federal Reserve Bank of
Chicago, noted that the rising costs of
providing payment services are indeed a
significant industry challenge. While many
consumers have weathered economic

setbacks that have made them more
aware of the terms of their relationships
with their payment providers, many of
their payment preferences have remained
the same. Consumers still want the same
speed, convenience, ubiquity of acceptance, and rewards from their payment
choices as before—all at the same low
cost. But for the payments system to run
smoothly and efficiently, consumers
must have confidence in that system
and in the myriad of parties that run it.
Thus, foregoing upgrades in technology

Even though the CTA offers slightly
cheaper fares for using electronic payments, many of its customers continue
to use cash. Laura Chambers, PayPal,
said that many people care a great deal
about what funding device they use,
and it can be counterproductive for a
company to attempt to change these
personal preferences.
In contrast to Chambers, John Drechny,
Walmart, argued that most consumers
are very adaptable when it comes to payment options. For example, if a merchant

Consumers are increasingly using alternatives to potentially
more expensive forms of payment like credit cards to help them
gain and maintain control over their spending and financing.
and security is not an option, said Jacob,
despite consumer pressures to keep
payment fees low. Sujit Chakravorti,
The Clearing House, reiterated that
customers developed high expectations
from their payment options in the past
and they continue to expect rewards
from using payment instruments like
credit cards. While payment providers
continue to search for ways to offer
added value, the general consensus of
the conference was that rewards are more
costly for payment providers today than
in the past, so companies have to develop
other strategies to increase or maintain
their customer bases. Bob Hunt, Federal
Reserve Bank of Philadelphia, offered
one general principle to keep in mind
as these strategies are developed: Payment transactions usually reflect preexisting relationships that individuals
have with other individuals or firms, so
payment providers should incorporate
those relationships into the payments
stream to better serve their consumers.
Ruth Judson, Board of Governors of
the Federal Reserve System, stated that
consumers’ payment choices are largely
determined by their household budgets
and the cost and convenience of the
payment options. Eric Reese, Chicago
Transit Authority (CTA), gave a specific
example: A large segment of the CTA’s
ridership is lower-income and lacks bank
accounts, so such CTA passengers rely on
cash as their primary form of payment.

does not accept a payment type, consumers will use another form of payment,
even if it is not their first choice. That
said, it becomes much more difficult to
reach and keep consumers if payment
options are offered by merchants or
providers and then taken away. Neil Platt,
CashEdge, contended that the biggest
struggle is to convince consumers to try
a new payment type; he observed that
once they sign up for a new service, they
quickly become comfortable using it.
Concurring with Platt, Paul Tomasofsky,
Secure Remote Payment Council, said
that investors must be patient with
companies developing and executing
new business models as they take time
to change consumers’ preferences. Lisa
Greco, AppleTree Credit Union, argued
that most consumers will switch to a
new form of payment if given enough
incentive to do so. Her financial institution introduced a large discount on
interest rates for consumers who committed to using automatic electronic
payments for loans while it also started
charging significant fees for loan check
payments. These clear incentives for
consumers to adopt electronic payments
had a ripple effect on the efficiency of
the entire credit union, enabling it to
survive the recession.
Although basic consumer preferences
may have remained largely unchanged,
as Jacob and Chakravorti explained,
speakers spotted new trends in consumer

behavior. Tim Murphy, MasterCard
Worldwide, said that since the recession,
consumers have been doing more research before making their purchases
and they have been searching for discounts. In addition, consumers have
begun to demand more information
about how certain forms of payment work,
and they have become interested in increasing their level of financial literacy.
Andy Rowe, Bank of America, stated that
in the past, many customers tended to
not keep track of what they could afford;
instead, they relied on banks to impose
limitations. As the economy worsened,
consumers perceived that banks had
failed them in that regard. Some consumers started to view merchants or nonbank companies as the more trusted
parties in a payment transaction. Emery
Kobor, U.S. Department of the Treasury,
claimed that the new trend of nonbanks
driving payment transactions represents a dramatic shift in the market.
While banks used to lead payment innovation, they often now serve as third
parties to nonbank firms that control
the payment services.
Conference participants noted that
consumers are increasingly using alternatives to potentially more expensive
forms of payment like credit cards to help
them gain and maintain control over
their spending and financing. Merchants
at the conference noted that, while consumers are still more likely to use credit
cards for large-ticket items, they usually
use cash, checks, and PIN-based (personalidentification-number-based) debit
cards for smaller transactions. For example, Susan Ehrlich, Sears Holdings
Corporation, reported that her firm’s
Kmart chain has seen a sharp increase in
PIN-based debit transactions. Greater
incidence of cash, check, and PIN-based
debit transactions implies that consumers
are less willing to incur and carry very
expensive credit card debt. This wariness
of credit card debt may also help explain
the increased use of prepaid cards since
the recession, which both Drechny and
Ehrlich reported. Ehrlich also discussed
how Kmart has seen great success in its
layaway programs, which have recently
experienced double-digit growth. As the
discussion focused on the rise of cash

transactions since the recession, conference participants offered many different
opinions on the overall costs of the cash
economy. Large merchants, such as
Walmart and Sears, view cash as a relatively efficient payment option, since
they are able to recycle cash and achieve
efficiencies of scale; however, others find
that the cost and security issues associated
with handling cash are quite problematic.

with them, to improve transfer functionality. Joe Hurley, Discover Financial
Services, described another example
where payment card and automated
clearinghouse (ACH) networks are
collaborating, rather than competing, on
products such as decoupled debit cards,2
which can give rewards to consumers
who are hesitant to use credit cards.

Reaching new markets

The payments market has moved beyond
the provision of simple credit and debit
cards, however. Payment providers have
been especially interested in finding
new ways to reach underserved groups.  
Allen Fishbein, Board of Governors of
the Federal Reserve System, reported
that demographic groups with fewer
banking relationships are more likely
to own mobile devices than those with
more banking relationships, so mobile
services may allow the unbanked (or
underbanked) to gain (more) access
to financial services. However, Murphy
cautioned that mobile payments are
not necessarily about financial inclusion
in the U.S., since most innovations in
this area have been for smartphones,
which are primarily owned by more
affluent consumers.

The cash economy is important because
it reveals an undercurrent in the payments
market—the presence of consumers
who do not have formal relationships
with financial institutions. Yazmin Osaki,
Federal Deposit Insurance Corporation
(FDIC), said that a 2009 FDIC survey1
showed that 7.7% of households in the
U.S. are unbanked and 17.9% are underbanked. While the number of unbanked
households in the U.S. might seem low,
more people in the world are unbanked
than banked, Kobor pointed out. Osaki
explained that cost is often the deciding
factor for many consumers in whether
or not they start or keep a relationship
with a financial institution. Individuals
who have never had a bank account say
that they have never opened one because they do not have enough money,
and the unbanked who have had a bank
account say that accounts generate too
many fees, Osaki reported.
While cash has become more popular
recently, technology may increase consumers’ access to alternatives to credit
cards. For instance, Lewis Goodwin,
Green Dot Corporation, said that prepaid cards can provide an alternative
way for consumers, especially the unbanked, to store value and make payments in a poor economy. In addition,
Hunt commented that successful payment providers are taking established
payment platforms, such as payment card
networks, and creating logical extensions
of those platforms to deliver more services. Former competitors are entering
into joint efforts to provide better, more
integrated payment services. For example, Platt explained how CashEdge, which
allows consumers to make electronic
transfers between bank accounts, is
partnering with banks, not competing

Moving to mobile

Nonetheless, Dave Wentker, Visa, argued
that the prevalence of mobile phones and
smartphones has created an immense
opportunity for payment providers, as
long as those providers choose the right
time to invest in infrastructure developments—i.e., when it is plausible to
achieve a critical mass. Paul Rasori,
VeriFone, explained that some of the
infrastructure needed to make mobile
payments even more popular is already
in place; e.g., his firm provides retailers
with sophisticated point-of-sale technology that enables secure electronic
payment transactions for many forms
of payment, including mobile devices.
Chambers said that much of Internet
commerce is actually conducted via
mobile devices, as opposed to computers,
so sales completed on mobile devices may
actually be underreported. Chambers
also remarked that mobile payments
change the nature of competition, since
payment providers are competing not
only with each other for consumers’

time, but also with nonfinancial software
companies that make entertainment
applications, such as games. Extending
the discussion on mobile payments, Erin
McCune, Glenbrook Partners, highlighted the growth in digital currencies,
which are used primarily to purchase
digital goods in virtual worlds (accessed
through computers and mobile devices)
but can also be used to purchase realworld goods.
Regulation and legislation

Changes in the payments market have
spurred new regulations and legislation,
such as the Dodd–Frank Wall Street
Reform and Consumer Protection Act
(Dodd–Frank Act). Kobor remarked
that in the past, the ongoing account
relationships between banks and their
customers distinguished banks from
the vast majority of nonbanks; but such
relationships are no longer the exclusive
domain of banks. Thus, regulators must
now consider how to provide consumer
protections when payments are offered
by previously unregulated entities.
Several speakers discussed how regulation
is often, by nature, reactive. The extremely
fast pace of change in retail payments
makes it difficult for policymakers to
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ISSN 0895-0164

stay on top of issues related to pricing,
competition, and term and fee disclosures. Indeed, Chakravorti stated that
if governments regulate too early as
new payment methods are being rolled
out and popularized, innovation may
be stifled.
In his keynote speech, Michael Barr,
University of Michigan Law School, contended that in the past, regulators did
not adequately protect households and
investors. Barr argued that the new regulations are intended to correct the deficiencies in the previous, unrestrained
financial market. He noted that in order
to provide consistent beneficial regulation, regulators need to consider the
incentives of financial service providers,
as well as the welfare of consumers.
Melissa Koide, Center for Financial
Services Innovation, said the Consumer
Financial Protection Bureau—created
under the Dodd–Frank Act—can help
ensure payment providers will offer
high-quality innovative products with
effective financial disclosures.
Duncan Douglass, of Alston & Bird, argued that the current regulatory environment has created too much uncertainty
in the payments space. Given this uncertainty, some firms might be less likely
to invest in infrastructure or innovative
products and services while they wait for
rules to be finalized. Tim Willi, Wells
Fargo, concurred, stating that investors are holding off on making major

investments in the payments industry
as they wonder about regulators’ next
moves. Moreover, some conference participants contended that it is possible that
the new regulations could harm the very
consumers they were meant to protect.
For instance, Goodwin said he was concerned that excessive regulation could
disenfranchise consumers—especially
those with few payment options. If regulations require more identification information to set up an ACH account,
some consumers might be reluctant to
use prepaid cards, leaving them with
fewer options overall. Murphy countered
this point by stating that prepaid card
fees are less expensive than PIN debit
fees under the Dodd–Frank Act, which
in turn provides incentives for the government and other entities to move to
prepaid programs.
Rowe contended that consumers do not
want the government to tell them how
to pay for any given transaction; however,
they do want transparency from their
payment providers, clear term and fee
disclosures for using particular payment
products, and more knowledge about
their rights and responsibilities when
using them. Barr said that financial disclosures might need to be changed over
time; while disclosures can help some
consumers better understand financial
products and gauge their risks, too
much complex information may slow
down others’ decision-making about
which products to use.

Conclusion

Achieving a balance between healthy
competition and effective regulation in
the payments space can be difficult. The
amount of regulatory change currently
taking place in the U.S. payments market is unprecedented. Some have argued
that this development is positive. Barr
stated that healthy markets rely on good
faith, trust, and transparency, which the
recent regulations encourage. Tomasofsky
argued that the high level of public discourse about financial institutions being
generated by the new legislation is healthy
for the economy and the country.
That said, many conference participants
said they preferred a more traditional
market-driven approach, where companies focus on new strategies to address
consumers’ unmet financial needs. As
Oliver stressed, such strategies will likely
be more difficult to develop in the current economic and regulatory environment. He argued that banks must be
willing to sponsor innovation that may
be disruptive to their usual ways of doing
business. So, banks may need to be more
open to collaborations with nonbank
players that yield new products with a
global reach.
1

For more on the FDIC survey, see
www.economicinclusion.gov.

2 A decoupled debit card is a debit card that
is not issued by, and not tied to, a particular
retail financial institution. Rather, it is
issued by a third party and connected to
a consumer’s bank account through ACH.