Management and marketing

2.3 Features of building a payment infrastructure in the conditions of the modern Russian banking market

In 2012, the first stage of the implementation of the norms of the legislation of the Russian Federation regulating electronic money transfers was completed. The market has gained a legal field, and therefore, the interest of credit institutions in the introduction of such a product as electronic money into their service lines is naturally increasing. For large banks, this direction is attractive due

to the opening opportunities for penetration into the retail payments market, for small credit institutions established before the entry
into force of the 161-FZ as operators of electronic wallets, which subsequently received licenses from NGOs, is an inevitable imperative for continuing operations. Over the past seven years
, many credit institutions have shown interest in electronic money, from small regional to the largest federal banks. But not every bank can afford to organize a full-fledged EMF functioning system
, it is more profitable for many to enter EMF through partners.
The possibilities of electronic money have opened prospects
for many ideas and startups, the most powerful players in the information business (mobile operators, Internet service providers, online TV and other content services) began rapid development after they received effective payment services for their network services. Today, you can pay with electronic money for everything: from cat food, to traffic police fines and state duties.
Currently, electronic money is considered as a potential substitute for cash for micropayments, including bank cards on the Internet. But by its qualities, electronic money can only partially replace and cannot completely displace cash in settlements.
Artificial limitation of the amount that can The need to save money in an electronic wallet is caused by the uncertainty of regulators in the reliability and security of using such a payment instrument, as well as the possibility of using electronic money by criminals.
But it is obvious that electronic money will continue its rapid development, and in the future we expect a much wider use of them in various fields of activity, as well as the emergence of new electronic money systems .
A significant disproportion between the issue of bank cards and the activity of their use is also a stimulating factor. The implementation
of large-scale salary projects was not enough to get rid of the dominance of cash at least a little. From this point of view, the segment of small remote payments remains outside the scope of "traditional" non-cash payments.
Over 5-7 years, the share of non-cash payments has certainly
grown significantly. Infrastructure has developed, pos terminals linked to online sales registers have appeared. However, these processes are still characteristic, first of all, for cities with millions, and not for Russia as a whole.
Perhaps the main limitation of entering a new market for a credit institution may be the unwillingness to restructure existing business models. The implementation of products based on electronic money requires not only close attention to the technological component, but also the flexibility of business processes. As the experience of large Russian electronic money systems shows, successful development requires constant monitoring of customer needs, provision of new services and consideration of market conditions. For those financial institutions that previously concentrated mainly on increasing capitalization, such restructuring presents certain difficulties. In other words, marketing campaigns that are popular for deposit products (for example, the issuance of souvenirs or gifts), for the target audience of electronic payments will not only are irrelevant, but even irrelevant. It is also important that in payment systems profit is generated mainly due to the number of transactions, that is, the turnover of funds comes to the fore .
Secondly, products based on electronic money can
contribute to a synergistic effect. There are already
payment instruments on the market that are focused on this opportunity, in particular, plastic cards issued by electronic money systems.
This is especially true in cases where convenience for the consumer
more than compensates for possible restrictions imposed on the client, primarily limits on a one-time purchase or turnover of funds.
Regulation of electronic money is less stringent than legislation relating to bank account (deposit) agreements.
This simplifies the procedures for accepting persons for service, in some cases frees from the need for customer identification. On the other hand, the insignificant degree of spread of non-cash payments in the micro segment and among the so-called "non-banking" population creates demand for simple, understandable and convenient tools.
Thirdly, the activity of transferring electronic funds may be relevant for those organizations that, by virtue of their main activity, keep customer advances on their accounts. First of all, of course, mobile operators belong to them. Mobile operators to a certain extent found themselves in a more advantageous position, since the issues
of mobile commerce were directly regulated by Federal Law
No. 161-FZ of 27.06.2011 "On the National Payment System". Despite the fact that payments from a mobile phone account are now impossible without the involvement of a credit institution, and the so-called "premium" SMS messages turned out to be completely outside the legal framework, such a situation is better than the one in which, for example, transport organizations were put. 88
So, legally correct registration of the use of funds on the card for travel in the subway for small payments is a non-trivial task.
Before proceeding to the organization of operations with electronic
money, it is necessary to understand what EDS transfers are.
Analysts and lawyers have repeatedly touched on this issue over the past year and a half. Nevertheless, we consider it necessary to emphasize again: e–money transfers are transfers without opening bank accounts. Such a simplified approach seriously restricts the basic set of operations that a credit institution must obtain a license to perform . Non-bank credit organizations (NPOs) that have the right to make money transfers without opening bank accounts and
related other banking operations have the minimum necessary license to work with electronic money. However, due
to the specifics of the EMF transfer, other types of NPOs and banks can also fully carry out operations with EMF.
In this regard, the main issue for many electronic money systems
after the adoption of the Federal Law "On the National Payment System" was the choice of the most preferred license. When choosing between a bank, a payment NCO or a settlement NCO, two key
considerations are taken into account: how wide the list of acceptable transactions is and how expensive it is to obtain a license. The difficulty lies in the fact that these factors can only be placed on opposite scales: it is impossible to get a "cheap" and at the same time universal license. The choice may be determined by what range of services the electronic payment system plans to provide to customers.
Banks have found themselves in an advantageous position in the implementation of electronic payment projects – they actually do not have the restrictions inherent in "non-bank" licenses, they have (as a rule) a wide range of products. Nevertheless, the independent implementation of electronic money projects by both large and small banks is rather an exception in the market. In our opinion, the reason for this is the lack of experience in implementing high–tech solutions. During the discussion of the Federal Law "On the National Payment System", opinions were expressed that simplified regulation for electronic money systems is unnecessary.
The experience of the years since the adoption of the law has shown the unreasonableness of such a point of view. Reducing the regulatory burden allowed NGOs to direct resources
to maintaining existing technological solutions and developing new ones. Thus, the division into "classic" banks and more flexible
electronic money systems has been preserved.
The necessity and inevitability of the appearance of electronic money follow
from the definition, properties and function of money. As soon as cheap
technical means appeared, allowing to realize electronic money electronic money also appeared. By technical means we mean "new wave technologies" (computers, smartphones and tablets,the pervasive Internet) and other IT products (
information security tools, databases, websites). Naturally, it was technology and IT companies that were the first to notice and began to occupy a new niche, and
only then both banks and the regulator "caught up". And this is completely logical:
technology companies, understanding technologies, offered novelties in the financial sector, and the financial sector, after thinking (and seeing prospects), joined the development process.
All the current problems of the implementation of both electronic money and transactions with them are temporary. Part of these problems follows from the novelty of the financial instrument of electronic money itself. So far, there are no practices or laws preventing these problems (technical overdrafts). Some of the problems, or rather tasks, have not yet been fully solved (limited anonymity, and the convenience of electronic money as a means of payment is far from indisputable).
Some problems, on the contrary, are only emerging - because now, with the rapid growth of the number of e-money operators, they will have to not just solve the problem of transferring funds, but also integrate technical means of making payments and transfers (mobile applications, for example) conveniently for the end customer. But, all these problems are clear and solvable, so the prospect of electronic money is excellent.
Without a doubt, the provision of services based on electronic money is an attractive business direction, both for credit and for a number of other institutions. At the same time, several "pitfalls" remain on this path , which must be taken into account in order to reduce possible legal risks. However, this is not the only reason
why experts continue to pay special attention to the analysis of the regulation of money transfers. Unfortunately, the remaining shortcomings in regulatory legal acts restrain, and in the future - determine the direction of the evolution of individual payment products. Nevertheless , in the future, the importance of regulatory analysis will only increase. In this regard, understanding the technical details that are likely to undergo changes in the near future is the key to the successful development of the payment industry and each of its participants. Let's consider promising directions for the introduction of electronic money into the payment and settlement system. From the point of view of ensuring the most optimal composition of money turnover, the spheres of optimal use of electronic money were identified.
Firstly, this is the sector of micropayments, including the sector of payments
made on a regular or permanent basis (payments in transport, in catering organizations, as well as in cultural organizations, payment for parking cars, payment for communication services and housing and communal services, etc.). In this sector, electronic money will function within the framework of a substitutional approach, displacing traditional money: cash in this area is less convenient, since it has limited divisibility, creates problems of providing so -called change when calculating large banknotes or a change coin of a larger denomination. This circumstance complicates the process of making a cash payment transaction and slows it down. The use of non-cash money for micropayments looks unreasonable due to more complex processing and, as a result, higher fees charged for making the payment.
Secondly, this is the e-commerce sector, which is currently characterized by rapid development. In this sector , electronic money will function in accordance with an additive approach to expanding the composition of monetary turnover, complementing traditional
means of circulation and payment.
Firstly, it is the sector of micropayments, including the sector of payments
made on a regular or permanent basis (payments in transport, in catering organizations, as well as in the field of culture organizations, payment for parking cars, payment for communication services and housing and communal services, etc.). In this sector, electronic money will function as part of a replacement approach, displacing traditional money: cash in this area is less convenient because
it has limited divisibility, creates problems of providing so-called
- it is called surrender when calculating large banknotes or a change of a larger denomination. This circumstance complicates the process of making a cash payment transaction and slows it down. The use of non-cash money for micropayments looks unreasonable due to more complex processing and, as a result, higher fees charged for making a payment.
Secondly, it is the e-commerce sector, which is currently characterized by rapid development. In this sector , electronic money will function in accordance with the additional an approach to expanding the composition of monetary turnover, complementing the traditional means of circulation and payment.
Regulation of electronic money is less stringent than legislation relating to bank account (deposit) agreements.
This simplifies the procedures for accepting persons for service, in some cases frees from the need for customer identification. On the other hand, the insignificant degree of spread of non-cash payments in the micro segment and among the so-called "non-banking" population creates demand for simple, understandable and convenient tools.
Thirdly, the activity of transferring electronic funds may be relevant for those organizations that, by virtue of their main activity, keep customer advances on their accounts. First of all, of course, mobile operators belong to them. Mobile operators to a certain extent found themselves in a more advantageous position, since the issues of mobile commerce were directly regulated by Federal Law
No. 161-FZ of 27.06.2011 "On the National Payment System". Despite the fact
that payments from a mobile phone account are now impossible without the involvement of a credit institution, and the so-called "premium" SMS messages turned out to be completely outside the legal framework, such a situation is better
than the one in which, for example, transport organizations were put. So, legally correct registration of the use of funds on the card for travel in the subway for small payments is a non-trivial task.
Before proceeding to the organization of operations with electronic money, it is necessary to understand what EDS transfers are. Analysts and lawyers have repeatedly touched on this issue over the past year and a half. Nevertheless, we consider it necessary to emphasize again:
e–money transfers are transfers without opening bank accounts. Such a simplified approach seriously restricts the basic set of operations that a credit institution must obtain a license to perform.
Non-bank credit organizations (NPOs) that have the right to make money transfers without opening bank accounts and related other banking operations have the minimum necessary license to work with electronic money. However, due to the specifics of the EMF transfer, other types of NPOs and banks can also fully
carry out operations with EMF.
In this regard, the main issue for many electronic money systems after the adoption of the Federal Law "On the National Payment System" was the choice of the most preferred license. When choosing between a bank, a payment NCO or a settlement NCO, two key considerations are taken into account: how wide the list of acceptable transactions is and how expensive it is to obtain a license. The difficulty lies in the fact that these factors can only be placed on opposite scales: it is impossible to get a "cheap" and at the same time universal license. The choice may be determined by the range of services the electronic payment system plans
to provide to customers. Banks have found themselves in an advantageous position in the implementation of electronic payment projects – they actually do not have
the restrictions inherent in "non-bank" licenses, they have (as a rule) a wide
range of products. Nevertheless, the independent implementation of electronic money projects by both large and small banks is rather an exception in the market. In our opinion, the reason for this is the lack of experience in implementing high–tech solutions. During the discussion of the Federal Law "On the National Payment System", opinions were expressed that simplified regulation for electronic money systems is unnecessary.
The experience of the years since the adoption of the law has shown the unreasonableness of such a point of view. Reducing the regulatory burden allowed NGOs to direct resources to maintaining existing technological solutions and developing new ones.
Thus, the division into "classic" banks and more flexible electronic money systems has been preserved.
The necessity and inevitability of the appearance of electronic money follow from the definition, properties and function of money. As soon as cheap technical means appeared, allowing to realize electronic money, electronic money also appeared. By technical means we mean "new wave technologies" (computers, smartphones and tablets, the pervasive Internet) and other IT products ( information security tools, databases, websites). Naturally, it was technology and IT companies that were the first to notice and began to occupy a new niche, and only then both banks and the regulator "caught up". And this is completely logical: technology companies, understanding technologies, offered novelties in the financial sector, and the financial sector, after thinking (and seeing prospects), joined the development process. All the current problems of the implementation of both electronic money and transactions with them are temporary. Part of these problems follows from the novelty of the financial instrument of electronic money itself.
So far, there are no practices or laws preventing these problems (technical
overdrafts). Some of the problems, or rather tasks, have not yet been fully solved 90 (limited anonymity, and the convenience of electronic money as a means of payment is far from indisputable). Some problems, on the contrary, are only
emerging - because now, with the rapid growth of the number of e-money operators, they will have to not just solve the problem of transferring funds, but also integrate technical means of making payments and transfers (mobile
applications, for example) conveniently for the end customer.
But, all these problems are clear and solvable, so the prospect of electronic money is excellent. Without a doubt, the provision of services based on electronic money is an attractive business direction, both for credit and for a number of other institutions. At the same time, several "pitfalls" remain on this path, which must be taken into account in order to reduce possible legal risks. However, this is not the only reason why experts continue to pay special attention to the analysis of the regulation of money transfers. Unfortunately, the remaining shortcomings in regulatory legal acts restrain, and in the future - determine the direction of the evolution of individual payment products. Nevertheless, in the future, the importance of regulatory analysis will only increase. In this regard, understanding the technical details, which are likely to undergo changes in the near future, is the key to the successful development of the payment industry and each of its participants.
Let's consider promising directions for the introduction of electronic money into
the payment and settlement system.
Firstly, this is the sector of micropayments, including the sector of payments made on a regular or permanent basis (payments in transport, in catering organizations, as well as in cultural organizations, payment for parking cars, payment for communication services and housing and communal services, etc.). In this sector, electronic money will function within the framework of an institutional approach, displacing traditional money: cash in this area is less convenient, since it
has limited divisibility, creates problems of providing so-called change when calculating large banknotes or a change coin of a larger denomination. This circumstance complicates the process of making a cash payment transaction and slows it down. The use of non-cash money for micropayments looks unreasonable due to more complex processing and, as a result, higher fees charged for
making a payment. Secondly, this is the e-commerce sector, which is currently
characterized by rapid development. In this sector, electronic money will function in accordance with an additive approach to expanding the composition of monetary turnover, complementing traditional means of circulation and payment.
The volume of cash, non-cash and electronic money will increase significantly if credit institutions issue electronic money at the expense of cash. If the issue
of electronic money will be carried out at the expense of non-cash money, then the choice of the issuer of electronic money will not affect the volume of cash, non-cash and electronic money, provided that the rate of reserve requirements of obligations on electronic money will be absent.
Otherwise, the increase in the volume of cash, non-cash and electronic money will be significantly less if they are issued by a credit institution. As a rule, the issue of electronic money is carried out at the expense of cash, since with this model of issue there is the greatest92 expansion of the possibilities of using electronic money, both in a new quality and in new conditions.
The infrastructural direction is associated with increasing the availability of electronic money and expanding the scope of their application through the development and legalization of payment instruments, as well as standardization and unification of the technological component.
As part of this direction, it is advisable to introduce or expand the use of prepaid payment instruments, including mobile payment instruments built according to the scheme of both credit and debit transfers - methods of making payment transactions using prepaid value stored on a particular technical device. The features of electronic money, being a prepaid value, determine the corresponding features of prepaid payment instruments [55]:
- Payment transactions are carried out by transferring the prepaid value using a technical device, the type of which determines the method of transferring, storing and processing information;
- the transfer of electronic money is carried out through the assignment of the claim;
- clearing and determination of clearing positions can be carried out by the issuer's accounting department; repayment of obligations is carried out by offsetting mutual claims based on certain clearing positions.

The introduction of new prepaid payment instruments will solve the tasks of increasing the availability of financial services, ensuring high efficiency of payments, as well as making them safer and more convenient.

Also, within the framework of the infrastructure direction, it is necessary to unify the standards of information exchange. Taking into account the fact that the technical devices necessary for carrying out payment transactions using electronic money are diverse, we consider the most important factor constraining the development of the sphere of making payments using electronic money to be the low level of efficiency of intra-system interaction of settlement participants, including information and technological. Standardization and unification of financial transactions will increase the efficiency of activities by automating processing and reducing the costs of making payment transactions. Ensuring and improving the security of making payment transactions using electronic money. Currently , electronic money has a prepaid nature, which determines the structure of the finances of issuing organizations: cash and non-cash funds have a significant share in the asset, and short–term liabilities in the liability.
In this regard, the following is proposed: It is necessary to introduce the main directions of investing free liquid assets in reliable assets with a low level of risk. These include debt securities issued in rubles or foreign currency by the central bank or the government, development banks, deposits of reliable banks with
a high credit rating, etc.
- It is advisable to introduce a requirement to ensure the sufficiency of solvency in terms of repayment of obligations on electronic money by a bank guarantee in the amount of funds invested in less liquid but more profitable assets, whereby a bank or other credit institution undertakes to pay the holder of electronic money issued by a non-credit organization a monetary amount upon submission of a claim for its payment. This circumstance will provide additional financial profitability to organizations involved in the process of issuing electronic money without significantly reducing the liquidity risk.
Within the framework of the conducted research, the main licensing requirements necessary for obtaining a license to carry out exclusive activities with electronic money are formulated, to which we refer the following:
- the organization must be registered on the territory of Russia and be a resident of Russia;
- the organization must be registered in the organizational and legal form of a limited liability company or a joint-stock company;
- the equity capital must have a size that ensures the financial stability of the organization that issues electronic money;
The organization should implement a system for identifying and managing risks inherent in electronic money systems in accordance with risk profiles.;
The managing staff of all departments of the organization that issues electronic money must have an adequate level of qualification, higher economic education in the relevant specialty, as well as a proper level of business reputation.
Among the qualitative measures to minimize the liquidity risk, we refer to the consolidation at the legislative level of the norm requiring organizations
that issue electronic money to keep the funds received from the issue of electronic money separately from other funds. A quantitative measure of liquidity should be recognized as the establishment of a liquidity standard. In this regard, we have clarified the liquidity standard established for non-bank credit institutions that have the right to make money transfers without opening bank accounts and
related other banking operations, defined as the ratio of the amount of separately stored liquid assets with a maturity in the next 30 days, as well as assets invested in less liquid assets., but secured by a bank guarantee, to the volume of obligations
assumed by organizations regarding the issue of electronic money, adjusted for the amount of obligations to provide a bank guarantee. The minimum value of the standard should be 100%.
Compliance with the principles of supervision, as well as the implementation of certain tools for supervision of the activities of organizations that are not banking, but that issue electronic money, is designed to ensure a high level of security of payments, while maintaining a high potential for the development of the sphere of relevant relations.