ENG
NBU
THE ARTICLE PREPARED UNDER THE SPONSORSHIP OF USAID'S FINANCIAL SECTOR TRANSFORMATION PROJEC
WHAT DOES THAT MEAN?
WHAT DOES THAT MEAN?
SERHII KHOLOD, NBU:
"We intend to introduce
PSD2 into the Ukrainian
legislation very soon"
ENG
NBU
SERHII KHOLOD, NBU:
"We intend to introduce PSD2 into the Ukrainian legislation very soon"
THE ARTICLE PREPARED UNDER THE SPONSORSHIP OF USAID'S FINANCIAL SECTOR TRANSFORMATION PROJEC
WHAT DOES THAT MEAN?
WHAT DOES THAT MEAN?
Journalists of AIN.UA prepared this article following editorial standards and published it under the sponsorship of an advertiser
SERHII KHOLOD
Serhii Kholod is Deputy Governor of the National Bank of Ukraine, he is in charge of payment systems and currency circulation at the National Bank of Ukraine. Mr. Kholod has 27 years of experience in the Ukrainian banking sector. He has held senior positions as deputy chairman of the board and/or a board member of a number of Ukrainian banks (Swedbank, Tascombank, VTB Bank). Serhii Kholod was in charge of IT development at INDEX-BANK (Credit Agricole Group) and Raiffeisenbank Ukraine (renamed into OTP Bank in late 2006). From 1991 to 2002, Mr. Kholod worked at the National Bank of Ukraine where he helped create the NBU's e-mailing system and its System of Electronic Payments.
In an interview for the USAID Financial Sector Transformation project, Serhii Kholod spoke about the NBU's agenda to develop the Ukrainian payments market.
In an interview for the USAID Financial Sector Transformation project, Serhii Kholod spoke about the NBU's agenda to develop the Ukrainian payments market.
— According to our recent survey of FinTech and banks, the legislative initiative they regard as most important for market development is remote client identification. Is the National Bank working on it?
— The development of information technologies and the introduction of electronic services demand that modern banking processes be moved into the electronic domain. The main goal here is to make the interaction between banks and their clients simpler, as well as to increase financial inclusion.
The NBU has a stake in achieving these goals, which we approach by working simultaneously on a number of solutions. The first solution is related to the development of the NBU's BankID. The second one involves the potential introduction of remote video identification of individuals, as this service may also be in demand by the financial services providers. We assume that remote video identification of individuals may soon become one of the acceptable ways for identification.
Another exciting area in this context is the capability to identify an individual by a handwritten physical signature made not on paper, but on a tablet screen with a stylus. We are currently considering the use of a digital handwritten signature in the Ukrainian banking system. This initiative has been introduced by several banks. This is not remote identification per se, but definitely a step forward compared to a handwritten signature on paper. This capability is particularly relevant for rural areas where adequate communications might not be available for remote identification.
The NBU has a stake in achieving these goals, which we approach by working simultaneously on a number of solutions. The first solution is related to the development of the NBU's BankID. The second one involves the potential introduction of remote video identification of individuals, as this service may also be in demand by the financial services providers. We assume that remote video identification of individuals may soon become one of the acceptable ways for identification.
Another exciting area in this context is the capability to identify an individual by a handwritten physical signature made not on paper, but on a tablet screen with a stylus. We are currently considering the use of a digital handwritten signature in the Ukrainian banking system. This initiative has been introduced by several banks. This is not remote identification per se, but definitely a step forward compared to a handwritten signature on paper. This capability is particularly relevant for rural areas where adequate communications might not be available for remote identification.
— What about the NBU's BankID?
— The NBU's BankID system currently has 11 member banks, with quite a few applications for linkup submitted by other banks. Mobile operators and other commercial market players have also shown their interest in the system and are willing to provide services using the NBU's BankID for identification.
We have been vigorously developing the NBU's BankID over the last few years. The system was initially focused on the remote delivery of free administrative services. The scope of the project has expanded eventually and now involves commercial players.
At the same time, there is a need to address the matter of monetizing the services of the banks that provide client identification data. Indeed, banks carry out primary identification, either physical or remote, and bear the costs of it. Banks thus are not ready to share this information freely with other commercial market players. They spend a lot of money to attract and identify clients, therefore, they may expect certain reimbursement.
This is why we intend to introduce flexible rates within the NBU's BankID system. This would allow any commercial member requesting client identification to obtain it from the banks, for a reasonable fee. The company that requests identification information will have to pay, not the client. Financial companies and some mobile operators, for instance, have already expressed their willingness to pay reasonable rates for each identified client. Banks should also be interested.
We are currently working on tentative rates for commercial entities. Identification will, however, remain free for administrative services. We also hope that, with this mechanism, the number of members in our system will grow rapidly.
We have been vigorously developing the NBU's BankID over the last few years. The system was initially focused on the remote delivery of free administrative services. The scope of the project has expanded eventually and now involves commercial players.
At the same time, there is a need to address the matter of monetizing the services of the banks that provide client identification data. Indeed, banks carry out primary identification, either physical or remote, and bear the costs of it. Banks thus are not ready to share this information freely with other commercial market players. They spend a lot of money to attract and identify clients, therefore, they may expect certain reimbursement.
This is why we intend to introduce flexible rates within the NBU's BankID system. This would allow any commercial member requesting client identification to obtain it from the banks, for a reasonable fee. The company that requests identification information will have to pay, not the client. Financial companies and some mobile operators, for instance, have already expressed their willingness to pay reasonable rates for each identified client. Banks should also be interested.
We are currently working on tentative rates for commercial entities. Identification will, however, remain free for administrative services. We also hope that, with this mechanism, the number of members in our system will grow rapidly.
— Mobile operators have MobileID. Are they willing to abandon its development and concentrate on NBU's BankID?
— MobileID application implies that the client data must appear from somewhere. The majority of subscribers in Ukraine use prepaid packages, and few customers undergo identification by mobile operators. The latter are thus highly interested in their clients' primary identification performed via the NBU's BankID. This would subsequently allow for MobileID to be offered to such clients. In fact, only banks now have more or less relevant databases measured in tens of millions of identified users. The rest are either local, small players or their data has not been validated properly. Banks indeed validate their data quite rigorously, complying with the regulator's requirements. This includes passport data, tax codes, photos, copies of documents or any other necessary information.
— Who else, besides mobile operators, might be interested in using the NBU's BankID?
— Microfinance companies that provide lending services, other businesses that apply KYC procedures or are expected to obtain client data. We are also developing an integration project with the Ministry of Digital Transformation — the NBU's BankID will be used in the "Diya" mobile application as a key tool for user identification in the delivery of public services.
— Are you working to update the legislation on remote identification? When will a draft law or some document be released by the task group and discussed by the market?
— This is a matter of a few months and will probably be linked to the new regulations associated with the Open Banking and PSD2. It makes sense to submit all these bills to the legislators simultaneously, if not in a single batch.
— What is the status of your efforts to develop the laws on PSD2 and the E-Money Directive?
— As previously announced by the National Bank, we have recently initiated large-scale activities to revise fundamentally the legislation for the Ukrainian payments and remittances market.
We are talking about harmonizing the national payment laws with the European ones, in conformity with the Ukraine-EU Association Agreement. In particular, we intend to integrate provisions of the European PSD2 Directive into the national legislation, thereby boosting competition in the financial market and contributing to the innovative development of the domestic payments market.
This would create uniform transparent rules for banks and nonbanks players, increase competition and, as a result, have an impact on the quality and price of payment services.
We have a roadmap that defines the timeline and required resources. We are currently drafting the legislation. Donors, experts, and law firms are involved in the process. Meanwhile, we hold regular working meetings with the market players concerned, including external stakeholders and associations (between 5 and 7 such internal and external meetings are held each week).
The new regulation will be comprehensive, covering the issues of financial monitoring, currency regulations, e-money, which may be of interest to external players, and not only to those that currently operate in Ukraine.
We intend to present our draft proposals for public discussion soon. After that, we will accumulate feedback, consider alternative proposals and suggestions, and hope that our initiatives will be placed before the Parliament by the next mid-year.
We are talking about harmonizing the national payment laws with the European ones, in conformity with the Ukraine-EU Association Agreement. In particular, we intend to integrate provisions of the European PSD2 Directive into the national legislation, thereby boosting competition in the financial market and contributing to the innovative development of the domestic payments market.
This would create uniform transparent rules for banks and nonbanks players, increase competition and, as a result, have an impact on the quality and price of payment services.
We have a roadmap that defines the timeline and required resources. We are currently drafting the legislation. Donors, experts, and law firms are involved in the process. Meanwhile, we hold regular working meetings with the market players concerned, including external stakeholders and associations (between 5 and 7 such internal and external meetings are held each week).
The new regulation will be comprehensive, covering the issues of financial monitoring, currency regulations, e-money, which may be of interest to external players, and not only to those that currently operate in Ukraine.
We intend to present our draft proposals for public discussion soon. After that, we will accumulate feedback, consider alternative proposals and suggestions, and hope that our initiatives will be placed before the Parliament by the next mid-year.
— What, in your opinion, is the key priority for the sector for the legislative changes?
— In the regulation that we are currently drafting, the first priority is opening access to the client's banking information or account (the Open Banking concept). This is the key aspect of this regulation. We believe that this would give the market an opportunity to introduce new products, raise its competitiveness and bring down the price of services for the clients.
— The NBU's System of Electronic Payments is being transferred to the ISO 20022 messaging platform. What new capabilities will this bring to the SEP? Will ISO 20022 introduction help create a gateway for the SEP into the European payment system?
— ISO 20022 is a technological platform for standardized message formats. It may be compared to a highway to drive on. The new legislation introducing PSD2 rules provides the road signs that govern driving on the highways.
Our intent is to build normal high-quality "highways" that will allow free travel in the desired direction. Credit transfer, direct debit, various information requests, account balance — all these will be implemented according to the formats regulated by the ISO 20022.
The ISO 20022 XML formats are more flexible. They allow for more payment information to be transmitted, and enable simplified crediting for the so-called bulk payments where a transaction includes extensive supporting information. ISO 20022 will simplify routine work associated with the payment of pensions and payroll. This will reduce transaction costs and make the delivery more secure. Another example: Today, it is technically impossible to reverse a wrong transaction. A reversal requires banks to enter into correspondence. ISO formats make it much easier because everything is regulated. We will also have a separate message for transaction reversal.
Whether the NBU's SEP is going to interact with SEPA in Europe is an open question. That is not only for the NBU to decide. However, we will be offering this technological capability.
We will align our payment "highways" with the European SEPA and Target, introduce the ISO 20022 payment messages format and synchronize with the European laws. Today, the NBU's task is to build these highways. Whether the barrier on them is up or down, is for the regulators to decide together, after the highways have been commissioned.
Our intent is to build normal high-quality "highways" that will allow free travel in the desired direction. Credit transfer, direct debit, various information requests, account balance — all these will be implemented according to the formats regulated by the ISO 20022.
The ISO 20022 XML formats are more flexible. They allow for more payment information to be transmitted, and enable simplified crediting for the so-called bulk payments where a transaction includes extensive supporting information. ISO 20022 will simplify routine work associated with the payment of pensions and payroll. This will reduce transaction costs and make the delivery more secure. Another example: Today, it is technically impossible to reverse a wrong transaction. A reversal requires banks to enter into correspondence. ISO formats make it much easier because everything is regulated. We will also have a separate message for transaction reversal.
Whether the NBU's SEP is going to interact with SEPA in Europe is an open question. That is not only for the NBU to decide. However, we will be offering this technological capability.
We will align our payment "highways" with the European SEPA and Target, introduce the ISO 20022 payment messages format and synchronize with the European laws. Today, the NBU's task is to build these highways. Whether the barrier on them is up or down, is for the regulators to decide together, after the highways have been commissioned.
— Many believe that PayPal and TransferWise do not operate in Ukraine because of its small market. PayPal, nevertheless, operates even in smaller countries. What is the reason for that?
— It is claimed very often that players like PayPal consider our existing regulations as being too complicated. But what about ApplePay, GooglePay, Western Union and other major global players who came to Ukraine? They entered the Ukrainian payments market easily and without any difficulties.
Furthermore, in the past three or four years, we have significantly streamlined registration procedures and produced the necessary explanatory materials and instructions, including their English versions. They provide simple and detailed explanations about the fastest and easiest way to register in Ukraine. We have simplified our regulations for the registration of international online payment systems. For them, these rules are even simpler and allow very fast registration. This was the case with UnionPay, successfully registered last year. A few more payment systems are currently going through registration, and the process presents no problems for them.
Therefore, the key question here, I think, is PayPal's interest in the Ukrainian market. After all, this company accepts certain rules of the game, if it finds the market easy to understand and promising. In my opinion, complying with our regulatory requirements would not be difficult for them. The registration process is not rocket science; PayPal just needs to be entered into the Payment Systems Register. This would allow us to perform our oversight functions.
I think, therefore, that this matter has to do more with administrative and business aspects, than with the regulations. From a regulatory viewpoint, the procedure has been made as simple as possible.
Furthermore, in the past three or four years, we have significantly streamlined registration procedures and produced the necessary explanatory materials and instructions, including their English versions. They provide simple and detailed explanations about the fastest and easiest way to register in Ukraine. We have simplified our regulations for the registration of international online payment systems. For them, these rules are even simpler and allow very fast registration. This was the case with UnionPay, successfully registered last year. A few more payment systems are currently going through registration, and the process presents no problems for them.
Therefore, the key question here, I think, is PayPal's interest in the Ukrainian market. After all, this company accepts certain rules of the game, if it finds the market easy to understand and promising. In my opinion, complying with our regulatory requirements would not be difficult for them. The registration process is not rocket science; PayPal just needs to be entered into the Payment Systems Register. This would allow us to perform our oversight functions.
I think, therefore, that this matter has to do more with administrative and business aspects, than with the regulations. From a regulatory viewpoint, the procedure has been made as simple as possible.
— In Ukraine, banks and FinTech companies have different priorities. Communication between them is not the best. What would be your message for FinTech and banks?
— There is nothing new for me to say, I have been reiterating this at every conference, workshop or task group meeting. We are interested in developing comprehensible and transparent rules that might be different for FinTechs and banks, but understandable to them. Why different? In the global practice, different capital requirements and normativestandards exist for the businesses based on the types of financial services they provide.
The rules, nevertheless, should be easy to understand for all and provide the clarity necessary for planning an expansion to offer a wider range of services. For example, Revolut, in order to expand its business model, obtained a banking license in the UK in compliance with the regulatory requirements. The same thing should be happening here.
I see the future in the liaison between the FinTech companies and the banks. Some banks are not ready for this communication and, in my opinion, might lose their competitive edge.
The future may develop in three ways. The first is, "See nothing, hear nothing, know nothing, I am a bank and no one can serve clients better than I." The second is, "I am doing my own FinTech." Examples of the second approach are Monobank (operating under the Universal Bank's license) and, to some extent, PrivatBank, which has been developing its FinTech functionality. The third way is a mutually beneficial cooperation: FinTech companies are faster, more flexible and can provide interesting tools to their clients, and they can do it through the banking system to comply with the complex regulatory requirements that they do not want to invest in. For example, they might unwilling to set up AML, financial monitoring, or customer service units.
To recapitulate, the future lies with the cooperation between FinTech and banks. Those banks that fail to restructure, risk taking a back seat. On the other hand, I do not think they would disappear in the next five or ten years. But they are likely to lose a significant share of their market and clients. I also do not rule out a possibility that, similar to the developments in the European market, some FinTech companies with significant potential will eventually recognize the need for a banking license. A good example is the mentioned Revolut and PayPal, which has a European banking license in Luxembourg.
The rules, nevertheless, should be easy to understand for all and provide the clarity necessary for planning an expansion to offer a wider range of services. For example, Revolut, in order to expand its business model, obtained a banking license in the UK in compliance with the regulatory requirements. The same thing should be happening here.
I see the future in the liaison between the FinTech companies and the banks. Some banks are not ready for this communication and, in my opinion, might lose their competitive edge.
The future may develop in three ways. The first is, "See nothing, hear nothing, know nothing, I am a bank and no one can serve clients better than I." The second is, "I am doing my own FinTech." Examples of the second approach are Monobank (operating under the Universal Bank's license) and, to some extent, PrivatBank, which has been developing its FinTech functionality. The third way is a mutually beneficial cooperation: FinTech companies are faster, more flexible and can provide interesting tools to their clients, and they can do it through the banking system to comply with the complex regulatory requirements that they do not want to invest in. For example, they might unwilling to set up AML, financial monitoring, or customer service units.
To recapitulate, the future lies with the cooperation between FinTech and banks. Those banks that fail to restructure, risk taking a back seat. On the other hand, I do not think they would disappear in the next five or ten years. But they are likely to lose a significant share of their market and clients. I also do not rule out a possibility that, similar to the developments in the European market, some FinTech companies with significant potential will eventually recognize the need for a banking license. A good example is the mentioned Revolut and PayPal, which has a European banking license in Luxembourg.
— At the National Bank, you are in charge of both cashless and cash. Some experts cite cheaper cash among the reasons why we are moving to the cashless economy so slowly. What is your opinion of this matter?
— The attempts to improve one thing at the expense of the other baffle me. All branches of the payments ecosystem should develop freely. Cash is now a well-oiled mechanism that functions with a clockwork precision. Cash costs only between 0.2% and 0.3%. Collection copes with these rates, banks are happy with this situation. Cash is not to blame for the cashless branch developing more slowly so far. Raising financial literacy levels requires extra efforts. We need to offer consumers exciting and accessible tools, similar to Swish or QR transactions, which may turn out to be cheaper.
The National Bank has an expert group for cash-related projects. We are building a modern cash processing center and improving the communication system. We implemented a delegate model when the CIT companies appeared on the market.
We also run a number of projects for cashless, such as the development of financial inclusion, transition to ISO 20022, PSD2, IBAN, development of the PROSTIR national payment system. We have merged all these projects into a large single program under a common umbrella. A dedicated committee has been set up that collectively manages the evolution both of money circulation and of payment systems.
Attempting to bring about something without any investment, efforts, or intellectual input, by merely raising the cash and collection rates, is wrong. The tools should develop in parallel. As soon as cashless payments become as convenient as they are now in Sweden, where almost no one uses cash, where even the percentage of the plastic card usage is dropping, and people pay cheaply via Swish, cash will disappear from the pockets — it will be substituted with other tools. When it happens, collection might become more expensive. This is because cash still has to be transported, although there will not be much of it.
The National Bank has an expert group for cash-related projects. We are building a modern cash processing center and improving the communication system. We implemented a delegate model when the CIT companies appeared on the market.
We also run a number of projects for cashless, such as the development of financial inclusion, transition to ISO 20022, PSD2, IBAN, development of the PROSTIR national payment system. We have merged all these projects into a large single program under a common umbrella. A dedicated committee has been set up that collectively manages the evolution both of money circulation and of payment systems.
Attempting to bring about something without any investment, efforts, or intellectual input, by merely raising the cash and collection rates, is wrong. The tools should develop in parallel. As soon as cashless payments become as convenient as they are now in Sweden, where almost no one uses cash, where even the percentage of the plastic card usage is dropping, and people pay cheaply via Swish, cash will disappear from the pockets — it will be substituted with other tools. When it happens, collection might become more expensive. This is because cash still has to be transported, although there will not be much of it.
— The NBU inaugurated an innovation center last summer. Our survey shows that the FinTech companies are skeptical about it. What are the functions of the center? And do you consider building an actual sandbox on its basis in the future?
— Yes, we would like to design a full-fledged sandbox and we have studied the experience of Lithuania, Estonia and other countries. At the moment, our Expert Board is actually not a classic sandbox with a capacity for running pilot projects without the need for relevant licenses to cover new types of products. We need to amend the National Bank Law to be able to have a sandbox. However, our legislation is changing quite slowly. We hope that things will become easier in the future.
So far, our idea is to work in the Expert Board format to accumulate information about the necessary exceptions for companies, so that they could run their pilot projects without breaking the law.
Following the Expert Board's operation in 2019, we will prepare a report on the meetings held and the requests submitted to us. The Board of the National Bank will then decide whether we are moving towards setting up a full-fledged sandbox or leaving the project to function as a consulting board.
So far, our idea is to work in the Expert Board format to accumulate information about the necessary exceptions for companies, so that they could run their pilot projects without breaking the law.
Following the Expert Board's operation in 2019, we will prepare a report on the meetings held and the requests submitted to us. The Board of the National Bank will then decide whether we are moving towards setting up a full-fledged sandbox or leaving the project to function as a consulting board.
— Several trends have emerged globally in the development of retail payments: instant payment systems, like the Swedish Swish; systems that offer online payments directly from a bank account, like iDEAL. Does Ukraine need a similar system to process small transactions? Could it be that mobile operators might drive retail payments?
— Mobile operators already handle microtransactions, although they are focused on addressing a rather narrow set of payments, which mostly concern account top-up or some services of their own. No one, however, prevents them from expanding. Under 14,000 hryvnias, they can offer micro-transactions. Even with this restriction, 90% of the micro-transaction market needs will be covered.
If we examine the emergence of instant payments in Europe, we will find that they had no actual substitute tool. In Ukraine, a kind of monopoly exists: the vast majority of users have PrivatBank accounts. PrivatBank customers are able to access actual instant payments at any time. Both individuals and vendors can use this system for microtransactions. For example, on the Prom.ua and OLX platforms most payments are made via Privat24. In other words, a substitute tool is available in Ukraine.
Stronger competition could bring down the price of transactions for clients and vendors. Thus, we are considering several options. We could upgrade the SEP, run it 24/7 and add instant payments to it. A second option would be to implement instant payments based on the PROSTIR National Payment System, or to implement a third system that is already operational in other markets (for example, the one similar to TARGET Instant Payment Settlement (TIPS)). Optimistically, such a project could be completed in a year or a year and a half, and between 1.5 and 2.5 years within the SEP.
If we examine the emergence of instant payments in Europe, we will find that they had no actual substitute tool. In Ukraine, a kind of monopoly exists: the vast majority of users have PrivatBank accounts. PrivatBank customers are able to access actual instant payments at any time. Both individuals and vendors can use this system for microtransactions. For example, on the Prom.ua and OLX platforms most payments are made via Privat24. In other words, a substitute tool is available in Ukraine.
Stronger competition could bring down the price of transactions for clients and vendors. Thus, we are considering several options. We could upgrade the SEP, run it 24/7 and add instant payments to it. A second option would be to implement instant payments based on the PROSTIR National Payment System, or to implement a third system that is already operational in other markets (for example, the one similar to TARGET Instant Payment Settlement (TIPS)). Optimistically, such a project could be completed in a year or a year and a half, and between 1.5 and 2.5 years within the SEP.
— If the SEP is used for microtransactions, will its lack of a clearing mechanism constitute a problem? Or liquidity is it not a problem for the Ukrainian banks? How difficult is it to design such a mechanism and is it needed in the retail system?
— The liquidity control mechanism is certainly an important tool that should be integrated into an instant payment system. The complexity of its implementation depends to some extent on the platform selected for such a system. For example, PROSTIR NPS has its own clearing module that calculates the mutual liabilities between the issuing and acquiring banks on the transactions with the system's payment cards, and this module could potentially be upgraded. Vendors who have already implemented the instant payments functionality in other countries also have such solutions.
— Portmone has expressed interest in having a settlement account at the National Bank. Central Banks in the UK, Lithuania, Hong Kong have allowed nonbanks to hold accounts with them. Is this possible in Ukraine?
— If this matter concerns access by the nonbanks to our RTGS system, the NBU's SEP, we will not be considering this option within a two-year horizon. Why? Because banks have done a lot to implement the KYC, AML, financial monitoring policies and the associated reporting. This entailed large labor costs, and the creation of complicated units that liaise not only with the National Bank, but also with the State Financial Monitoring Service and other regulators. These rules must be observed. At the current stage, FinTech companies should interact with the banks in these matters. The state will thus be confident that the KYC and AML principles are being properly observed. But the market does not stand still. Legislation and regulation are being updated, and nonbank financial institutions are evolving. The liaison among all market participants, the quality and functionality of the products and services will certainly grow.
The views and opinions of the author expressed herein do not necessarily state or reflect those of the U.S. Government or USAID.
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