2011年-世界发展银行全球_Mobile_Banking_and_Financial_Inclusion___The_Regulatory_Lessons_34页_724kb

Mobile Banking and Financial Inclusion: The Regulatory Lessons

Core Content

This working paper by Michael Klein and Colin Mayer explores the implications of mobile banking for financial inclusion and regulatory frameworks. It highlights how mobile banking is transforming financial services, particularly in developing economies, by enabling access to banking in areas where traditional banking infrastructure is lacking. The paper emphasizes the need for a nuanced regulatory approach that reflects the unique nature of mobile banking services, which are often structured differently from traditional banking.

Main Points

• Mobile Banking as a Financial Revolution: Mobile banking is driving a significant shift in financial inclusion, especially in low-income and underserved communities. It allows people to access financial services through mobile phones, bypassing the need for traditional banking infrastructure.

• Rapid Growth and Expansion: Mobile money schemes have grown rapidly, with over 140 global ventures by the end of 2011. Kenya's M-PESA is a standout success, with over 50% of adults using its mobile payment system within four years.

• Unbundling of Financial Services: Mobile banking separates financial services into distinct components: exchange of money, safe-keeping, transportation, and investment. This disaggregation provides a clearer understanding of the nature of financial services and the regulatory implications.

• Key Components of Mobile Banking:

  • Exchange of Forms of Money: Mobile banking facilitates the exchange of cash and book-entry money (BEM) through mobile platforms, often using SMS for confirmation.
  • Safe-Keeping: Mobile money systems allow users to store money electronically, with some schemes requiring identity verification and anti-money laundering (AML) compliance.
  • Transportation: Mobile banking enables the transfer of money between users without relying on traditional banking systems, making transactions faster and more transparent.
  • Investment: While some mobile money systems invest funds in regulated banks, the focus is primarily on safe-keeping and transactional efficiency.

Regulatory Considerations

• Business Conduct Regulation: This includes consumer protection and AML measures. Cash merchants, for example, may be required to perform identity checks and maintain transparency in their operations.

• Prudential Regulation: Involves capital adequacy, liquidity, and risk management. It is more relevant for the safe-keeping and investment components of mobile banking, particularly when funds are held in regulated institutions.

• Competition Policy: Mobile banking raises concerns about market monopolies and the need to maintain an open environment for new business models. Regulators must ensure that the system remains competitive and accessible.

• Interoperability: Mobile banking systems may need to interconnect with other financial services and institutions, which requires clear regulatory guidelines to ensure seamless and secure transactions.

Key Information

• M-PESA as a Case Study: M-PESA in Kenya is a prime example of mobile banking success. It allows users to store, send, and withdraw money through a network of retail agents, significantly increasing financial inclusion.

• Cash-in/Cash-out Services: These are critical for mobile banking, enabling users to convert between cash and BEM. Retail agents, often located in informal markets, play a key role in this process.

• Regulatory Separation: The paper stresses the importance of separating mobile money accounts from the telecom company's accounts to prevent risks to customer funds. This is exemplified by Safaricom's use of a special trust to safeguard M-PESA deposits.

• Impact on Financial Systems: Mobile banking provides insights into the nature of financial services and can influence the design of regulation in both developed and developing economies, particularly in terms of the separation of commercial and investment banking.

Conclusion

The paper concludes that the regulatory approach to mobile banking should be tailored to its specific components and risks. It advocates for a comprehensive and practical framework that considers the unique aspects of mobile money services, such as their role in financial inclusion, the need for consumer protection, and the importance of maintaining an open and competitive market. Mobile banking's ability to unbundling financial services offers a new perspective on financial regulation and highlights the potential for innovation in financial systems.