Schlagwortarchiv für: Regulators

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An open marketplace has expanded both supply and demand for taxi services. Photo: Daniel Horacio Agostini

One unique feature of Ripple is the open nature of the network, which has numerous benefits for banks, market makers, regulators and ultimately consumers.

Given that the idea of an open value network is somewhat of a new paradigm, it’s worth going over just exactly what might mean for the payment ecosystem’s various stakeholders.

The benefit of an open network for banks

Managing information is pivotal for banks. As part of their daily operations, banks need to manage an endless flow of payment data, which also includes customer information. Not only do customers expect and demand this information to be kept private, regulators require it. Moreover, it’s important for banks to maintain confidentiality since transaction information—such as the volume or the currency—is considered competitive intelligence.

Throughout our numerous conversations with banks and financial institutions, a common question was whether or not an open network could facilitate both privacy and confidentiality. At first glance, “open” may seem concerning because banks naturally expect payment networks to be private.

In reality, Ripple satisfies both privacy and confidentiality. While transaction information on the ledger is public, payment information is not. It’s difficult for anyone to associate transaction information with any specific bank.

Finally, there are benefits to transparency, especially for cross-border (out-of-network) payments, which have traditionally been relatively opaque. End-to-end traceability will not only reduce risk and delays, it should also reduce the cost of compliance allowing banks to lower costs of fee-disclosures and regulatory reporting.

The benefit of an open network for market makers

The market for settling payments is huge. The heart of the issue is that it isn’t necessarily accessible. This undermines both efficiency and competition. Meanwhile, market makers already specialize in managing capital and the associated risks. As we’ve discussed previously, what Ripple does is essentially allow market makers to access what is essentially a marketplace for float, where market makers can compete to provide liquidity, which lowers costs for banks and businesses.

One way to understand the impact of expanding accessibility is to look at how Uber affected the marketplace for taxis. In San Francisco, the taxi market was about $ 140 million per year, according to Uber CEO Travis Kalanick. But Uber is already making three times that with revenues of $ 500 million per year. This means that competition doesn’t necessarily cannibalize existing revenue, it can help the entire pie grow much larger. In the case of Uber, by expanding the supply of drivers and offering a far better experience, many more customers decided to use taxi services rather than other modes of transportation, expanding the marketplace and eventually spurring on both innovation and competition.

The benefit of an open network for regulators

The role of regulators is to protect the welfare of any payment systems, primarily because payments can be used to finance activity that is deemed detrimental to society—such as crime and terrorism. As a result, being able to track payments is fundamental to regulators doing their job.

With the way things are today, it’s extremely difficult to monitor transaction activity given disparate systems, networks, and platforms plus the continued prevalence of physical cash. As a result, transaction monitoring is a highly manual and operationally intensive process, which means that regulators incur high costs simply to do their job or in some cases, they aren’t able to do their job as effectively as they would like.

For regulators, the open nature of Ripple provides further transparency and payment traceability, thereby reducing their costs while allowing them to do their jobs more effectively. If regulators and banks are able to automate compliance processes with Ripple, it reduces costs for everyone in the ecosystem.

In the end, however, the real winners are consumers, who benefit from a safer, more open, and competitive ecosystem that provides a platform for innovation, better access, and lower costs.

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Continuing our dialogue with regulators about efforts to build more efficient, safer payment systems, Ripple Labs recently detailed the benefits and implications of a distributed network to the UK’s new Payment System Regulator (PSR).

In most cases, payments are included under a general framework for financial regulations. Yet the UK has taken a unique approach in designating a new regulator to build a more competitive, innovative and inclusive payment system.

Since the group will be fully operational in April 2015, the PSR called for industry input on its regulatory approach and initial priorities. Ripple Labs commends the PSR’s transparency, thoughtfulness, and inclusion in its call for input, and is grateful for the opportunity to submit a letter.

Our recommendations reflect ongoing discussions with regulators—such as our recent correspondence with New York Department of Financial Services (NYDFS) and the BitLicense proposal—and along those lines, represent our core perspective on regulations. That is, we believe the following four points to be essential to not only the PSR’s success, but regulatory frameworks in general:

  • Ensure regulations account for the new technologies that will be necessary for creating a more competitive, innovative, and inclusive payment system. Generally, existing regulations assume the use of a centralized operator. However, new technologies such as open protocols and distributed networks may not rely on a central operator. Regulators should ensure their rules account for technology with  alternative governance models to best leverage their benefits in the payments system.
  • Enable startups and smaller companies to contribute to the payment system. We encourage a flexible regulatory framework that is inclusive of startups and smaller companies—typically the drivers of innovation. We commend both the PSR for recognizing this need in their proposals, as well as the NYDFS’ decision to include a two-year transitional operating license giving  startups and small businesses an opportunity to compete with established players.
  • Take a holistic view of risk and consider the cumulative impact of regulations. New technologies present new risks, yet many of these risks are known and can be mitigated. Ripple Labs urges regulators to also consider the risk of continued reliance on antiquated infrastructure. These risks grow over time, are often underappreciated, and may have systemic consequences. Further, regulators should take a coordinated approach when implementing new rules, being mindful of their cumulative impact.
  • Consider how new infrastructure technology can minimize payment, operational, and systemic risks while improving anti-money laundering (AML) efforts. Novel approaches to infrastructure improvements can also go a long way in optimizing compliance capabilities and mitigating structural risks. In the case of distributed networks, the shared ledger lowers the cost of compliance by providing improved funds traceability and AML oversight.

In this case, we also included an overview of how Ripple benefits regulators, government agencies, and central banks. As an innovative approach to funds transfer, Ripple is an opportunity to improve today’s payment systems and minimize or even eliminate structural inefficiencies.

Unlike existing systems, Ripple is an Internet protocol-based technology, which means it is both neutral and also has the capacity to maintain a record of balances without a central counterparty. The result is a competitive market for funds exchange and delivery.

A payment system powered by Ripple has numerous benefits:

  1. Reduces fragmentation and concentration; increases competition.
  2. Enables fund traceability and transaction visibility.
  3. Reduces systemic risk: no single point of failure.
  4. Reduces the possibility of conflicts of interest as a neutral infrastructure layer.
  5. Improves capital efficiency and liquidity management.
  6. Decreases operational and settlement risk.
  7. Enables new products and improved consumer experience.
  8. Improves information security and reduces cyber threats.

In all, Ripple Labs supports and shares the PSR’s objectives of fostering a competitive, innovative, and inclusive payments systems. Indeed, we believe the Ripple protocol embodies many of the PSR’s goals. We look forward to continuing our proactive engagement with the PSR and other regulators in the future.

For a more in-depth overview of how Ripple Labs approaches regulations, you can view the entirety of our response to PSR CP14/1 here (PDF): Ripple Labs response to PSR

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