1. Regulatory Frameworks
Group C

2. Capital Requirements Country specific
Based on the cost of doing mobile money business
Central bank should consider balance of factors in determining capital requirements, responsible for using data to anticipate risks
Capital requirement should NOT include banks issuing e-money

3. Designing Credit Frameworks without causing financial fragility
Non-bank e-money issuers should not be allowed to provide credit on their own account
However, they can do this in partnership with regulated financial institutions
Must be underwritten by the regulated financial institution
Risk mitigation factors in the form of collateral and credit limits should be adhered to
Customer protection should also be catered for

4. When should regulations be introduced relative to capacity?
At start, there should be some recognition of regulatory oversight proportionate to regulators’ understanding of the product and its capacity
The process should be consultative and evolving

5. How do we balance the cost of these requirements with risk minimisation?
Principle of proportionality should underlie these considerations
Objective of financial inclusion
Continuous engagement
Market surveillance
Learning from other countries

6. What are the necessary features?
Eligibility
Internal Controls and Audit Trails
Customer protection
Accounting system
Technology requirements
Capital requirements
Permissible transactions
Transaction limits / KYC
Management of float account

7. What are the common sticking points?
Clarification of roles between stakeholders
Central Bank as the primary regulator
MOU between central bank and telecom regulator
Interest payments
Transaction limits / KYC
Identification issue (cards and registration)