include a restriction on the size, number and type MSBs who had worked with banks for (e.g. international) of payments that can be offered decades received letters to notify them of the to end customers, whether these payments are executed by the bank itself, or on behalf of clients closure of their banking facilities. using the bank’s services. In addition, many banks chose to rule out the provision of financial services providers, who have the flexibility and means to to entire industries, rather than taking a prudent dedicate time to analysing specific industry risks, (yet admittedly laborious) risk-based approach, as require the control to be able to make these risk- advised by the regulators. based decisions for themselves. Money Service Businesses (MSBs) – non-bank 4. The Cost Issue: institutions that transmit or convert money – suffered in particular with this approach. In some As the number of clearing banks offering access to instances, MSBs who had worked with banks for payments services is limited, alternative payments decades received letters to notify them of the providers are forced to pay a mark-up price to closure of their banking facilities. This denied them operate through a high street bank – which is access not only to credit, but to basic services in many cases up to 600%. Direct access would such as bank accounts. This blanket decision to not necessarily solve this issue, as many FinTech eliminate certain industry sectors from participation players do not have the scale to support the fixed has also resulted in clearing banks preventing their cost that technology platforms require. But with a own partners from servicing those same industries, greater number of credible banks and hopefully even if the partner is regulated in its own right. some larger electronic money issuers (EMIs) accessing the scheme, a more competitive market With widespread business operations and therefore would drive down existing pricing, enabling those compliance considerations, it is understandable procuring these services to pass savings onto that high street banks want to avoid additional customers and continue their mission of creating a regulatory hurdles. This is why smaller, more tailored fairer financial landscape. Payment infrastructure: a call for fair and equal access for FinTech | 5