There has been a growing demand to allow non-bank entities to be part of the Domestic Money Transfer mechanism.
The most quoted alternate is MPesa pioneered in Kenya.
The focus of RBI, is on KYC/AML norms. Any domestic money transfer mechanism, should be KYC/AML compliant. This might seem to be a bit harsh, and the proponents of alternate money transfer mechanisms, see this as the stumbling block in financial inclusion.
However, in the long run, compliance to KYC/AML norms will safeguard the Banks, customers and other participants.
There have numerous representatives to RBI, to open up the formal banking channel to facilitate fund transfers of small value, subject to monthly ceilings and monitoring, to give impetus to the process of financial inclusion.
In this regard, RBI today issued notifications on Domestic Money Transfer - Relaxations vide notification no RBI/2011-12/213 DPSS.PD.CO.No. 62/02.27.019/2011-2012 dt,October 5, 2011.
The notification can be viewed @
The relaxations will not give impetus to the money transfer facilities in the country, but also ensure that the financial transfers happen in a safe, secure and efficient manner across the length and breadth of the country.
Broadly, the relaxations fall under the following three categories:
01) Liberalising the cash pay-out arrangements for amounts being transferred out of bank accounts to beneficiaries not having a bank account and enhancing the transaction cap from the existing limit of Rs. 5,000 to Rs. 10,000 subject to an overall monthly cap of Rs. 25,000 per beneficiary.
02) Enabling walk in customers not having bank account (for instance migrant workers) to transfer funds to bank accounts ( of say family members or others) subject to a transaction limit of Rs. 5,000 and a monthly cap of Rs. 25,000 per remitter.
03) Enabling transfer of funds among domestic debit/credit/pre-paid cards subject to the same transaction/monthly cap as at (b) above.
The operational instructions are in a separate Annex.
Banks/ non-banks may adhere to the following while enabling the domestic fund transfers enumerated above.
a) A robust risk and fraud management system in place which will include reporting of suspicious transactions to the appropriate authorities.
b) Such fund transfers are expected to be effected on a real/near real time basis.
c) The total outstanding amount on a prepaid payment instrument shall not at any point of time exceed the limits prescribed in the extant guidelines on the RBI on the policy guidelines for issuance and operation of prepaid payment instruments.
d) Inter-bank settlement of funds shall be effected using RBI approved payment systems only.
e) On charges, the same should be reasonable, i.e a balance between the cost of the scheme and the charge paying capacity of the target audience.
f) Banks/non-banks may put in place appropriate systems for redressal of customer grievances.
g) The customer grievances under the Domestic Money Transfer Scheme will also be part of the Reserve Bank of India’s Banking Ombudsman Scheme.
The key aspect of the relaxations is the monthly cap restriction.
The participants under the Domestic Money Transfer Scheme, have to devise ways to ensure that the transactions do not breach the monthly cap norm.
Cash-Out - Monthly cap - Rs25,000/- per beneficiary.
Cash-In - Monthly cap - Rs25,000/- per remitter.
In my view, the Rs25,000/- cap per beneficiary or per remitter monitoring has to be done not Payment System Provider wise, but the complete industry wise.
Eg: Cash- Out Monthly cap - Rs25,000/- per beneficiary.
Can Beneficiary A receive money from 10 remitter’s in excess of Rs25,000/- in a month. If the limit is breached, what will be the monitoring mechanism?
The key question, is what will be unique identifier to ensure that the cap on the remitter is not breached.
Here, the UIDAI/Aadhar number can fill in the gap.
The process flow :
a) The transaction is originated with the UIDAI/Aadhar number
b) The UIDAI/Aadhar number is verified at the UIDAI server and the transaction tagged to the UIDAI/Aadhar number.
c) Subsequent transactions are tagged to the respective UIDAI/Aadhar number, and in case the monetary limit is breached, the transaction can be denied.
Benefits:
01) UIDAI/Aadhar number is expected to be issued to majority of our countrymen and is also expected to be the game changer for financial inclusion.
02) The start can be made now. Yes, initial investments will be required at all levels. This will be one-time investments and the infrastructure can be utilised for other purposes.
03) Tagging of financial transactions to UIDAI/Aadhar number, will reduce the investments in risk management of individual Payment System Providers. Each Payment System Provider, need not develop individual tools, but utilise the UIDAI/Aadhar number tool.
04) Risk Management can be automated, and manual intervention will be required only for exceptional cases.
