Senior civil servant  regulator in Manoa working at the Manoan Financial Commission (MFC)

Situation:

Visa is coming to you with a business-to-business (B2B) payment network connection product, designed to make B2B payments simpler. While you want to help businesses by cutting red tape and processes in Manoa (that is your job), you are also very cautious about introducing new products to the market, especially if they are either new/untested or of questionable value to businesses in the country.

You want to see this product is being adopted globally first before you allow that into Manoa. You are a career bureaucrat who enjoys stability and hve a long tenure at the regulator. Your career aspiration is to rise through the ranks within the regulator. Therefore, you don’t have much experience in the private sector and don’t appreciate the faster pace of the commercial world. Even though you have plans to support more fintech innovations in Manoa, the organization-wide mindset is still that of a regulatory supervisor. GDP growth in Manoa has outpaced nearby countries despite the pandemic, and you feel that the regulator’s conservative approach has been the bedrock on which that is built. 

You would like to know: what markets have approved this, what is the uptake (transaction volume, number of banks, and the names of the banks themselves), and how Visa handles the settlement flows, and so on. 

You understand in some markets entities like Visa just give an overall brief to the regulators. But you feel you need to really understand the experience of other banks/regulators and what impact has been. Better to be more risk-averse now, than get in trouble later. You feel other regulators can be a bit loose and fast to approve things they do not understand.  

You need to be reassured that these products do not bring new risks, and also is compliant with all the existing regulations. If anything goes wrong with any new product approved under your watch, it could be widely reported in Manoa’s sensational media (as has happened in the past), and would be a career killer. Therefore, you naturally take it slowly, want to see a product proven elsewhere before allowing it into Manoa, and will follow the rulebook of gathering extensive info (e.g. gathering approval credentials from other regulators, global uptake statistics, the product’s technology, security, governance & rules, AML requirements) – as these procedures worked well in the past, even though they could be outdated in this age of fast-paced innovation.

Ideally, by direct request of the MFC Head Chair, you’d like Visa to put you in contact with some regulators and banks in other markets so that you can discuss with them their views on the product and how the roll-out is going. Your boss's boss needs to see real commitment and efforts from Visa at addressing your concerns.