You: Help!! Help!! I see a wolf in the distance!!
Mediator: I am here to help. What is your name and what is your location?
You: No that’s private information I am not comfortable disclosing!
You: Help! Help!! A wolf is chasing me!!
Mediator: I wish to help. What is your name and what is your location?
You: No that’s private information I will not share that information!
You: Help! HELP! I can’t leave my house I can’t operate my business! I won’t be able to maintain my home, or feed my family! The wolf is prowling outside my home, outside my business!
Help!! HELP CAN ANYONE HEAR ME??
Over the last several months I have shared countless news articles on the De-risking and De-Marketing practices global Banks are conducting to a very specific market industry; MSB’s, MTO’s, E-Money, Remittance Businesses, Online Payment Processors and Third Party Payment Processors. Businesses are being crippled, some have thrown in the towel, given up the fight and closed shop. Not only have they lost their livelihood but the numbers are significant enough that it has been foreseen to negatively impact the global economy. Some have chosen to continue to fight but find not so “compliant” means to keep their businesses running. And while from a staunch compliance position the option of creativity is frowned upon, the de-risking and de-marketing banking practices are feeding this creativity. This is creating an environment of pushing businesses to utilise “underground” or “covert “practices in order to process the volume of transactional money flow. The money flow is the most important aspect of these businesses, for it is the money supply and demand business model that keeps their businesses afloat, provides the needed service and becomes a important factor in our global economic growth.
Here in Canada, the Money Service Business industry, including all those that fall under this industry sector, formed an association; The Canadian MSB Association. The mandate of the Canadian MSB Association, is to bring about structure, compliance adherence, provide training and information conferences. In turn the hope is it will change the opinions of the industry’s banking partners and regulators. The association wants them to know that their concerns are being taken seriously and the industry is prepared to hold itself accountable to doing business within a regulatory frame-work.
Globally there are many other association like ours here in Canada. When the news of banks taking steps to de-risk and de-market our fellow colleagues internationally, the Canadian MSB Association along with our fellow colleagues and our fellow associations took action., As there is strength in numbers we joined forces. We opened discussions, we sent letters and our voice was heard in front of the Deputy Minister of Finance here in Canada. Eventually the World Bank got wind of the issue and the call to action began.
Do each and every one of you who are either directly or indirectly affected by this global de-risking and de-marketing issue understand what we collectively were able to do? Let me repeat! We joined forces with our fellow colleagues, our fellow industry associations, we opened discussions, we sent letters and we had our voices heard and then….. and THEN…. The WORLD BANK took note!
Let that fact sink in for a moment and appreciate the value statement this makes. When a united force comes together to bring about change, change can happen but the unification of our industry was only half of the required action needed to bring about change. The battle was only half won. This collective action we took cannot stand still. The World Bank took note, and then they took action. They created a Survey and asked us to respond to the Survey in order to assist them in bringing the proof required of our experiences, of the unfair de-risking and de-marketing practices the global banks are taking.
In some ways the World Bank can be considered a mediator. They bring to the global banking and finance decision makers the world’s economic concerns. They hold regular annual meetings where they discuss and make decisions on global concerns, including the world economic outlook, poverty eradication, economic development and aid effectiveness. The mandate of the World Bank is to end extreme poverty by decreasing the percentage of people living on less than $1.25 a day to no more than 3%. Additionally, they promote shared prosperity by fostering the income growth of the bottom 40% for every country.
These underprivileged individuals along with third world countries and under-banked countries rely on the global presence of Money Service Businesses, Remittance Services, E-Money, Money Transmitters and Third Party Payment Providers as a means to receive money from family and to buy goods and services they otherwise would not have access to. This industry fulfills a cost efficient need that the big banks simply cannot fulfill.
Finally our voices were heard. We are fighting for our right to exist along side the big global banks, our right to a livelihood, to provide services to those countries and individuals in need and we are part of the cause and effect solution.
The World Bank took us seriously. They launched a survey in order to collect the needed data to provide to World Government Officials, decision makers of the global financial ecosystem. The data is needed to provide accurate statistical information so a complete picture can be seen. Only once the data is collected, reviewed and analyzed can the confirmation of our struggles, the unfair treatment and the misunderstood business practices be confirmed.
The World Bank reached out to those of us they saw as activists for the industry or those individuals that were directly or indirectly involved in changing the perception of the industry. The World Bank was looking for our assistance in communicating the Survey to the Industry. Collectively many of us used whatever means we could to communicate to all of you, the news of the Survey and how to access the Survey. Using email blasts, discussion groups, training webinars, committee conference calls, tweets and throughout most social media networks, we worked to spread the word of the World Bank Survey to industry counterparts, colleagues and fellow associations.
However the feedback from the World Bank is that the response from the industry was pitiful. Too few industry members responded and the data is incomplete. The common whisperings heard as to why members of this industry did not respond to the survey? It is believed that it is our position on not wanting to share information, our wanting to remain anonymous, and our lack of trust of the process.
In hearing this feedback from the World Bank it made me think of the boy who called Wolf.
Have we as an industry cried Wolf? Did we bring the decision makers and law-makers to our doorstep ready to listen, ready to show a willingness to work with our Industry and understand our business only to not follow through with the needed information that a “wolf” actually exists? By responding to the survey it would provide us the opportunity to show them the steps we have taken collectively as an industry, to unite and create a culture of compliance with the objective to not only blindly follow the rules but to safeguard our financial banking systems. This kind of opportunity does not come around often to an industry in need. We missed their first attempt to help us by collecting the information needed when requested. This kind of opportunity does not come around a second time so as the fable of the boy who cried wolf goes; what are the chances that we will be provided a second let alone third opportunity to be heard and to bring about change. We have our second opportunity to be heard as they have extended the deadline for the collection of this information. In the fable of the boy that cried wolf, help is attempted twice before his cries are no longer answered. Let’s use this opportunity or stop-crying wolf!
The de-risking and de-marketing issues are real. They are happening. You know it, I know it and all of us in this industry know it. It is unfortunate that the bureaucratic way to change is to have to prove ones case. Nothing can ever be hearsay. We must prove our case not just give lip service. Lip service is easy and holds little accountability and responsibility. Taking action means seeing the process through to the end and being accountable, and being responsible. The game changers are ready to be engaged. Having your voice heard is an incredible accomplishment – and a shame to let it be wasted and more so for all of us who desperately need change to happen. I am hopeful that it is not too late; the survey is still available online at : https://remittanceprices.worldbank.org/en/survey-on-de-risking
Please lets not simply cry wolf and take no further action. This initiative is a collective one and we need each and every one of you to act. The next step is to provide the information needed to guide those that can help us, to what needs to happen next for this industry to move forward!