TPT #50 UK PAYMENTS INITIATIVE

Speaker A: Welcome to the Payments Trilog where three seasoned professionals discuss payments and more for Europe and beyond.

Speaker B: Hello, my name is Michael Salmony and I'd like to welcome you to the 50th episode of the Payments Trialog no less. Uh, where Javier, Ralph and I have interesting people in and around payments. And today uh, we're happy to have Charles who's one of these clever people from the Netherlands who are always prominent in payments, but he's actually defected to the UK and he will tell us about what new uh, things are happening about payments in the uk. So over to you Charles. Maybe you can tell us a little bit about yourself and what you're working on.

Speaker C: Thank you very much for the kind introduction Michael. Ah, great to be on the podcast. Um, a big fan. Um, so yes, my name is Charles Damon. Um, I'm Chief Product officer@token IO. Token is one of the leading eight way infrastructure providers in the UK. Uh, we enable pay by bank on behalf of for payment service providers, banks, uh, and FinTechs across the UK and Europe. But I represent um, the UK payments initiative as an industry director and that's really what the topic is. Um, what uh the topic is about. We announced the UK Payments Initiative uh, in the beginning of June at Money20 20. Yes. So delighted, delighted to be here.

Speaker B: Thank you Charles. So um, can you give us a little bit of a background why there was a need to redo payments in the uk? I mean some people could say that they've already got foster payments which some people still struggling with. Uh, open banking is where the uh, the country where UK is doing best of all in the whole world. Why is there a need to do anything new in payments in the uk?

Speaker C: So yeah it's, it will be really good to take a little bit of a step back uh because um, open uh, banking is present but we took quite a different approach in the UK to the rest of Europe. Uh, open banking came from uh, the Competition Markets Authority, um, which required the incumbent banks or which required to um, uh to increase competitiveness between incumbent banks and NEO banks. Um, as a result uh, Open Banking Limited was set up um, and in 2021 the competition markets Authority um, required uh, the banks to set up so called sweeping VRPs. Um VRPs are variable recurring payments and sweeping V are me to me transactions and the purpose of that is to enable me to me transfers in particular from an incumbent bank account to go for example to your NEO bank account. Variable um, recurring payments is the technology to make that really easy. Um, why, um, the reason Is that it's consent based. So a consumer or an account holder sets up a consent uh from their bank account to move money uh either based on an uh on, on on an instruction or on a, based on a rules on a recurring basis to move money from your incumbent bank account to a NEO bank account for example. As a result all the mainstream banks, so the CMA 9 had to implement VRPS technology as part of the competition uh markets authority order so to say. So they had to implement the infrastructure sweeping VRBs now represent uh 18% of all the open banking transactions in the UK. Now in 2022 uh some of the banks realized that there is actually a commercial opportunity to use this technology um which we call so called non sweeping VRPs or commercial VRPs. The leading bank in the UK AH was the NatWest and they announced a commercial model around VRPs. Um but they were the, so they were a very innovative bank. They took a first mover step um but they were the only bank to do so. Uh so that meant that as a TPP we had agreements with, with NatWest, a number of other TPPs in the UK had an agreement with NatWest. We publicized it, we tried to sell it to merchants but merchants of course want ubiquity. They want to make sure they can address all the account holders of all the banks in the market. And unfortunately natwas was the only bank that would ah at that time enable commercial vrp have a commercial model around that and a bilateral agreement as a result. And if we look at it uh the regulators ah the regulators started to look at this and they saw that there was real potential with this technology. Um the FCA came out with the PSR at that time. FCA and PSR have merged now um through ah an initiative called the Joint Regulatory ah the jroc, the Joint Regulatory Oversight Committee with a strategy recommendation that commercial VRPs should um become a strategic priority. Um in 2024 this was in 2023. In 2024 the so called national payments vision was announced and this came from the treasury and the treasury highlighted that and made a really big statement that in the UK account to account payment should become ubiquitous both at point of sale and at E commerce. And also pointed out that open banking technology should be used as a foundation uh as the foundation of that that spun off a whole set of work uh and an entity had to be set up uh that was funded by the industry so to say. So there were 31 companies funding this initiative to create the framework uh around this. So the technology was Already there. But we had to build a commercial model. We had decided to look at what should we be doing around consumer protection for example. So um, late last year ah, basically a number of the leading banks as well as the leaning TPPs decided to become shareholders of and created so called UK Payments Initiative, um, to really make that a reality. So what happened? There are about 23 companies that now that have funded the UK payments initiative and it's very different to what has happened before with kind of payment schemes so to say because this is a commercial for profit entity. So the entities that have invested the nine largest banks in the UK as well as um, 14 of the largest DPPs are uh, shareholders, uh, have an equity stake in the company as well as voting rights which are equal. Ah there's a board, the board has uh, an MD, a chairman, a non exec director and then four industry directors, two from the TPPs and two from the ASPs. And I represent one of the TPPs, one of the DPP industry directors.

Speaker A: Could I jump in right here? Because from an open banking perspective this is almost like um, a fairy tale at least from, if I look at it from Europe's uh, perspective. I wish and dream that um, we could have gone this way in Europe as well. And of course we have tried. I guess we were even first with SPA and all of that very I think similar. But then the banks decided to well we love TPPs, we like them but maybe not enough to actually work together but instead we do our own thing. We create uh, the European Payments Initiative uh just amongst ourselves we have similar uh, activities in each country. Swish, Twist, vipps, bifm, et cetera. Whether all the banks have decided to just um, club together, stay together and um, basically have a closed job, a closed banking solution. So why is it that UK has come to a different conclusion? Why did the banks not go this way in the uk?

Speaker C: Yeah, no, great question Ralph. It's, I think there's a combination of things. One, there was significant investment in open banking. Uh the banks funded the Open Banking implementation entity or what is now obl but also Pay by Bank or open banking. Open banking payments are a real success in the uk. It's still a small proportion of overall E commerce payments but it has become really, really ah, a really visible payment method in the market. You can pay your taxes through, through Pay by Bank. You can buy goods and services on Amazon using Pay by Bank. Um, you can repay your credit card or fund your account using Pay by Bank. So um, Pay by Bank already has become uh not, not necessarily mainstream but it's certainly becoming a really growing payment method. There are about 37 million, no, but 40 million payments a month now. Um, so I think it's a combination of one, there was a good framework, there's, there's already uh, uh, that banks and TPPs are, are used to. The second element that I think was a critical piece was then the VRP technology uh, was already in place with the banks. The banks had to build it as part of that sweeping VRP compliance mandate. So the investment actually for banks now to enable so called non sweeping transactions, it's basically, it's a change of a flag and then it's all around creating the multilateral framework or the multilateral rulebook, uh, the commercial model, consumer protections, etc. Etc. So the technology investment was, was relatively limited.

Speaker B: I mean what you say is good because I, I love Ralph's question. I think that's, that's really to the point and a lot of people are asking why isn't this happening in Europe? I mean in addition to what you said there are two other reasons which, which are often cited. One is it was absolutely driven and governed in the right way. It was governed by the cma, a competition authority which uh, which really made sure that the banks got a new competitive uh, uh, uh, offer. Whereas in Europe you know the APIs were mandated but whether they actually worked or not wasn't really followed up by a lot of NCAs. So it wasn't, it had a completely different governance. So that, that is one another one this is a more controversial opinion says is Brexit is the UK was actually able to do, set its own rules and didn't have to follow the PSD2 and PSR which manifestly didn't work. What do you say to those two?

Speaker C: Um, so certainly the Competition Markets Authority or the CMA order really helped open banking and ensure that open banking was implemented in a different way. Um, there were for example user experience guidelines, uh, there was app to app redirect from the start the APIs were. And if we compare it with what we experience in Europe in certain markets, uh, the framework was very good. Um, and of course again yeah the sweeping VRP implementation really helped. I think the second element, um, in terms of Brexit, I'm not sure to what extent uh, that made a big difference and more from the perspective that it was prior to Brexit the CMA order had already been established so the UK already went its own route and we adopted of course certain aspects of PSD2, uh, when PSD2 came into effect, um, but I'm not sure to what extent, uh, to what extent that had a major effect.

Speaker B: Okay. The interesting thing is, so it wasn't a Brexit benefit. I'm still trying to find one benefit that Brexit ever gave.

Speaker C: Anything. That's a different conversation, Michael. That's. I'm also looking for that one, but that's a different conversation.

Speaker B: But on the CMA thing, I mean, uh, you've described some of the reasons. I mean, I had a really, uh. It really came home to me. I actually spoke to somebody from the CMA where I asked them that question. And uh, uh, I said, why are the banks opening up? Which is not a natural thing to do. Lots of banks say, I want to keep the data to myself. I want to protect my old world. And how did you open it up? And, uh, the CMA said, uh, well, we phone the CEO of the bank. If a TPP complains that the access is not working properly, the CEO, not some technical guy, don't send a fax. Three weeks later they phone the CEO of the bank and says, if you don't get this working, we will reconsider your license and various other things. So that really puts pressure on people to change. And that's of course nothing like that happened in Europe. Uh, could you confirm that? Is that for your experience too? Because that seems a governance, uh, uh, that is very powerful. Right. Uh, and really ensures competition.

Speaker C: I mean, I know Ralph has alluded to it very often and we see what we. I don't know to what extent CEOs in Europe are contacted or not, but we could see certainly a lot more enforcement of uh, of the rules in the eu. Ah, we see a number of markets where it's a real challenge even with providing a lot of evidence. But we, we don't often see that, that active enforcement, uh, of the standards and the rules around PSD2, ah, IBAN discrimination is also a very good example that still is ongoing, whereas we know that it's. That it's not a legal, legal practice. Um, so, So I think the other element, and this is we have been heavily involved with, with, with SPY as well, was that whereas EPI seemed to have been a CEO discussion spa, unfortunately until now so far wasn't. And we do see positive, um, movements in certain markets where dynamic recurring payments is now being looked at also as a compliment. Uh, so, uh, you recently had, uh, I think people from JIRA API on the call. It's certainly being looked at uh, in that context and I don't think it should have to be one or the other, uh, if we open up, and particularly with PSD3 now and the work also to establish recurring payment mechanisms for some of the more bank led initiatives, why wouldn't you leverage that through an API and M monetize that at the same time? Um, and a really interesting aspect is that coming together as shareholders in UK Payments Initiative has really changed the mindset between banks and TPPs. You suddenly have aligned incentives. So it actually has become a lot more collaborative instead of the antagonistic uh, approach that we have experienced sometimes in the past.

Speaker A: Uh, there's my next question actually. Sorry to jump in again, uh, but um, the governance. So you already mentioned Charo API and of course a big difference between that and SPA is that Charo API is the child, the baby of the German banks and the TPPs are invited to the party but um, with not too much to say so far. So spa is 50 50. The UK PI is what and how, how do you break the tie?

Speaker C: If needed it is 50 50. Uh, so two industry directors from TPPs to industry directors from uh, ASPs. Independent chairman. Independent, uh, or there's a chairman that is employed by UK PI and MD and then an independent non exec director. There are certain elements that are for example where industry directors don't get involved in particular price setting. So there's an independent pricing committee and then when it comes ultimately to vote and that's where the independent. So the chairman, the MD and the independent net are the decision makers at that time. So uh, both ASPs and TPPs got involved with the appointments of the MD, the non exec independent, non exec director and uh, the chairman.

Speaker D: Well, if I may, because I think this part, this collaboration and trust is probably what we are missing many, many times we always say that financial services are based on trust but then we forget about it and we think or we talk about infrastructure investment and all that. But at the end of the day it's trust and it's uh, confidence in between the different partners. And after Michael's uh, train, uh, of thoughts, I was wondering what's the relevance of national communities? Because what I see is that uh, at the national and you know, well the UK market, uh, before and after the exit, the Brexit and you know, well also the European Union market. So what's the relevance of, of national communities? What I see is at a purely uh, national community it is easier to get to certain degrees, certain levels of trust that can allow certain Initiatives or certain alignments? Well still at European Union level we have these two tier uh, uh system in which we have still national communities but then we are trying to build a European Community? I would say still we are not yet uh, barely we are in the childhood of this uh, financial community at ah European level which brings a lot of complexities because while I see that a British TPP can talk and can share many things with a British bank, it is much more difficult for a German TPP to share those uh, whatever circumstances with a Portuguese bank. And we still at European level we have not fully uh created this banking community, not to talk about uh, the wider financial community including the TPPs. So are national communities still that relevant? Do we have still to focus on national communities to create, to bring an initial trust on which to build or do we have to aim to a European level trust which still I don't see it very materially. What can we do when we have at least in Europe these two tiers uh, um system in which we have to play at two levels and many times we don't get anywhere because we are just uh, fighting those two battles in different fronts.

Speaker C: Yeah, that's, it's a really interesting question. I um, think on the one hand we have, we have an opportunity with PSD3 ah to um, to almost bring, bring Europe together in a way in which we will have and I often say this, you know it's, it's, it's kind of. We often talk about payment sovereignty in Europe but actually pay by bank in Europe uh, reaches anyone in Europe. So do we really need another payment method to do that? And to. So PSD3 will hopefully help us to harmonize this further and to address the user experience issues. Of course where we also have really evolved is now with the SEPA instance regulation that suddenly we have a better set of Rails. We now with PSD3 will have a hopefully a better set of APIs and a more harmonized user experience. Can we with standardization such as through the Berlin Group where the spy APIs are also part of that create this model where one it becomes interesting for banks to uh, whilst we're opening the bonnet so to say to make the implementation of something like dynamic recurring payments available across uh the different banks in the different markets using that symbol, that single API and leverage some of the great work that was already done by spa because the model is there uh, to just use. Uh, so I think there's an opportunity there. Um, I guess the flip side is that not, not the interest in different Markets may not always be aligned. Uh and that's I think that the challenge so to say, I mean regulators have still played an important role in the UK to make this happen. There was an awful, there was a lot of industry work and industry invested a lot of time and money and organizations such as UK Finance for example really contributed to creating um uh uh contracts that could be used by TPPs and banks to establish initial bilateral agreements or the commercial model for E Commerce transactions which is also where, where they got involved. So it has been a whole collaboration of industry and regulates but regulators still played an important role in the UK as well.

Speaker A: And could I ask. Well we already mentioned competition Authority. There is also the other aspect of um. Well if I understand correctly they said that there will not be a Competition act investigation at this stage. So you're having some time now I guess to agree and I don't know if you have already or how much you can talk about it. We had similar situation in spa. It uh took a year or so to come to a conclusion which then both sides didn't like. And um, it's also one of the obstacles there. And I uh, guess there's a different process in Germany with our API but also um, with a lot of involvement by the Competition Authority there. So where are you with that? So

Speaker C: as always Ralph, you're very well informed. Uh so um, there is indeed one of the critical pieces in the creation of UK payments initiative was uh some of the legislative work that is ongoing. The so called Data Use and Access act, uh that is uh that will soon go out for consultation that creates a, that gives the FCA a set of powers sort uh of financial conduct authority, a set of powers to uh, to overcome uh pricing issues around and the competition issues around pricing. There uh will be a mandation element for banks then to, to effectively adopt uh this uh, this scheme. So so uh there's a very clear uh legislative act ongoing to overcome the competition issues uh which will enable us to really launch the E Commerce use cases ah next year.

Speaker A: And is there um already a discussion around whether there should be ad valorem percentage fees as well or just fixed fees? Because that has been one of the biggest discussions over here.

Speaker C: Yes, so there is currently a pricing model. So so perhaps important to say a UK payments initiative went live on the 1st of June. Uh so five uh out of six major banks um are transacting and five of the major TPPs are transacting um currently the model uh so. So currently it's a fixed fee model because it Addresses five uh use case categories. Regulated financial services so you can top up your E Money account. You can pay for regulated utilities so you can pay so it's more like a direct debit substitute. So for your phone bill, your electricity, your water bill, your gas bill etc. Um you can pay for ah regulated uh it's from, to purchase rail tickets from regulated uh rail companies because there's an alternative form of consumer protection that's so called delay scheme and payments um to local governments and payments to charities. So the reason why those five categories are currently permitted is because there's no because those are all regulated and you don't require purchase protection like through for for example something uh, like, like chargebacks um in so to answer your question on ad valorem um that is currently being looked at um, uh particularly for E commerce purchases uh so you come then into the whole risk balance uh who will in case of disputes who will be covering those um where does the liability sit? Uh the, the work that was initially done by, by UK Finance looked at and recommended an ad valorem model. The advantage of an ad valorum model is that it also really increases the scope because of of course you can then suddenly start to also use uh this new scheme for your very low value recurring transactions. Your streaming music or TV subscriptions for example or your EV charging or your ride hailing services or things like that. So yes, long winded answer to say yes. Ant valorum is certainly being looked at at the moment.

Speaker A: Yeah because uh, I mean from a merchant's perspective I think the expectation I guess is not different in the UK at least uh certainly over here is that pay by bank is cheaper and will be uh, as safe or even safer than cards. So essentially you get uh more protection for the merchant side, you need less protection on the consumer side because of more security, sea etc. And the whole thing is then hopefully just transaction based that is Fixed fees et cetera. So there is this um, big expectation which hopefully will translate sooner or later into the demand pull on the merchant side and getting more, more of this and maybe less of cards and other uh traditionally bit more expensive solutions. And um, what do you expect? Um in the UK I guess you have big ambitions there and well not just replicating um all the cards and their bells and whistles is probably um, well not what you want.

Speaker C: No indeed. So yeah in order to drive adoption it is critical that commercial uh VRP um has a lower cost of processing for merchants. Commercial VRP overall drives a lot of advantages for merchants. One is a better user experience. Once you have set up your consent your one of consent through which you apply sca your subsequent transactions either customer initiated are one click without sea or you're they're merchant or they can be merchant initiated for fix or variable amounts. Um so when I was processing at a merchant I always as a merchant I was always looking at three things. You have better user experience, better acceptance so the acceptance we get through coverage and a lower cost of processing. So certainly there's a big expectation that there will be a lower cost of processing on that. On the consumer protection element it's an interesting element because it's a little bit different. The UK is a little bit different to some other European markets like Germany or France for example where you have Carbon Care or Germany uh uh in that consumers are used Debit cards are the most popular payment method. Consumers are used to being protected through uh, through chargebacks um and can raise chargebacks um now should we replicate what uh is currently in the market? Chargebacks are 50 years old, are very expensive for uh, for both banks as well as acquirers as well as merchants to process and they don't give a, they don't give a great user experience. We believe that there are opportunities to um, to do a number of things. One could, could the merchant play a bigger role in providing good refund mechanisms etc, etc. Can we therefore avoid the number of the uh, of the calls that are being made to banks to raise a charge back? Have you spoken with a merchant before? Ah, the bank should not be the first port of call. Ah when you have a dispute with a merchant it should be the merchant that has the first port of call. Um but I think the second element, I think that you can make some real improvements to take costs out of the system. Um an example I often use is um uh MasterCard did a study and highlighted that 30% of chargebanks uh that are based with the issuer come from people that do not recognize the transaction uh because they can't recognize the good or service that they bought or they can't recognize the name of the merchant because it was a legal entity instead of the merchant name. 30% of chargebacks. So by having longer descriptors which is supported in the open banking standards where you can have much longer descriptors that you can see within your mobile banking app or your bank statement you can avoid up to 30% of those charge because consumer can just see what they have bought and therefore they don't have to call uh their bank. So we believe That a number of improvements that we can make and really take also disputes into the digital age so to say uh, uh, and make it much more uh adapted to um this new payment method.

Speaker D: Charles Typically the UK market works as a leading indicator to the rest of Europe in many cases at least. So what do you expect or what are you aiming to in 5, 10 years so that we can expect what or we can learn what will happen in the continent in 10 to 15 years.

Speaker C: Wow, uh, that's, that's if I had a glass bowl uh, I hope I, I don't believe that uh so, so I truly hope that in 10 to 15 years um, we will have um uh that every person in Europe will be able to leverage the open banking rails to make a payment but also to make sure that there is something in it for uh, for all parties in the, in the system. So uh, there should be an incentive for banks to invest more to provide a better user experience. I think PSD3 provides a really good driver for banks at least to as gijs would say open up the bonnet so to say uh ah to build better APIs, to build better user experience and let's leverage this to build some of uh those premium services that we identified in spa and I think given the interest that we have seen from major, major merchants, uh dynamic recurring payments is really um a feature that a lot of given the flexibility that it provides uh the use cases that it can cover um a real opportunity um uh for pay by bank uh or whatever we may call it in future um to make a real uh impact and have multiple ways to address the sovereignty question. Uh in Europe uh we believe that there are multiple ways to skin the cat so to say.

Speaker A: I have one more question on the uh well actually going back uh you alluded to it already because um. Well you know one of the objectives we have with this podcast here is to show that we'll actually need less regulation rather than more that there is more common ground between the stakeholders and in particular also between fintechs and banks which are too often seen just really on opposite sides of the table and um, so driving collaboration, driving a dialogue or a trialogue. Uh this is what we're trying to achieve here and that seems as if you've now achieved in the UK with this UK payments initiative. But um, let me just put my finger into that one thing on um, uh whether you believe it would have happened without a regulatory push. So without the Damocles sword there ah over the banks that something worse may happen unless they now start to play ball.

Speaker C: I think it would have been difficult. The national payments vision really was a shot in the arm so to say. So a really positive development because it really demonstrated that the government really wanted to make, make a counter campaign. It's ubiquitous was a very strong statement. Um the regulatory intervention definitely helped. Uh there wasn't, there was a strong push um so it made it, it made it more front and center. And that came back to a little bit to your point Michael. It, it was not. It, it became on a higher, it came on a higher level. CEOs were involved in that conversation say well no actually this is a really important, this is a really important element that we need to support throughout the organization.

Speaker B: So what I really like is also that it wasn't only sort of mandated and enforced and sort of there was also trying to see common ground and how to align the incentives of the Fintech uh and the banks and there's a lot of. I think that's always the more successful model. Right. I mean mandating and forcing that, that sort of. We've seen plenty of examples where that doesn't, doesn't work too well. Right. It's so much better if everybody sees uh their own advantage. And I get the impression you've really done that.

Speaker C: Yes and this is why I think the setup of having a company limited by shares uh where effectively there's. Because the funding was actually not is proportionate in that banks fund more but get more equity but with equal voting rights. So and that really helped to have both still an equilibrium between TPPs and FinTechs whilst the investment uh once the investment structure could also give uh the returns if and when they, they will be there in uh, uh after the initial, after the initial investment. And the way the funding was structured is for a period of six years. Uh so this means that the scheme could run based uh on the volume projections for about six years without incremental funding. Um so that was also an important piece uh because as we know with every new scheme there's a, there's a build up uh there is a period that we need to implement that we need to get PSPs on board, merchants on board, drive volumes etc.

Speaker B: Right.

Speaker A: I have one. Before you call in I see Michael already suggesting that we run out of time but I have one more question and sorry it is um, um of course so I already said looking at you and what happens there with envy from a European perspective and of course we hope that it'll sort of give some um traction here in A similar direction in Europe. But uh, I'm also a little bit concerned about that uh, you know, in Europe. So we have these, um, there's only the bank solutions, the closed banking solutions, which are seen to be the savior of European uh, sovereignty and they are now joining. Somehow you have these roaming agreements between the different solutions. Different, different countries. Would you. Could you be tempted to join them as the UK leg in the closed banking um, network there?

Speaker C: Oh, uh, that's not my decision. Let me flip it around. I think to still. I think for. If we take the lens from a merchant, for merchants, it's actually really difficult to. And of course the parties have. That can help but to integrate to all these different solutions. This is where I think open banking and pay by bank has so much more of an advantage. Uh, because through a single API you reach all the EU member states, all the account holders. That is payment sovereignty. So with instant payments now being Universal, with uh, PSD3 addressing the user experience, I um, think there's a major opportunity for payback to emerge as that real alternative. So uh, I'd like to focus more on making that, uh, enabling that um, and then we'll see if there is a need for UK payments initiative to join any of the domestic schemes.

Speaker A: But that's certainly not a decision and I love that. Highlighting again that, that it's the really open bank, your paper bank is the only one to reach everyone in Europe and in the uk. Anyway.

Speaker B: Sorry, yeah, ah, no, no, I think uh, but unless anybody else has any urgent topics they want to address, I would gradually say time gentlemen please. As it used to be said at the pubs before they closed. Um, but I've been super impressed. I mean this is uh, we'll definitely be following this what happens in the next six years. So on the fifth 500th episode of the TPT, we will ask you back to see where things have ended up. I personally must be impressed at the breadth of this uh, this topic because I'd initially always been a bit concerned. It's also focused on vrp. It's the only one model that the UK is looking at, whereas Berlin Group has a hundred different APIs and scenarios and use cases. And that has changed when I hear you now you're looking at uh, card on file replacement, direct debit replacement, B2B, paying taxes, charging your EV, paying at Amazon. This is becoming a really broad instrument. Right? It's not. Uh. So, um, all power to you, Charles. We uh, all wish you well. I think it's for the benefit of the banks, the fintechs, the consumers, the government sovereignty, everybody. So, um, really wish you well. So thanks very much Javier and Ralph and everybody listening. I hope you enjoyed it and uh, look forward to seeing you next time.

Speaker C: Thank you very much.

Speaker D: Thank you.

Speaker A: Thank you.

Speaker C: Bye bye.

Speaker B: Many thanks for watching and listening.

Speaker C: We hope you enjoyed this episode.

Speaker B: Looking forward to seeing you again next time.