Prepaid Payment Instruments

A Discussion on
Draft Guidelines by RBI

Salient features

Eligibility

Banking & non-banking entities, current or planned are covered

Only banks, which have Mobile Banking approval are permitted to launch
mobile based prepaid instruments

Non Banks would be permitted to issue only closed system prepaid payment
instruments & semi-closed system prepaid payment instruments

Closed Instruments out of purview of guidelines

Safeguards against money laundering KYC/AML/CFT provisions

Uses of prepaid instruments for cross border transactions are not permitted.

The maximum value of any prepaid payment instrument shall not exceed Rs
50,000/-.

Semi-Closed System Payment Instruments up to Rs 1000/- may be issued

without any KYC subject to reporting Issuer to ensure that, more than one
card is issued to the same person.

Semi-closed Prepaid payment instruments which permit only payment of

utility bills/ essential services up to a limit of Rs 10,000/- can be issued
without any KYC being undertaken by the issuer.

Salient features

Escrow for Non Banks with a scheduled bank

Qtly certificate from the auditors shall be submitted certifying the same

Annual certificate, as above, coinciding with the accounting year of the entity to the RBI.

Records regarding daily position of the value of instruments outstanding vis--vis

balances maintained in the escrow made available for the scrutiny to the RBI or the bank
with the Escrow account on demand

Issuance & reloading :

All entities issuing prepaid instruments are allowed to issue reloadable & non- reloadable
instruments.

Reloading of closed system payment instruments would be permitted at the retail agents
& issuers outlets against cash/ debit cards/ credit card.

Banks & NBFCs can issue & reload at branches against payment by cash/ debit to bank
account or credit card.

Banks are permitted to issue & reload through BCs

Validity

Minimum 6 months validity from date of issue.

Transferring outstanding balances to a new instrument depends on Issuer

The outstanding balances not to be terminated immediately at expiration

The value may be depleted at the rate of 10 percent of the outstanding value per month.

Holders should be adequately cautioned in advance regarding the expiry date

Definitions

Redemption
Redemption up to full outstanding value at any participating merchant up
to expiry date
Redemption in cash only for open system instruments
Anyone can redeem the outstanding balance in cash within the expiry
date, if the scheme (issuer) is being wound-up or directed by the Reserve
Bank to be discontinued.
Where redemption is provided, the redemption value shall not be in
excess of the amount outstanding or the face value (loading limit) for the
instrument, whichever is lower.

Fraud Prevention, Security Standards & Customer Protection

Issuers shall put in place adequate information & data security
infrastructure, & systems for prevention & detection of frauds
Disclosure of important information to the customer preferably in local
language including:

Customer service telephone number & website URL.

Expiry period & all other terms & conditions
Customer service telephone number & website URL.

Definitions

Closed System Payment Instruments:

Shoppers Stop Gift Vouchers
Exempt from the purview of draft guidelines

Semi-Closed System Payment Instruments:

Redeemable at a group of clearly identified merchants/ establishments

Specific contract with the issuer to accept the payment instrument
No limit on the number of such merchants
No cash withdrawal or redemption in cash allowed

Semi-open System Payment Instruments:

Can be used for purchase of goods & services at any card accepting merchant
locations (Point of sale terminals)
No additional specific contract required between issuer & merchant
No cash withdrawal or redemption in cash allowed

Mobile Prepaid Instruments:

Prepaid talk time issued by mobile service providers
Can also be used for purchase of 'value added services
Cannot be used to pruchase goods or pay for other non VAS services

At a Glance

Discussion Points
If Bank & non-Bank service provider wish to work together,
then the suggested process is
Bank takes a Board approval
Confirms that the entity has fulfilled all requirements
Writes to DPSS for a case by case approval

NOF waived where stipulated ESCROW is maintained

Software & intangible assets (such as IPR, Brand value etc.) are a
major part of the Net Worth of the Service providers in this field &
deduction of the same while calculating NOF , will means a
reduced NOF & maybe ve in some cases

Right over Escrow Account balance

Acquirer will have first right
Holder will have next right
Issuer will have last right

Discussion Points
Instruments issued without any KYC
Currently permit only payment of utility bills & essential services
Need to be more broad based including merchants from organised
sectors like Movie halls / Hospitals / Hotel chains / Retail chains

Similar merchants to be included in Semi Closed

Increase in limits for cases wherein Card is issued with
limited KYC Current limits are Rs. 5,000
Confirmation on Limits
We assume they are on a per Card per day basis
If not, we need clarity on what the basis is
E.g. Semi-closed for utility payments is limited to Rs. 10,000

Expiry
Should be terminated immediately after expiry date
Refund/ transfer to new instrument depends on Issuer
Market forces will not allow unequal competition

Discussion Points
KYC Requirements
Semi Closed system up to Rs. 1,000 issued without KYC
customer may take multiple such Cards & mis-use the system
Views on how this can be controlled in a fool proof manner

Where KYC is to be collected, what is the expected process to

collect & maintain the same
KYC for Non cash Reload
Reload at an ATM
Reload on internet/ mobile banking
Relaod at branch

For cases wherein Cards can be issued by accepting any

Government issued Identity Card as ID proof, if the purchase /
recharge is happening only through any option mentioned above
the same card should to be acceptable ID proof

Discussion Points

Which NBFCs that can issue such instruments

Any NBFC accepting deposits
Any NBFC not accepting deposits
RNBC with Escrow and the necessary NOF ?

DSAs to be used by banks for sourcing applications for prepaid

instruments similar to credit cards

Thank You