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ITU-T Focus Group Digital Financial Services
                                              Technology, Innovation and Competition



               By partnering with another MNO, it allows the bank to access and use USSD, SMS or STK or any other facility
               offered at a far lower cost than the MNO the bank may primarily be competing with in their DFS product
               portfolios.
                        245
               17.2  Country examples

               Colombia

               Bank BanColombia entered the telecommunications market by acquiring a majority share of MVNO Uff!.

               Kenya
               As noted above, licensed Kenyan MVNO Equitel  – the telecommunications arm of Equity Bank – uses its
                                                        246
               thin SIM technology to bypass market leading MNO Safaricom, using instead cheaper bearer services from
               Safaricom competitor Airtel.  Equity Bank has also begun to loan Equitel subscribers money to buy dual SIM
                                       247
               smartphones.  Safaricom reportedly lowered many of its transaction fees in response to the emergence of
                           248
               Equitel.  As of mid-2016. Equitel had over 2m million subscribers. 250
                     249
               South Africa
               First National Bank, one of the largest retail banks in South Africa, in 2015 launched its own MVNO using its
               own SIM and billing systems.
                                       251




               18     New payment rails and interfaces


               18.1  Overview

               As noted above, access to payments infrastructure is often unavailable to entities, or if it is, is not at FRAND
               terms. While bank-based models of DFS have faced most favorable conditions in integrating with payments
               infrastructure, situations may arise where a non-bank incumbent has such large market penetration, that
               the accessing of their large customer base by banks and other non-bank PSPs, or at FRAND terms without
               regulatory intervention, is challenging. There could also be challenges in accessing card networks or due to
               the excessive costs relative to the amounts transacted in relation to card networks.

               In all cases, developing enabling payment switches using existing technologies and standards, or introducing
               new alternative, technologies such as Distributed Ledger Technology (DLT) are seen as solutions for both actual
               access and for lower access fees. These are shown in the country examples below.

               DLT  in particular is a new type of secure database or ledger that is shared across multiple sites, countries or
                  252
               institutions with no centralized controller. In essence, this is a new way of keeping track of who owns a financial,
               physical or an electronic asset. A primary incarnation is blockchain technology. All blockchains operate by


               245   Of course, besides boosting its DFS business through increased usage through cheaper access channels, the bank may even profit
                  from provision of telecommunication services to its customers and other looking for a cheaper telecommunications alternative.
                  It also allows the bank to participate on relatively equal terms with its MNO rivals by being able to incentivize customer DFS use
                  through giving away free minutes and SMSs when their customer transacts.
               246   The holding company is called Finserve Africa.
               247   In the case of Equitel in Kenya, use of the shortcode *247# will divert the session to use the Airtel network. See Equitel (2016)
                  Get Activated, available at http:// www. equitel. com/ my- phone/ get- activated.
               248   The Star (2016) Equity Bank To Loan Equitel Subscribers Money To Buy Dual SIM Smartphones, available at https:// goo. gl/ S8nzt8
               249   Mazer & Rowan (2016) ibid
               250   The Star (2016) ibid
               251   It also sells mobile hardware on credit and at discounted prices.
               252   For further information on DLTs, see Perlman, L (2016) Aspects of The Legal and Regulatory Issues In Blockchain Technology; and
                  ITU Focus Group Digital Financial Services Technical Report: Distributed Ledger Technologies and Financial Inclusion (2017)



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