Duvvuri Subbarao: Indian payment and settlement systems responsible
innovation and regulation
Keynote address by Dr Duvvuri Subbarao, Governor of the Reserve Bank of India, at the
IDRBT (Institute for Development and Research in Banking Technology) Banking
Technology Awards Function, Hyderabad, 3 August 2012.
* * *
1. First of all, my thanks to the management of IDRBT for inviting me to this eighth
edition of the IDRBT Banking Technology Awards function.
Financial innovation in the context of the crisis
2. We are gathered here today to recognise and celebrate financial innovation. If we
take a long sweep of history, there is no doubt that innovation has contributed to enhancing
the quantum, quality and reach of financial intermediation. In recent years though, financial
innovation has become a contentious issue. Unbridled financial innovation and the failure of
regulators to check that are also being cited as among the culprits for the global financial
crisis.
3. Quite understandably, the crisis has triggered a number of questions about financial
innovation. Is all financial innovation for the good? Are there good and bad innovations?
What determines if an innovation is good or bad - the innovation itself or the way it is used?
Who is to determine if an innovation is good or bad? Do regulators have the wisdom and
competence to regulate without stifling value adding innovation?
4. These questions are subject matter of a vigorous debate among financial markets
and financial sector regulators. Even as this is largely work in progress, the objective of all
this effort is clear - to make both innovators and regulators more responsible.
5. Is this talk about responsibility just a homily? I believe it is more than that. Let me
explain. Innovations, we know, are not driven by altruism; they are motivated by private
profit. If there is no private profit, there will be no innovation. In theory, as Adam Smith had
propounded over two centuries ago, this is no bad thing. Individual pursuit of profit, driven by
selfishness, can indeed lead to collectively optimal outcomes. The important condition for this
to happen though is that markets must be competitive and efficient. But markets fail, and
financial markets fail more notoriously than other markets for a variety of reasons -
information asymmetry, moral hazard, adverse selection, externalities etc.
6. Possibly the only way to mitigate the risks of market failure in respect of financial
innovation is regulation. And herein comes responsibility. Innovators must be responsible for
the way they use their innovations. Regulators must be responsible for ensuring that financial
stability and consumer interest are not compromised by the innovations. This sort of
responsibility demands competence, foresight and wisdom on both sides.
Payment and settlement systems
7. Responsible innovation and regulation is the topic I want to address today.
"Responsibility" should be the thrust of innovation in all segments of financial markets and
responsibility should be the credo governing regulation across all dimensions of financial
regulation. Today, though, I will focus on a narrower segment - responsible innovation and
regulation in payment and settlement systems.
8. This choice of payment and settlement systems is informed by three motivations.
First, payment and settlement systems have witnessed by far the most game changing
innovations, especially in the matter of furthering financial inclusion. Second, innovations in
payment and settlement systems have been both market based and technology based, and
illustrate how technology based innovations can be mainstreamed. Mainstreaming
technology based innovation is particularly relevant at this platform because that is the
mandate of IDRBT.
9. Third, and most remarkably, during the depth of the financial crisis in 2008/09, when
virtually all financial systems and all financial markets went into near collapse, the payment
and settlement systems worldwide remained stable. What would have happened if the
payment and settlement systems too had seized up? Even to imagine that is frightening.
RBI as a responsible regulator
10. The Reserve Bank is deeply conscious of being a responsible regulator. We
interpret this responsibility as follows. We must encourage financial innovation but only such
innovation that improves the efficiency of financial intermediation and therefore contributes to
the real sector. We must ensure that as innovations are rolled out into actual financial
transactions, they do not erode financial stability. We must be especially sensitive to
consumer protection. And uniquely, because of our developmental role, we must ensure that
financial innovation furthers financial inclusion.
11. Responsible regulation here means providing a stable, predictable and contestable
regulatory framework that encourages innovation, emphasizes safety, security, efficiency and
accessibility, and aids the orderly growth of the payment and settlement systems. As you are
aware, the Payment and Settlement System (PSS) Act, 2007 designates the Reserve Bank
as the statutory regulator of the payment and settlement systems in the country. But even
before becoming the statutory regulator, the Reserve Bank has been engaged in
modernizing the payment and settlement systems; and even as we are the statutory
regulator today, we continue to take the lead in facilitating innovation.
12. Having set that context, I now want to address three specific sub-topics in the area
of payment and settlement systems:
i. RBI's role in modernizing payment systems
ii. RBI's approach to responsible regulation
iii. RBI's role as facilitator of innovation
RBIs role in modernising payment systems
13. So, let me turn to the first sub-topic - the role played by the Reserve Bank in the
modernization of the payment and settlement infrastructure of the country.
Paper based clearing
14. The Reserve Bank kickstarted the modernisation of the paper based system in the
mid-80s with the introduction of MICR technology in the four metros. Today MICR technology
is used at 66 centres across the country. Besides, more than 1100 smaller centres have
been brought under a uniform computerised clearing package - the "Express Cheque
Clearing System" - to enable the required level of interoperability across all the clearing
houses. Leveraging on the core-banking infrastructure of banks, we introduced "Speed
Clearing" in 2008 to facilitate collection of outstation cheques on a local basis.
15. Another major initiative has been the Cheque Truncation System (CTS) which was
operationalised in the National Capital Region of Delhi in 2008. CTS, as many of you know,
is an image based cheque clearing system obviating the need for physical movement of
cheques. A further technological improvement of the regular CTS environment is the grid
based CTS. The grid based CTS encompasses multiple clearing locations spread across
several states facilitating the processing and clearing of cheques of all the banks under that
particular grid. The National Payments Corporation of India (NPCI), the umbrella retail
payments organization set up by banks, has since operationalized a grid based CTS in
Chennai in 2011.
Electronic payment systems
16. Even as it was modernizing paper based transactions, the Reserve Bank was also
simultaneously working on retail electronic payment systems such as Electronic Clearing
Service (ECS) for bulk payment transactions (credit as well as debit) and an Electronic
Funds Transfer (EFT) system. The localised ECS has today metamorphosed into an ECS
suite of products: (i) a localised ECS catering to the bank branches of a local clearing house;
(ii) a Regional ECS covering all the bank branches of a state or several states as in the
North-east; and (iii) a national ECS covering the entire country. Alongside, the EFT has
evolved into the pan-India NEFT. Together, these two products have revolutionised the
electronic retail payments market landscape in the country.
Real Time Gross Settlement (RTGS)
17. The paper based and electronic systems that I just talked about were both retail
payment systems. As an economy grows, the volume of large value payment transactions
increases. For complementarity across the system, it then becomes important to extend
modernization to the large value payment systems as well. Towards this endeavour, the
Reserve Bank introduced the RTGS system in March 2004 for settling gross inter-bank and
customer transactions of values over 200,000. When we started off the RTGS in 2004, the
gross daily turnover was just about 5 billion. Today, the average gross daily turnover is
nearly 2.5 trillion, an expansion by a factor of 500. Similarly, the volume of transactions that
stood at just a few thousand on average per day when we started the RTGS has today
increased to well over 200,000 per day. We are now focusing on graduating to the Next-Gen
RTGS system with enhanced liquidity saving features and faster and higher processing
capabilities.
RBI's approach to responsible regulation
18. Having indicated what the Reserve Bank has done to modernize the payment and
settlement systems, let me now move on to RBI's approach towards being a "Responsible
Regulator" in this area. As I said earlier, the Payment and Settlement Systems Act, 2007
accorded statutory regulatory powers to the Reserve Bank. Even as we are the regulator, we
continue to be the large value payments system operator given the systemic and financial
stability issues involved. But our effort is now focused more towards encouraging banks and
authorized private entities to increasingly take over the retail payment space. I will tell you
about a few important things we have done in that direction.
Think global, act local
19. The Reserve Bank's strategy has been quintessentially "think global, act local". For
example, in the roll out of the retail payment systems - both paper based and electronic - we
followed a decentralized approach. As technology improved and as banks moved on to core
banking platforms, we shifted to aggregation and consolidation of the decentralized systems
to exploit economies of scale. The shift to grid based CTS, and in the case of retail electronic
payments, the NECS and the NEFT systems are illustrative of this.
Recognising the role of non-banks
20. Recognising that non-banks can provide innovative payment products and foster
competitiveness in the market, the Reserve Bank authorised non-banks to enter the retail
payment space. At the same time, we took care to ensure that the non-banks which come in
adhere to KYC/AML guidelines and follow the prescribed guidelines for customer protection
and customer service. For example, even as non-banks specialise in payment services and
products, the settlement domain remains with the banks, and the outstanding balances are
required to be kept in an escrow (trust) account so as to insure against bankruptcy.
21. Recently, the Reserve Bank has allowed entry for non-banks into another payment
space - ATMs. Although there has been a steady year-on-year 25 per cent growth in the
number of ATMs in the country, their penetration as measured by the number of ATMs per
million population is still very low when compared to other emerging markets. To increase the
deployment of ATMs, especially in the smaller centres, non-bank entities are now permitted
to set up, own and operate ATMs, styled as "White Label ATMs" (WLA). Accordingly, the
regulatory guidelines prescribe a proportion of ATMs to be necessarily installed in Tier III to
Tier VI centres (towns/villages with population of less than 50000), thereby extending
anytime, anywhere banking facility to a wider segment of population. Since this initiative will
bring in less literate and less empowered population into the ambit of ATMs, we have
expressly stipulated that, even as the WLA is set up by an NBFC, the primary responsibility
for redressing the grievances of customers relating to failed transactions and for cash
management remains with the sponsoring bank.
Promoting safety and security of payment instruments
22. We have implemented several measures to improve "hygiene factors" such as
safety and security of payment transactions. The security of online card transactions has
been strengthened with the implementation of additional factor of authentication. With effect
from July, 2011, an online alert for all card transactions has become mandatory. Similarly, to
protect card present transactions, we issued directions to banks and other stakeholders to
initiate measures to strengthen the security and fraud risk management practices, merchant
sourcing, and to issue EMV (Europay-MasterCard-VISA) chip card and PIN to customers
who have evidenced at least one purchase using their debit/credit card in a foreign location.
23. The Reserve Bank will soon need to take a decision on the choice between
migrating to EVM cards with chip and pin and an Aadhaar based biometric authentication.
The chip and pin is an established and tested technology, but is relatively expensive. The
Aadhar based option is cheaper, but the robustness of this technology is as yet unproven. If
indeed we are finally able to marry Aadhaar into the cards, we would be achieving the same
level of security available in chip and pin model at a much lower cost. Our other initiatives
include implementing CTS2010 standards to promote safety in paper clearing and to
immobilize the cash retraction facility in ATMs to prevent frauds.
Customer centric regulation
24. By far the largest number of complaints we receive in the Central Office of the
Reserve Bank as well as at our ombudsman offices across the country are about failed ATM
transactions. RBI has mandated that in case of a dispute, the disputed amount should be
credited to the customer's account within seven days, failing which the customer's bank is
liable to pay compensation to her at the rate of 100 per day from the date of the complaint,
provided the complaint is filed within 30 days from the date of the failed transaction.
25. Debit cards can potentially be a win-win option by enhancing convenience for the
customer and improving business for the merchant. Disappointingly, the penetration of debit
cards has been shallow. One disincentive is the business cost to merchants. So far, the
Merchant Discount Rate (MDR) for debit and credit cards has been uniform in India. Given
that a debit card is a secured product while a credit card is part of the unsecured credit
product portfolio, the Reserve Bank decided to introduce a differential MDR for debit card
transactions. Under this recently announced policy, the MDR for usage of debit cards should
not exceed 0.75 per cent of the transaction value for transactions upto 2000, and not
exceed 1 per cent for transactions above 2000.
26. Why is this regulatory intervention to reduce the MDR important? For an emerging
market with limited payment system acceptance infrastructure like PoS machines, a lower
MDR would encourage even smaller merchants to accept card payments since the outgo in
terms of the fee payable by them to the acquiring bank (the bank which has installed the PoS
machine) would be relatively small. In the case of developed countries where the acceptance
ecosystem is already in place, MDR is not an issue and only the interchange fee as
determined by the network operator has come under regulatory purview.
27. In an effort to facilitate domestic person-to-person fund transfer for migrant
population who do not have access to banking facilities because of inability to meet the KYC
requirements, three schemes have been rolled out: (i) cash pay out scheme; (ii) cash pay-in
scheme; and (iii) card to card transfers. The first two schemes facilitate fund transfers with a
bank account either at the remitting end or at the beneficiary end. These guidelines aid the
underprivileged who do not have a bank account for whatever reason, to get an access
nevertheless, to the formal banking channel to send and receive remittances safely and
inexpensively. There are no reliable estimates of what it costs to remit money through
informal channels, especially to and from remote locations; however, anecdotal evidence
suggests that informal channel remittances can cost several multiples of costs through the
banking system.
RBI as facilitator of innovation in payment systems
28. Let me now move on to our third role - as facilitator of innovation in payment
systems. Responsible regulation must also involve facilitating value adding innovation. Let
me give an account of what we have done towards this endeavour.
Calibrated approach towards introduction of new payment products
29. The last few years have witnessed a remarkable growth in new payment products
and access channels viz. debit cards and credit cards issued by banks, and prepaid cards
that can be issued by both banks and non-banks. The safety and efficiency of the access
channels viz. ATMs, PoS, E-commerce and M-commerce have been instrumental in the
popularization of these alternate payment products.
30. RBI recognizes the potency of prepaid payment instruments to be cash substitutes.
This was an area where regulation followed innovation. Since the guidelines were issued in
2009, prepaid payment instruments have been gaining popularity. Noticing their growing
popularity, we tweaked the policy on a dynamic basis to further facilitate the issuance and
acceptance of these alternate payment products. Under the recently introduced Domestic
Money Transfer guidelines, while no cash-out is still permitted in respect of semi-closed
prepaid payment instruments issued by non-banks, they can now be utilised for transferring
money to other semi closed cards or into bank accounts.
31. In October 2008, the Reserve Bank put out operating guidelines on mobile banking
for banks. Only banks which are licensed and supervised in India and have a physical
presence in India, are permitted to offer mobile banking, after obtaining the necessary
permission from the Reserve Bank. The guidelines focus on systems for security and
interbank transfer arrangements through Reserve Bank's authorized systems. On the technology
front, the objective is to promote inter-operable standards so as to facilitate fund transfers
from one account to another in the same bank or in another bank on a real time basis
irrespective of the mobile network of the customer.
Aadhaar initiative in payment systems
32. Aadhaar has been recognised as an alternate authentication mechanism in the
payment systems. Aadhaar based payment products have already been designed and
introduced.
33. Aadhaar Enabled Payment Systems (AEPS) is a payment system aligned with
UIDAI's plan to utilize the UID number for routing all government benefit transfer payments to
beneficiaries. AEPS is a bank led model which allows online financial inclusion transaction at
a PoS (MicroATM) through the Business Correspondent of a bank using the Aadhaar
authentication.
34. Aadhaar Payment Bridge System (APBS) is a centralised electronic benefit transfer
system which will facilitate disbursement of government benefits to the bank accounts of the
beneficiaries linked to their Aadhaar numbers. Such electronic transfers will enable efficient
and secure disbursement of benefits to the intended beneficiaries and will help the
Government in reducing the administrative costs of the various schemes as well as the
leakages in the transfers. This will also further financial inclusion by bringing the beneficiary
households into the banking fold.
Mobile financial services
35. Around the world, the delivery of payment services through the mobile has followed
two models viz. bank-led model as in India, South Africa and the Philippines, or non-bank led
as in Kenya and again in the Philippines. Why did we opt for a bank-led mobile banking
model? For several reasons. First, mobile payment systems can provide only a remittance
facility; they cannot provide other benefits under financial inclusion such as overdrafts, credit
and micro-insurance. Also, banks are heavily regulated and this allows us to address
concerns about KYC/AML as also customer service. With mobile payment companies, we
have neither similar regulatory authority nor comfort. Third, entry into the banking space has
to be on open, transparent and contestable criteria. We cannot allow privileged access to
mobile operators into commercial banking through the mobile route. Accordingly, we have
consciously pursued the bank led mobile banking model.
36. As of June, 2012, 50 banks were providing mobile banking services with an
aggregate customer base of 14.75 million. Both the volume and value of mobile banking
transactions are witnessing a remarkable growth. As of June 2012, a year-on-year growth in
terms of volume was 143 percent while that in terms of value was 213 percent.
37. The Interbank Mobile Payment Service (IMPS) launched by the NPCI in November
2010 is expected to give a further boost to the growth of mobile payments. The IMPS is a
unique 24x7 inter-bank electronic funds transfer system which provides instantaneous credit
to the beneficiaries which, I am told, is the first of its kind in the world. Currently, the IMPS is
at a nascent stage with limited volume of transactions and settlement values, but several
enhancements currently under way, are expected to increase the volume and value
substantially.
Focus on central clearing
38. India has preferred a central clearing arrangement for large value interbank
transactions wherever feasible. The Reserve Bank's tryst with central clearing started with
the setting up of the Clearing Corporation of India Limited (CCIL) in 2001. CCIL offers central
counterparty clearing and settlement arrangements for transactions in government securities,
forex segment and CBLO. Settlement through the CCP arrangement has reduced the
associated risk, cost and time in the completion of the settlement. Quite early on, the CCP
arrangement instituted netting in forex transactions. This proved to be particularly valuable in
the depth of the crisis when, even as liquidity lines had virtually dried up, banks in India did
not face any liquidity and funding shortages.
Institution building
39. The Reserve Bank is proud of its record as an institution builder. This has been the
case in the area of payment and settlement systems too where we built robust institutional
structure as part of responsible financial regulation. We promoted the CCIL for central
clearing and trade warehousing in large value payment systems, the IDRBT for promoting
development and research in banking technology and NPCI to act as an umbrella
organisation for retail payment systems. We all know, of course, that the opacity around the
volumes, value and counterparties to the OTC contracts was one of the main causes of the
global financial crisis. To mitigate this, in India, we prescribed, as early as 2007, that OTC
derivative trades (IRS trades) should be reported to the data warehouse, the CCIL. India was
possibly the first country to do this, and notably we did this even before the crisis. We have
now permitted CCIL to act as a trade repository for CDS and foreign currency derivatives.
The INFINET network and the Structured Financial Messaging Solution have been rolled out
by IDRBT at the behest of the Reserve Bank. These were pioneering efforts at networking
the industry and providing an alternate domestic solution for the transmission and exchange
of domestic financial messages.
Taking stock
40. I have so far discussed the Reserve Bank's role in payment and settlement systems
in three modes - in modernizing them, as the regulator and as a facilitator. What has been
the result of all this effort?
41. The large value payment systems have mostly shifted to the electronic mode,
possibly because of the regulatory fiat. Disappointingly, retail payment systems continue to
be paper centric and electronic systems have not penetrated deep enough. When compared
with other emerging markets like Brazil, Mexico and Russia, the value of banknotes and
coins in circulation in India, at 12 per cent of GDP, is high. The number of non-cash
transactions per person in India stands at just 6 per year, which again is very low in
comparison with other emerging economies.
42. Why is this so? Let us look at some important reasons.
Slow pace of infrastructure building
43. In proportional terms, India has one of the lowest numbers of ATMs and PoS
terminals - just 63 ATMs and 497 PoS per million population. Only a small fraction of the
10 million plus retailers in India have card payment acceptance infrastructure. Though the
usage of mobile banking and internet banking is growing, a significant percentage of
customer base is not covered.
44. Expanding the acceptance infrastructure such as ATMs, PoS terminals,
microATMs, handheld devices etc. into smaller towns and villages is very much required to give an
impetus to electronic payments. The recent policy initiative on white labeled ATMs is
expected to go a long way in increasing the acceptance network.
45. Developing and expanding payment infrastructure, as we all know, has associated
upfront costs. A question in this context is whether each institution should set up its own
dedicated infrastructure or whether there are economies of scale in setting up shared
infrastructure and competing for business based on that shared infrastructure. A good
example of sharing infrastructure while competing for market share is the mobile industry.
While infrastructure in the form of towers is shared, the mobile network operators (MNOs)
compete aggressively for protecting and increasing their market share. Innovation is, of
course, a splendid competitive weapon, but it is sometimes best fostered by collaboration.
Limited product innovation
46. Limited product innovation is another factor behind the tepid growth of retail
payment systems. While the private non-bank entities including MNOs have been in the
forefront of introducing pre-paid payment instruments including mobile wallets, the market is
yet to deepen. For example, there are innovative products like paypal Virtual Account and
Google Wallets etc. which are becoming popular in e-commerce because they are
convenient, safe and efficient. Why has something similar not developed in India?
47. The question in this context is whether RBI's regulation of payment systems is
acting as an entry barrier. Are RBI's regulations governing payment systems too complex
and demanding? Experience shows that that is not the case. Since the PSS Act came into
operation 2007, RBI has granted authorization to 41 entities to operate payment systems. In
framing and operating the guidelines, we have been guided by the need to develop payment
systems in the country while safeguarding safety and security. In introducing new products,
we have adopted a consultative approach and routinely seek feedback from the stakeholders
before taking a regulatory decision. We are open minded and receptive to new ideas. What
all this means is that we need to probe further to understand what is inhibiting innovation in
the Indian payment systems - is it that the regulatory environment is still not conducive
enough, or is the market not able to appreciate the future business promise?
Lack of initiative by banks?
48. A related question is: are banks taking the easy way out by being content with the
measures initiated by the regulator, and following, rather than leading the effort towards
electronification of payments? A typical illustration of this is that while all banks are active
card issuers, very few are card acquirers. Is this because card issuance is a lot easier than
enrolling merchants and putting in place the PoS infrastructure? How should RBI, as the
regulator, respond to this? Should we mandate that for a certain number of cards issued, the
issuing bank should have a prescribed proportion of PoS terminals as well? If the cost of a
PoS terminal is an impediment, should the banks not think of alternatives? There are
alternatives such as a mobile PoS which could be cheaper to deploy and easier to service.
Conclusion
49. Let me now conclude. I started with the broader debate on financial innovation and
regulation, on how the crisis has renewed that debate, and how the response to that debate
is crystallizing in the form of greater sensitivity to responsibility on the part of both innovators
and regulators. I then moved on to the narrow area of payment and settlement systems and
spoke on the role played by RBI in modernizing payment systems and in facilitating
innovation. I spoke about how we try to be a responsible regulator, encouraging innovation,
but at the same time ensuring that innovations add real value and do not compromise
financial stability or customer interest.
50. Payment and settlement systems is a fast growing area, witnessing rapid
innovations, spurred by market forces as well as technology. We need to bring in the best
practices and products of the world to India but we should adapt them to our environment
and conditions. In particular, we should focus on reducing costs and improving "literacy"
about payment products and systems. And as we shift from a largely cash based economy to
a less cash based economy, we need to grapple with the monetary policy implications of this
transition.
51. As a professional, forward looking institution, the Reserve Bank has put out in the
public domain a vision document on the road map for the evolution of payment and
settlement systems in India for the period 2012-15. The document reinforces the
commitment of the Reserve Bank to continue to ensure that all payment and settlement
systems in the country are safe, efficient, interoperable, authorised and accessible, while
also furthering financial inclusion and compliance with international standards. The goal is to
proactively shift from cash to electronic payment systems.
52. I have spoken today about RBI as a responsible regulator in the narrow area of
payment and settlement systems. You all know that the Reserve Bank's regulatory mandate
is wide, extending to banks, non-banks and significant segments of the financial markets.
This consciousness about responsibility straddles our entire regulatory mandate.
53. The financial sector is forever in a flux, and the challenge for regulators is to keep
pace with those rapid changes. Regulators should be knowledgeable, and this means they
should realize that they are always on a learning curve. Regulators should encourage
innovators to push the envelope, but should always ensure that the envelope remains sturdy
and strong.
Glossary of acronyms
AEPS Aadhaar Enabled Payment System
APBS Aadhaar Payment Bridge System
AML Anti Money Laundering
ATM Automated Teller Machine
CBLO Collaterlised Borrowing and Lending Obligation
CCIL Clearing Corporation of India Ltd.
CCP Central Counterparty
CDS Credit Default Swap
CTS Cheque Truncation System
ECS Electronic Clearing Services
EFT Electronic Funds Transfer
EMV Europay-MasterCard-VISA
GDP Gross Domestic Product
IDRBT Institute for Development and Research in Banking Technology
IMPS Interbank Mobile Payment System
INFINET Indian Financial Network
IRS Interest Rate Swaps
KYC Know Your Customer
MDR Merchant Discount Rate
MICR Magnetic Ink Character Recognition
MNO Mobile Network Operator
NECS National Electronic Clearing Services
NEFT National Electronic Funds Transfer System
NPCI National Payments Corporation of India Ltd.
OTC Over the Counter
PIN Personal Identification Number
PoS Point of Sale
PSS Act Payment and Settlement Systems Act
RTGS Real Time Gross Settlement System
UID Unique Identification
UIDAI Unique Identification Authority of India
WLA White Label ATM