UK PAYMENTS INITIATIVE

Michael Salmony 0:12

Hello, my name is Michael Salmony and I'd like to welcome you to the 50th episode of the Payments Trilogue, no less, where Javier, Ralf and I have interesting people in and around payments. And today 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

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.

Charles Damen 0:48

Thank you very much for the kind introduction, Michael. Great to be on the podcast. A big fan. So, yes, my name is Charles Damen. I'm Chief Product Officer at Token.io. Token is one of the leading A2A infrastructure providers in the UK. We enable pay by bank on behalf of for for payment service providers, banks, and fintechs across the UK and Europe.

But I represent the UK Payments Initiative as an industry director, and that's really what the topic is what the topic is about. we announced the UK Payments Initiative in the beginning of June at Money 2020, yes, so delighted delighted to be here.

Michael Salmony 1:39

Thank you, Charles. So 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 faster payments, which some people are still struggling with. Open banking is where 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?

Charles Damen 2:06

So yeah, it's it would be really good to take a little bit of a step back, because open banking is present, but we took quite a different approach in the UK to the rest of Europe. open banking came from the Competition Markets Authority, which required the incumbent banks or which required to to increase competitiveness between incumbent banks and neo banks. as a result.

Open Banking Limited was set up. And in 2021, the Competition Markets Authority required the banks to set up so-called sweeping VRPs. VRPs are variable recurring payments, and sweeping VRPs 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 recurring payments is the technology to make that really easy. Why? The reason is that it's consent based. So a consumer or an account holder sets up a consent from their bank account to move money either based on an 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 CMA9, had to implement VRP as technology as part of the Competition Markets Authority order, so to say. So they had to implement the infrastructure. Sweeping VRPs now represent 18% of all the open banking transactions in the UK. Now in 2022, some of the banks

realized that there is actually a commercial opportunity to use this technology, which we call so-called non-sweeping VRPs or commercial VRPs. The leading bank in the UK was the NatWest, and they announced a commercial model around VRPs. But they were the so they were a very innovative bank. They took a first mover step, but they were the only bank to do so. So

That meant that as a TPP, you know, we had agreements 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, NatWest was the only bank that would 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, the regulators started to look at this and they saw that there was real potential with this technology. The FCA came out with the PSR at that time. FCA and PSR have merged now through an initiative called the Joint Regulatory JROC, the Joint Regulatory Oversight Committee.

with a strategy recommendation that commercial VRPs should become a strategic priority. 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 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 the foundation, as the foundation of that. That spun off a whole set of work. and an entity had to be set up that was funded by the industry, so to say. So there were 31 companies funding this initiative to create the framework around this. So

The technology was already there, but we had to build a commercial model. We had to start to look at what we should be doing around consumer protection, for example. So late last year, basically a number of the leading banks, as well as the leading TPPs, decided to become shareholders of and and created so-called UK payments initiative.

To really make that a reality. So, what happens? 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 14 of the largest TPPs.

our shareholders have an equity stake in the company, as well as voting rights, which are equal. there's a board. The board has an MD, a chairman, a non-exec director, and then four industry directors, two from the TPPs and two from the ASPSPs. And I represent one of the TPPs, one of the TPP industry directors.

Ralf Ohlhausen 7:51

Could I jump in right here? Because from

an open banking perspective, this is almost like a fairy tale, at least from if I look at

it from Europe's perspective. I wish and dream that we could have gone this way in Europe as well. And of course we have tried, I guess we were even first with SPAA 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 the European Payments Initiative, just amongst ourselves. We have similar activities in each country: Swish, Twist, Vipps, Bizum etc. Where the all the banks have decided to just

club together, stay together and do basically have a closed shop a closed banking solution. So why is it that the UK has come to a different conclusion? Why did the banks not go this way in the UK?

Charles Damen 9:06

Yeah, no, great question, Ralf. It's I think there's a combination of things. One, there was significant investment in open banking. 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

a 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. you can repay your credit card or fund your account using Pay by Bank. So Pay by Bank already has become not not necessarily mainstream but is certainly becoming a really growing payment method. There are about thirty seven million, no about forty million payments a month now.

so I think it's a combination of one, there was a good framework, there's a there's already that banks and TPPs are are used to. The second element that I think was a critical piece was that the VRP technology 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 the change of a flag and then it's all around creating the multilateral framework or the multi multilateral rule book, the commercial model, consumer protections, et cetera, et cetera. So the technology investment

Michael Salmony 10:49

Charles, can I just say...

Charles Damen 10:51

was relatively limited.

Michael Salmony 10:53

I mean, what you say is good because I love Ralf's question. I think 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 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 really made sure that the banks got a new competitive offer.

Whereas in Europe, you know, the APIs were mandated, but whether they actually worked or not wasn't really followed up by lot of NCA's. So it wasn't, it had a completely different governance. 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?

Charles Damen 11:46

so certainly the competition markets authority or the CMA order really helped open banking and and and and ensure that open banking was implemented in a different way. there were, for example, user experience guidelines that was app to app redirect from the start. The APIs were and if if we compare it with yeah what we experienced in Europe in certain markets, the the framework was very good. and of course, again, yeah, the sweeping VRP implementation really helped.

I think the second element in terms of in terms of Brexit I'm not sure to what extent that that made a big difference. And more from the perspective that it was prior prior to Brexit, CM the CMA order had already been established. So the UK already went its own route. And we adopted, of course, certain aspects of PSD2

when PSD2 came into effect. but I'm I'm not sure to what extent to what extent that had a major effect. The interesting thing is sorry, go.

Michael Salmony 12:52

Okay, it

wasn't a Brexit benefit. I'm still trying to find one benefit that Brexit ever gave anybody. Maybe we'd find one.

Charles Damen 13:01

That's

a different conversation, Michael. That's

Michael Salmony 13:04

Okay.

Charles Damen 13:05

I'm also looking for that one, but but that's a different conversation.

Michael Salmony 13:08

But on the CMA thing, mean, you've described some of the reasons. I mean, I had a really, it really came home to me. actually spoke to somebody from the CMA where I asked them that question. And 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 worlds. And how did you open it up? And the CMA said, 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 because nothing like that happened in Europe. Could you confirm that? Is that what your experience doing?

Because that seems the governance that is very powerful and really ensures competition.

Charles Damen 14:11

I mean, I I know Ralf has alluded to it s very often and we see what we I don't know to what extent CEOs in Europe are are are are are contacted or not, but we could see certainly a lot more enforcement of of the rules in in the EU. we see a number of markets where it's a real challenge even with providing a lot of evidence. We we we don't often see that.

Active enforcement of the standards and the rules around PSD2. IBAN discrimination is also a very good example that still is ongoing, whereas we know that it's an and that it's not a a legal a legal practice. So I think the other element, and this is we have been heavily involved with with SPAA as well, was that whereas EPI was a seem to have been a CEO discussion, SPAA, unfortunately.

until now so far wasn't. And I and I we we we do see positive movements in certain markets where dynamic recurring payments is now being looked at also as a as a complement. so you recently had at I think people from giroAPI on the call it's certainly being looked at in in in that context and

I don't think it should have to be one or the other. if 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 monetize that at the same time? and a really interesting aspect then 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 approach that we have experienced sometimes in the past.

Ralf Ohlhausen 16:21

That

that there's my next question, actually. Sorry to jump in again. And but the governance. So you already mentioned giroAPI, and of course a big difference between that and SPAA is that giroAPI is the the child, the baby of the German banks and the TPPs are invited to the party, but not with not too much to say so far. So SPAA is fifty fifty.

The UK PI is what? And how how do you break the tie if needed?

Charles Damen 17:00

It is fifty fifty. so two industry directors from TPPs, two industry directors from ASPSPs, independent chairman, independent or there's a chairman that is employed by UKPI, an MD, and then an independent non exec director. There's certain elements that are, for example, where industry directors don't get involved in particular price settings.

So there's an independent pricing committee, and then when it comes ultimately to a vote, and that's where the independent, so the chairman, the MD, and the independent NED are the decision makers at that time. So both ASPSPs and TPPs got involved with the appointments of the MD, the the non-exec, the independent non-exec director, and the and the chairman.

Javier 17:54

Well if if I if I may because I think this this part, this collaboration and trust is probably what we are missing. We 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 confidence in between the different partners. And after Michael's chain of thoughts, I was wondering

What's the relevance of national communities? Because what I see is that at the national market and you know well the UK market before and after the exit the Brexit and you know well also the European Union market. So what's the relevance of national communities? Because what I see is at a at a purely 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 this two-tiers system in which we have still national communities, but then we are trying to build a European community. I would say still we are we are not yet barely we are in the in the childhood of this financial community at European level, which brings a lot of complexities because while I 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 whatever circumstances with a Portuguese bank. So and and we still at European level, we have not fully created this banking community, not to talk about the wider financial community including the TPPs. So our

National communities is still that relevant? Do we have still to focus on national communities to create to bring in 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's what what can we do when we have at least in Europe these two tiers system in which we have to play at two levels and many times we don't get anywhere because we we are

Just fighting those two battles in different fronts.

Charles Damen 20:24

Yeah, that's a it's a really interesting question. I think on the one hand we have we have an opportunity with PSD3 to

To almost bring bring Europe together in a way in which we will have and I I often say it is, 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 reaches anyone in Europe. So do we really need another payment methods to do that and to so 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 instant 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 SPAA APIs are also part of that, creates this model where one, it becomes interesting for banks to have, whilst we're opening the bonnet, so to say, to make the implementation of something like dynamic recurring payments available across the different banks in the different markets using that simple that single API.

And leverage some of the great work that was already done by SPAA because the model is there to to just use. so I think there is a there's an opportunity there. I guess the flip side is that not not the the interest in different markets may not always be aligned. that's I think the the the challenge, so to say. I mean, r regulators have still played an important role in the UK to make this happen.

Was a often 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 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 so it has been

whole collaboration of industry and regulators, but regulators still play an important role in the UK as well.

Ralf Ohlhausen 23:03

And could I ask well we already mentioned competition authority. There is also the other aspect of well, if I understand correctly, they they they said that the well the there will not be a competition act investigation at this stage. So you 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. But we had a similar situation in

SPAA it took a year or so to to come to a conclusion which then both sides didn't like and is also one of the obstacles there. And I guess there's a different process in Germany with giroAPI, but also with a lot of involvement by the competition authority there. So where are you with that?

Charles Damen 23:51

So as always, Ralf, you're very well informed. so there is indeed one of the critical pieces in the creation of UK payments initiative was some of the the the legislative work that is ongoing, the so-called Data Use and Access Act. that is that will soon go out for consultation. That creates a that

gives the FCA a set of powers, so the Financial Conduct Authority, a set of powers to to overcome pricing issues around and the the the the the competition issues around pricing, there will be a mandation element for banks then to to effectively adopt this this scheme so to say so a very clear there's a very clear

legislative act ongoing to overcome the competition issues, which will enable us to really launch the e commerce use cases next year.

Ralf Ohlhausen 25:00

And is there 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.

Charles Damen 25:12

Yes, so there is currently a pricing model. so so perhaps important to say a UK payments initiative went live on the first of June. so five of the six major banks are transacting and five of the major TPPs are transacting.

Currently the model so so currently it's a fixed fee model because it addresses five 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. you can pay for regulated it's from to to purchase rail tickets from regulated rail companies because there's an alternative form of consumer protection, it's so-called delay repay scheme.

Payments 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 like like chargebacks. in so to answer your question on ad valorem that is currently being looked at, particularly for e-commerce purchases.

So you come then into the whole risk balance. who will in case of disputes, who will be covering those? where does the liability sit? the the the the work that was initially done by by UK Finance looked at and and recommended an ad valorem model. The advantage of an ad valorem model is that it also really increases the scope because of course you can then suddenly start to also

use this new scheme for your very low value recurring transactions, your streaming music or TV subscriptions, for example, or your EV charging or your right hailing services or things like that. So so yes, long winded answer to say yes, ad valorem is certainly being looked at at the moment.

Ralf Ohlhausen 27:30

Yeah, because I mean from a merchant's perspective, I think the expectation I guess it's not different in the UK, at least certainly over here, is that pay by bank is cheaper.

And will be as safe or even safer than than than cards. So essentially you get more protection for the merchant side, you need less protection on the consumer side because of more security, SCA, etc. And the whole thing is then hopefully just transaction-based, i.e. fixed fees, etc. So there is this

big expectation, which hopefully will translate sooner or later into into the demand pull on the merchant side and getting more more of this and maybe less of cards and other traditionally but more expensive solutions. And what do you expect in in the UK? I guess you you have big ambitions there. So and well not just replicating all the cards and their bells and whistles is probably well not what you want.

Charles Damen 28:34

No, indeed. so so yeah, in order to drive adoption, it is it is critical that commercial VRP has a lower cost of processing for merchants. commercial VRP overall drives a lot a lot of advantages for for 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 SCA, or you're they're merchant, or they can be merchant initiated for fixed or variable amounts. 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 that certainly there's a big expectation that it will be a lower cost of processing. On the

On the 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 or France, for example, where you have Card Bancaire or Germany. in that consumers are used the debit cards are the most popular payment method. consumers are used to being protected through through chargebacks and can raise chargebacks.

Now should we replicate what is currently in market? Chargebacks are 50 years old, are very expensive for 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 to do a number of things. One, could the risk could the merchant play a bigger role in providing good refund mechanisms, et cetera, et cetera.

Can we therefore avoid the number of the of the calls that are being made to banks to raise a chargeback? Have you spoken with the merchant before? the bank should not be the first port of call when you have a dispute with a merchant. It should be the merchant that has the first port of call. but I think the second element, I think that can you can make some real improvements to take costs out of the system. an example I often use is

MasterCard did a study and highlighted that 30% of chargebacks that are raised with the issuer come from people that do not recognize the transaction 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 the legal entity instead of the merchant name. 30% of chargebacks. So

By having longer descriptors, which is supported in the open banking standard, 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 charges because the consumer can just see what they have bought, and therefore they don't have to call their bank. So we believe that there are a number of improvements that we can make and really take also disputes into the digital age, so to say.

and make it much more adapted to this this this new payment method.

Javier 31:54

Charles, typically the UK market works as a leading indicator to the rest of of Europe, in many cases at least. So what do you expect or what's what I what are you aiming to in five, ten years so that we can expect what or we can learn what will happen in the continent in ten to fifteen years?

Charles Damen 32:16

Wow. If I had a glass bowl.

Javier 32:20

Mm-hmm.

Charles Damen 32:23

I hope I I don't believe that so so I truly hope that in 10 to 15 years we will have 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

for all parties in the in the system. So 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 at as as Gjis would say, open up the bonnet, so to say, to build better APIs, to build better user experience. And let's leverage this to

build some of those premium services that we identified in SPAA. And I think given the interest that we have seen from s major, major merchants, dynamic recurring payments is is really a feature that a lot of given the the flexibility that it provides, the use cases that it can cover, a real opportunity

for pay by bank or whatever we may call it in in in in future to make a real impact and have multiple ways to address the sovereignty question in in Europe. we believe that there are multiple ways to skin to skin the cat, so to say.

Michael Salmony 34:03

Yeah, very good.

Ralf Ohlhausen 34:03

I have

one more question on the well actually going back, you alluded to it already, because 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 and so driving collaboration driving a dialogue or a trilogue this is what we're what we're trying to achieve here and that seems as if you've now achieved in the UK with the with this UK payments initiative but let me just put my finger into that one thing on whether you believe it would have happened without

A regulatory push. So without the Damocless sword there over the the banks, that something worse may happen unless they now start to play ball.

Charles Damen 35:17

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 account to account payments ubiquitous. was a very strong statement. the regulatory intervention definitely helped. there was a there was a strong push.

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 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. So

Michael Salmony 36:01

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 and the banks. And there's a lot of I think that's always the more successful model, right? mean, mandating and forcing 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 their own advantage. And I get the impression you've really done that.

Charles Damen 36:29

Yes, and and it this is why I think the setup of having a company limited by shares, where effectively there's the because the funding was actually not is 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 whilst the investment structure could also give the returns should

if and when they they will be there in after the initial after the initial investment. And the way the funding was structured is for a period of six years. so this means that the scheme could run based on the volume project projections for about six years without incremental funding. so that was also an important piece because as we know with every new scheme there's a there's a build up there is a period that we need to implement that we need to

get PSPs on board, merchants on board, drive volumes, etcetera.

Michael Salmony 37:30

Right then we'll, Ralf has a

Ralf Ohlhausen 37:31

I have one before you call the I I see Michael already suggesting

that we run out of time. But I have one more question. And sorry. It is 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

traction here in a similar direction in in Europe. But I'm also a little bit concerned about that you know in Europe so we have these there's only the bank solutions, the closed banking solutions, which are seen to be the the savior of European sovereignty. And they are now joining somehow you have these roaming agreements between the different solutions, different countries.

Would you could you be tempted to join them as the UK leg in the closed banking network there?

Charles Damen 38:30

Well, that's not my decision. that's not let me flip it around. I think this still I think for if we take the lens from a merchant, for a merchant it's actually really difficult to and of course the parties that can help it 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. 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 PSD3 addressing the user experience, I think there's a major opportunity for Pay by Bank to emerge as that real alternative. So I I'm I'm I'm so so I'd I'd like to focus more on making that enabling that and

And then we'll see if there is a need for UK payments initiative to join any of the any of the domestic schemes. But that's that's certainly not a decision.

Ralf Ohlhausen 39:36

I l I love your answer

and and I love that highlighting again that it's the really open banking or Pay by Bank is the only one to reach everyone in Europe and in the UK. Anyway, sorry. Yeah.

Michael Salmony 39:50

No, no, I think, 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 to the pubs before they closed. But I've been super impressed. mean, this is, 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 was particularly

Charles Damen 40:18

I'd love to.

Michael Salmony 40:19

impressed at the breadth of this topic because I'd initially always been a bit concerned. It's all so 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 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 so all

Charles Damen 40:50

yeah.

Michael Salmony 40:51

power to you, Charles. We wish you well. I think it's for the benefit of the banks, the fintechs, the consumers, the government, sovereignty, everybody. So really wish you wish you well. So thanks very much, Charles,

Charles Damen 41:03

Thank you very much.

Michael Salmony 41:04

Javier and Ralf and everybody listening. I hope you enjoyed it and look forward to seeing you next time.

Charles Damen 41:11

Thank you very much.

Javier 41:11

Thank you.

Charles Damen 41:12

Thank you. Bye bye.