Submission Number: 561018-00011
Received: 2/20/2012 4:23:54 PM
Commenter: Seth Priebatsch
Agency: Federal Trade Commission
Initiative: FTC To Host Workshop on Mobile Payments and Their Impact on Consumers, Project No. 124808
Attachments: No Attachments
Everyone can generally agree that payments will, over time, shift to being made with our phones. This represents more than just a shift from a plastic card swiping vertically to plastic phone swiping horizontally. It represents the opportunity to make payments faster, cheaper and more valuable to both consumers and businesses.
My start-up, LevelUp, is trying to do just this. Enabling local businesses to accept mobile payments, run effective loyalty programs with the data, save on interchange fees and offer savings to the consumers.
The important comment that I have to make is not so much about what LevelUp or other companies are doing, but more about the essential nature of letting this space remain open.
The entrenched players are as powerful in this industry as any modern-day example that could be imagined. Their interest in boxing out competitors is only rational (and natural in a competitive economy) but their ability to do so is frightening. Any card company blocking processing for a smaller competitor (like LevelUp) would end their competitive viability. And it's not just the card companies that have power here, Verizon has blocked Google Wallet, and Google is no small player.
The ability for companies like Apple to embed NFC chips and then entirely block developer access (a la Verizon/Google Wallet) would instantly grant them a monopoly on mobile payments, if not in pure mathematical fact, in mindshare certainly. Any company that can't offer payments on the most popular device on the planet is not going to be considered a viable option by any merchant.
So, my summary point is to please just take extra caution to ensure that this space remains open and competitive. If it does, the American consumer, merchant and everyone in between will benefit. If competition is squashed before it starts, well, it won't be the end of the world, but it will be a lost opportunity.