Given the growing role of nonbank technology players in payments, a review of the nation’s oversight framework for retail payment systems could be helpful to identify important gaps. A good place to start may be contrasting the U.S. oversight framework for retail payment systems with other jurisdictions. Many foreign central banks, for example, have explicit authority for general retail payments oversight.
5 Moreover, most jurisdictions require that payment systems obtain a license and/or registration before commencing operations. A 2018 World Bank study found that the large majority of jurisdictions have some sort of license and/or registration requirement for mobile money platforms, payment card networks or switches, or clearinghouses.