Banking Law Project

On

“CONCEPT OF INTERNET BANKING”

Submitted to:

Dr. Y. Paparao
Assistant Professor

Faculty of Banking Law

Submitted by:

Shubham Kumar

Roll no. 151

Semester VII, Section C

B.A. LLB (Hons.)

Submitted on:
October 23, 2019

HIDAYATULLAH NATIONAL LAW UNIVERSITY

Uparwara Post, Abhanpur, New Raipur (C.G.) – 492002

 DECLARATION OF ORIGINALITY

I, Shubham Kumar, have undergone research of the project work titled “Concept of Internet
Banking”, as a student of Banking Law. I hereby declare that this Research Project has been
prepared by the student for academic purpose only, and is the outcome of the investigation
and preparation done by me under the able guidance and supervision of Dr. Yamala Paparao,
Assistant Professor, Faculty of Banking Law, Hidayatullah National Law University, Raipur.
The authors endorses certain views as his own and gives due credit to the jurists wherever
required.

Shubham Kumar
Roll. No. 151
Semester VII, Section C

I
 ACKNOWLEDGMENT

I feel highly elated to work on the project “Concept of Internet Banking”. The practical
realisation of the project has obligated the assistance of many persons. Firstly, I express my
deepest gratitude towards Dr. Y.Paparao, Assistant Professor, Faculty of Banking Law to
provide me with the opportunity to work on this project. His able guidance and supervision in
terms of his lectures were of extreme help in understanding and carrying out the nuances of
this project.

I would also like to thank The University and the Vice Chancellor for providing extensive
database resources in the library and for the internet facilities provided by the University.
Any errors in this research project, however, remain my own and I deeply regret them. I
would be grateful to receive comments and suggestions to further improve this project.

Shubham Kumar
Roll. No. 151
Semester VII, Section C

II
 TABLE OF CONTENTS

Declaration of Originality I
Certificate of Originality II
Acknowledgments III

Introduction 1
Meaning, History, Need and Types of Delegated Legislation 9
Problems of Delegated Legislation and Judicial Rescue 15
Conclusions 21
Suggestions 22
Bibliography 24

3
 INTRODUCTION
A Internet corporation is a temporary network of independent company’s suppliers,
customers by information technology to share skills, costs, and access to one another's
markets. This corporate model is fluid and flexible- a group of collaborators that quickly
unite to exploit a specific opportunity. Once the opportunity is met, the venture will, more
often than not, disband. In the concept's purest form, each company that links up with others
to create a Internet corporation contributes only what it regards as its core competencies.
Technology plays a central role in the development of the Internet corporation. Teams of
people in different companies work together, concurrently rather than sequentially, via
computer networks in real time.1 The Internet corporation to be a 'must have' road map for
every corporation that will soon find itself, its members and most importantly, its customers,
living, working and shopping in a Internet world.2

Why there is a need to build a Internet Corporation:3

Do we really need to build Internet Company? Let’s turn the question around and state it as
“Do we really need to invest money to reduce our cost?” Believe it or not the answer is often
“no”. There will be thousands of business next year that will spend more on e-commerce than
they will ever receive back in profit. Many of these companies would be better off financially
if they invested their money and focused their operations on tasks that provide the greatest
return on investment. However there are hundreds of thousands of companies that can
redirect staff towards value added tasks, such as sales through the greater use of automation.
They can also reach new customers in other locales or more effectively communicate with
their existing customer by using the virtual.

Role of information and communication systems in Internet corporations is highly significant.

The demands made on information technology for supporting company networks are
characterized by attempts at integration. Electronic interoperation is supported by three
pillars- Automation of information flow and the elimination of media break ,the interchange
of unstructured data, the linking of several local area networks into wide area networks.

1
Research article A concept for supporting the formation of Internet corporations through negotiation by
Boris Kotting published in (WET ICE ‘99) , pp 40
2
The Internet Corporation: Structuring and Revitalizing the Corporation for the 21st Century byWilliam,
H.Davidow, pp 23
3
The Complete idods guide: Ecommerce.

4
There are five basic dimensions that organizations can virtually organize and each dimension
is a continuum from physical to virtual.

 Location
 Organizational interfaces or boundaries
 Organizational processes
 Organizational structures
 Products / services

Benefit of virtuality:4 The benefits of Internet organizations include the following:

Reduced operational costs. Reduced costs of providing information. A global presence

(accessible anywhere). Always open for business (accessible anytime; Projects can be staffed
with people based on competency regardless of their physical location; People can connect
with each other regardless of time, space, or Organizational boundaries; Localized skills
shortages can be overcome.

Force Driving the Internet Corporation: 5

The first and foremost is Economics. The need for greater productivity per employee, the
reduction in capital available to corporations, and the arrival of hungry new competitors. Big
companies used to live off their fat in the lean times. Lean is in, lean is good. Second force is
Ecology i.e. Statutory need to reduce the numbers of commuters into our city cores, to reduce
automobile pollution and to reduce the demand for ever more transportation capacity. Internet
offices, along with telecommuting, van pooling, transit vouchers, are attempts to deal with
the environmental impact of millions of people swamping our cities. The last but not the least
is Technology. New technologies have focused on management, marketing, sales, and white
collar technology. Technology enables the Internet corporation.

4
Id
5
Id

5
 CHAPTER 1: CONCEPT OF INTERNET BANKING

The concept of virtualization play a vital role to transform banking industry from paper
banking to paperless banking which will majorly benefit the customers of banking industry.
Internet Banking works as a milestone to achieve the customer satisfaction towards the
services provided by commercial banks.

Internet Banking is a type of banking which allowed customers to access their financial and
banking services via internet world wide web. It’s called a Internet Banking because a
Internet bank has no boundaries of brick and mortar and exists only on the internet. With
cybercafés and kiosks springing up in different cities, access to the Internet Banking is going
to be easy.

Internet Banking is a development of computer banking format that is rapidly growing in

popularity. It is not restricted to a specific computer, as there is no need for the customer to
have any financial software program installed on the computer in order to conduct banking
over the internet. Instead of establishing a direct link between the customer’s own pc and the
bank via a modem, the World Wide Web is used as a distribution and communication channel
to the bank. This implies that Internet Banking may be cost-efficient and a convenient
banking format for many customers. It can be expected to generate its main benefits from
retail services such as short-term lending, deposits, cash management including card
payments, pre-scheduled payments for electricity, insurance, housing, etc. In those cases,
traditional manual operations within the bank are being replaced by online ones performed by
the customers themselves.

Dr. Edward P. Shea define in there article Rethinking CRA in a technological age 6 that
“Internet Banking is a term that suggests the ultimate state of technological equilibrium in
banking. That is the point at which banking as an industry transcends mere physical presence
and home-office size as a measure of capability—the art and science of being everywhere at
the same time. As banks get bigger and more virtual, their markets will get more diffuse,
harder to pin down, and less well identified with neighborhoods or communities.”

V. Shankar and his associates define in their article Customer satisfaction and loyalty in
online and offline environments.7 that “Indian Banking Industry today is in the midst of an IT
6
Edward P. Shea, “Rethinking CRA in a technological age,” CRA Bulletin, Vol. 5, No. 3, 1995
7
V. Shankar, A. K. Smith, A. Rangaswamy: Customer satisfaction and loyalty in online and offline
environments, Intern. J. of Research in Marketing, Vol. 20 pp. 153-175, 2003

6
revolution. Nearly, all the nationalized banks in India are going for information technology
based solutions. The application of IT in Banks has reduced the scope of traditional or
conventional banking with manual operations. Nowadays banks have moved from disbursed
to a centralized environment, which shows the impact of IT on banks. Banks are using new
tools and techniques to find out their customers need and offer them tailor made products and
services. The impact of automation in banking sector is difficult to measure.”

The article titled as Core Banking Solution for Banks-The Indian Experience by A K
Mohanty8 highlights that the usefulness of Core Banking Solutions (CBS) as a single
channels enabler for banks as providers for all their products such as ATM, debit cards,
Telebanking, Internet Banking etc., as well as other important functions. In spite of this some
banks have failed to implement CBS for fear of the complexities and cost involved.

8
IUP Journal May-June 2005

7
 CHAPTER 2: TYPES OF INTERNET BANKING

Banking industry is continuously increasing their product day by day, by which banks are
transferring from real to Internet very speedily. Banks divided Internet Banking products into
3 types based on the levels of access granted. They are:

2.1 Information Only System:

This type of banking provides general purpose information like interest rates, branch location,
bank products and their features, loan and deposit calculations are provided in the banks
website. There exist facilities for downloading various types of application forms. The
communication is normally done through e-mail. There is no interaction between the
customer and bank's application system. No identification of the customer is done. In this
system, there is no possibility of any unauthorized person getting into production systems of
the bank through internet.

2.2 Electronic Information Transfer System:

In this type of banking the system provides customer-specific information in the form of
account balances, transaction details, and statement of accounts. The information is still
largely of the 'read only' format. Identification and authentication of the customer is through
password. The information is fetched from the bank's application system either in batch mode
or off-line. The application systems cannot directly access through the internet.

2.3 Fully Electronic Transactional System:

This system allows bi-directional capabilities. Transactions can be submitted by the customer
for online update. This system requires high degree of security and control. It covering
Computerization, Networking and secure payment gateway. Internet Banking, ATM, Phone
Banking, Mobile Banking, Smart Cards, are the types of fully electronics transactional
system.

2.3.1 Internet Banking: Internet Banking involves consumers using the internet to access
their bank account and to undertake banking transactions. At the basic level, Internet
banking can mean the setting up of web page by bank to give information about its
product and services. At an advance level, it involves provision of facilities such as
accessing accounts, fund transfer, and buying financial products or services online. This is
called “transactional” online banking.

8
 There are two ways to offer of Internet banking. First, an existing bank with physical
offices can establish a website and offer Internet banking in addition to its traditional
delivery channels. Second, a bank may be established as a “branchless, Internet only or
Internet bank” without any physical branch ATM: Automated Teller Machine or automatic
teller machine also known as automated banking machine (ABM), cash machine, cash
point is a computerized telecommunication device that enables the customers of bank to
perform banking transactions without the need of cashier, human clerk or bank teller. On
the most modern ATMS customer identified by inserting a plastic ATM card with
magnetic strip or a plastic smart card with a chip that contains unique card number and
some security information such as an expiration date or CVV. Authentication is provided
by the customer entering a personal identification number. Use of Automated teller
machines has been a tremendous rise in the past few years in India “Automated teller
machines are computerized Telecommunications device that provides customers of a
financial institution with access to financial transactions in public place.” 24 The best part
about this Internet Banking is it access of 24 hours and 7 days. There are many research in
past few year related with customer perception towards ATM services in India and in
world shows that ATM is one of the most convenient way of banking for withdrawal
money, deposit money, collect statements. Customers visiting will reduce by an estimated
80% which will result in huge savings in the employee- related cost for the banks. The
cost incurred in servicing customers through ATM is 1/3rd of the cost incurred if the same
customer were to be served personally through the branches of the bank.

2.3.2 Phone Banking9 : Phone banking is also one of the types of Internet Banking which
has been provided by financial institutions. Telephone banking is a service that enables
customers of the financial institutions to perform financial transaction over the telephone,
without the need to visit bank branch or automated teller machine. Telephone banking
times can be longer than the branch opening times and some financial institutions offer the
services on a 24 hour basis. From the banks point of view, telephone banking reduces the
cost of handling transactions by reducing the need for customers to visit a bank branch for
non cash withdrawal and deposit transactions. To access telephone banking, the customer
would call the special phone number set up by bank, and enter on the keypad the customer
number and password. Some banks have set up additional securities steps for access, but
there is no consistency to the approach adopted. Most telephone banking services use an

9
www.worldbank.org/indicator/FB.ATM

9
 automated phone answering system with phone keypad response or voice recognition
capability. To ensure security, the customer must authenticate through a numeric or verbal
password or through security questions asked by a live representatives.

2.3.3 Mobile Banking10: Mobile technology is growing very speedily now a day in India,
it’s very economical and easy to maintain mobile for a person in its pocket. “According to
NDTV India is expected to have close to 165 million ile Internet users by March 2015, up
from 87.1 million in December 2014 as more people are accessing the web through mobile
devices and dongles, a report by Internet and Mobile Association of India (IAMAI) and
IMRB. According to the report, the number of mobile Internet users increased to 87.1
million by December 2014 from 78.7 million users in October 2014, who accessed
Internet through dongles and tablet PCs.”11

This tremendous growth of mobile users forces banking industry to begin one another type
of Internet baking i.e mobile banking to provide better service for their customers. The
main reason that mobile banking scores over internet banking is that it enables ‘Anywhere
Anytime Banking’. Customers don't need access to a computer terminal to access their
bank accounts, now they can do so on-the-go while waiting for the bus to work, traveling
or when they are waiting for their orders to come through in a restaurant. it is a way for the
customer to perform banking actions on his or her cell phone or other mobile device. It is a
quite popular method of banking that fits in well with a busy, technologically oriented
lifestyle. It might also be referred to as M-banking or SMS banking.

In mobile banking some banks offer only the option of text alerts, which are messages sent
to your cell phone that alert you to activity on your account such as deposits, withdrawals,
and ATM or credit card use, this is a basic type of mobile banking. A more involved type
of mobile banking allows the user to log into his or her account from a cell phone, and
then use the phone to make payments, check balances, transfer money between accounts,
notify the bank of a lost or stolen credit card, stop payment on a check, receive a new PIN,
or view a monthly statement, among other transactions. This type of banking is meant to
be more convenient for the consumer than having to physically go into a bank, log on from
their home computer, or make a phone call. While all of this is true, some are concerned
about the security of mobile banking.

10
www.worldbank.org/indicator/FB.PhoneBanking
11
www.worldbank.org/indicator/FB.MobileBanking

10
 CHAPTER 3: CONSTRAINTS IN INTERNET BANKING
Although there are obvious benefits in Internet Banking, there are some hurdles in the smooth
implementation of Internet Banking.

1. Start-up cost: The initial start-up cost for venturing in to Internet Banking is on the
higher side and in includes the following:

• Connection cost to the internet or any other mode of electronics

communication.

• Cost of sophisticated hardware, software and other related components like

modem, router, bridges, network management system etc,

• Cost of maintenance of all equipment, web sites, skill level of employees.

• Cost of setting up organizational activities

2. Training and maintenance: The introduction of Internet Banking involves 24 hours

support environment, quality service to end users and other partners which would necessitate
a well qualified and robust group of skilled people to meet external commitments. Hence the
bank has to spend lot training.

3. Lack of skilled Personnel: It is well known fact that there is an acute scarcity of web
developers, content providers and knowledgeable professional to route banking transactions
through internet.

4. Security: In paperless banking transaction, many problems of security are involved. A

security threat is defined as a circumstansive decision or event with potential to cause
economic hardship to data or network resources in the form of destruction, disclosure,
modification of data, denial of services, fraud, waste and abuse. There are chances that the
documents such as cheque, passbook, can be modified without leaving any visible trace.
Distortions of information are also possible. Providing appropriate security many require a
major initial investment in the form of application encryption which requires a major of
firewalls etc., In spite of implementation of several security measures, the possibility of
security breach cannot be ruled out.

5. Legal Issue: Legal framework for recognizing the validity of banking transaction
conducted through the ‘net’ is still being put in place. Though, initial legal framework has

11
been devised for e- banking activities, it is uncertain as to what possible legal issues may pop
up in future as banking on Internet progress.

6. Restricted clientele and technical problem: The user of Internet Banking needs a
computer and time to go on to the site, which means that the target clientele is restricted to
those who have home PC or can access the ‘Net’ through the office or cybercafé. Moreover
technical constraints due to telephone connectivity, modem connections etc. may cause
constraints.

Concerns About Internet Banking12

Since the usages of Internet Banking not restricted in any specific customers the concept
involved in many different areas, so that use of Internet Banking has brought many concerns
from different perspectives: government, businesses, banks, individuals and technology.

From a government point of view, the Internet Banking systems pose a threat to the antitrust
laws. Internet Banking also arouse concerns about the reserve requirements of banks, deposit
insurance and the consumer protection laws associated with electronic transfer of money. The
Indian Government is concerned with the use of high quality of encryption algorithms
because encryption algorithms are a controlled military technology.

Businesses also raise concerns about this new media of interaction. Since most large transfer
of Money is done by businesses, these businesses are concern about the security of their
money. At the same time, these businesses also consider the potential savings in time and
financial charges (making cash deposits and withdrawals which some banks charge money
for these processes) associated with this system another businesses concern is connected to
the customer. Businesses ponder the thought that there are enough potential customers who
would not make a purchase because the business did not offer a particular payment system
(e.g. electronic cash and electronic check). This would result in a loss of sales. On the other
side of the coin, if this system becomes wide spread, this would allow more buying power to
the consumer which puts pressure on businesses to allow consumers to use electronic transfer
of money.

Banks are pressured from other financial institutions to provide a wide range of financial
services to their customers. Banks also profit from handling financial transactions, both by
12
Vulnerabilities in e-banking: A study of various security aspects in e-banking - Tejinder Pal Singh Brar ,
International Journal of Computing & Business Research Proceedings of ‘I-Society 2014,ISSN (Online): 2229-
6166

12
charging fees to one or more participants in a transaction and by investing the funds they hold
between the time of deposit and the time of withdrawal, also known as the “spread”. With
more financial transaction being processed by their central computer systems, banks are also
concern about the security of their system.

Individuals are mainly concern with the security of the system, in particular with the
unwarranted Access to their accounts. In addition, individuals are also concern with the
secrecy of their personal information. 82 percent of Indian poled expressed concern over
privacy of computerized data. As more and more people are exposed to the information
superhighway, privacy of information and the security that goes hand and hand with this
information is crucial to the growth of electronic transactions. Some privacy technologies
related to the electronic banking industry are electronic cash and electronic checks.13

13
Basic Reflections on Security. Http://www.esd.de/eng/secu/secu.htm#10

13
 CHAPTER 4: SECURITY CONCERN IN INTERNET BANKING

The security of information may be one of the biggest concerns to the internet users. For
Internet Banking users who most likely connect to the internet via dial-up modem, is faced
with a smaller risk of someone breaking into their computers. Only organizations such as
banks with dedicated internet connections face the risk of someone from the internet gaining
unauthorized access to their computer or network. However, the electronic banking system
users still face the security risks with unauthorized access into their banking accounts.14

In order to provide effective and secure banking transactions, the following major controls
must be ensured.

• Authenticity controls: To verify identity to individuals like password, pin etc.

• Accuracy control: To ensure the correctness of the data, following across the network

• Completeness control: To make sure that no data is missing

• Redundancy controls: To see that data is traveled and processed only once and there is
no repetitive sending of data

• Privacy control: To protect the data from inadvertent or unauthorized access.

• Audit trail controls: To ensure keeping chronological role of events that are occurred
in the system,

• Existence controls: To make sure that ongoing availability of all the system resources
with the same throughout.

• Efficiency: To ensure that the system uses minimum resources, to achieve the desired
goal.

• Encryption controls: To enable only those who possess secret key to decrypt the cyber
text.

CHAPTER 5: BENEFITS OF INTERNET BANKING

14
See Kit Burden, “Insurance of E-commerce Risks” [2000] I.C.C.L.R. Issue 2

14
Advantages previously held by large financial institutions have shrunk considerably. Internet
Banking is a cost-effective delivery channel for financial institutions. Consumers are
embracing the many benefits of Internet Banking. Access to one's accounts at anytime and
from any location via the World Wide Web is a convenience unknown a short time ago.
Thus, a bank's Internet presence transforms from 'brochure ware' status to 'Internet banking'
status once the bank goes through a technology integration effort to enable the customer to
access information about his or her specific account relationship. The six primary drivers of
Internet Banking includes, in order of primacy are:

• Improve customer access

• Facilitate the offering of more services

• Increase customer loyalty

• Attract new customers

• Provide services offered by competitors

Dr. Mishra A. K. described15 that the Internet Banking is a cost-effective delivery channel for
financial institutions. The author also describes the advantages of internet banking, current
status of Internet Banking in India, and the mechanism to protect the customer’s data. The
advantages of internet banking ”to improve customer access; to facilitate more services; to
increase customer loyalty; to attract new customers; to provide services offered by
competitors; to reduce customer attrition.” Prof Geetika discussed16 the concept of Internet
Banking, perception of Internet bank customers, non-customers and issues of major concern
in Internet Banking. The state of Internet Banking in India has been explored using various
concepts like E-banking scale, and gap analysis related to the various services and the
security features offered. In order to have a clear and focused insight about the perceptions of
users (and non-users) about Internet Banking a survey was conducted. The findings of the
survey provide valuable insight into concern for security, reasons for lower penetration, and
likeliness of adoption, which have been used to make useful recommendations.

15
Mishra A. K., “Recent Trands in Internet Banking” International Journal of Research and Management, issue
I Dec 12.
16
Geetika, Nandan Tanuj, Upadhyay Ashwani , “Internet Banking in India: Issues and Prospects”, The
ICFAI University Journal of Bank Management, Volume-VII Issue 2 (May 2008) pages: 47-61

15
 CONCLUSION
As the saying goes, change is the only certainty. And it is this change that would govern the
banking industry, which is graduating from financial intermediary into risk intermediary. The
repetitive and overlapping systems and procedures have given way to simple key-press
technology, ensuring accuracy and speed of data flow to improve overall efficiency through
Knowledge Management. The emerging Information Technology (IT) facilitates in utilizing
Knowledge Management effectively and efficiently to improve both product range and
service quality in the banking sector.

Definitely by 2020, the vast and enormous differences in the ambience presently noticed
between public sector banks and the new generation private sector as well as foreign banks
would be noticeably narrowed down. But the dominance of public sector banks, which
accounts for nearly 80% share in the banking sector, is likely to reduce considerably by 2020.
Technology has played a vital role in the evolution of banking sector, through speed creation,
accuracy and efficiency of operation and reduction in the transaction cost. Banking services
are now oriented to anyhow, anywhere, anytime and any type banking. Bank would ready
with so many new technology which will going to be applies in future banking industry

Biometric ATM

We all know about ATM's that accept our credit/debit card and the PIN number to dispense
cash. Biometric ATM's are the latest inventions to help us avoid fraud and duplication. If
somebody steals our card and also knows our PIN they can easily withdraw cash from our
account. In case of biometric ATM's they cannot. Usually the PIN for bio ATM's is the finger
print of the card holder or his eye retina scan etc. These cannot be duplicated and hence they
are very safe and secure. But they are very costly when compared to traditional ATM
machines and hence they are not very widely used now a days but future banking will
defiantly go with biometrix Banks are more focused to put these ATMs in rural areas because
biometrics makes it possible for the low literacy population to use banks. With the
development of biometric solutions for the ATMs there is no need to remember PIN
numbers. Software vendors are coming up with finger print solutions for the rural masses.
Chennai based Financial Software and Systems (FSS) has recently launched its Biometric
ATM Interface Solution (BAIS) that enables connectivity of ATMs with biometric support to
Electronic Financial Transaction (EFT) switches. Elaborating on the working of the biometric
solutions, G. P. Shekar, Head - Consulting Practice, Financial Software and Systems (P) Ltd.

16
says, Customers opting for biometric authentication can visit a nearby kiosk or ATMs or
bank, where his finger-print data would be scanned into a special PC with a finger-print
scanner and the scanned fingerprint is then stored in an encrypted form in a central server.
When a customer inserts (or swipes) his card in a biometric enabled ATM, he is prompted to
set his finger in the fingerprint scanner. The transaction along with customer’s biometric
information is passed on to the switch. The switch verifies the fingerprint with the server, and
if successful, requests the banking application to authorize the transaction. Based on the
result, the Switch instructs the ATM to complete the transaction. FSS’ BAIS solution meets
this requirement, by performing requisite message translations as well as
confirming authorization.

M-Pesa (M for mobile, pesa is Swahili for money):

M-pesa is a mobile phone based money transfer and micro financing service, which allows
users with a national ID to use their money easily with a mobile. Vodafone is expected to
launch M pesa in India, in association with ICICI & HDFC bank.

Mobile Payment

As much as mobile banking may please or even delight customers, most banks have
discovered that on its own, mobile banking is not really a money maker. That’s where mobile
payments come in. While mobile banking, much like online banking before it, is generally
offered for free, banks have an opportunity to impose fees for mobile payments, particularly
if they’re performed in an expedited fashion. Now is the time to move in that direction. “It is
imperative that the financial services industry move beyond the confines of mobile banking
in order to fully realize the potential of the medium,” noted Tower Group in an August report.
The industry is just in the beginning stages of untangling the bewildering array of options for
supporting mobile payments. So far, the Financial Services Technology Consortium has
identified about two dozen mobile payment options that it thinks have potential. Says Lloyd
L. Hamm Jr., chief administration officer of the $6.6 billion Boston-based Eastern Bank, “It’s
the wild, wild West out there right now. Everyone thinks they have the next best solution.”
That complexity is not proving to be a deal breaker. According to the Independent
Community Bankers of America’s 2009 payments study, nearly half (47%) of community
banks with more than $500 million of assets plan to offer mobile payments by 2011. Even the
smallest banks are getting into the act. Seventeen percent of banks with less than $100
million in assets expect to offer mobile payments.”

17
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