Broox Peterson, Esq.: Recent Comments

Comment on Cuomo vs Clearinghouse Association-Why Preemption Cases are Important for the Prepaid Card Industry

2009-07-09T14:18:12Z

Hi Bruce, please see my latest post. Thank you for your question.

Comment on Cuomo vs Clearinghouse Association-Why Preemption Cases are Important for the Prepaid Card Industry

2009-07-08T15:13:51Z

Quick question on the prepaid issue -- what about commercial clients of the FI, specifically related to the issuance of payroll cards? Is the client (Company X) an "agent of the bank," or would they in essence become the issuer (like Simon)?

As payroll cards gain more steam and interest grows among FIs in issuing them this could be a major headache on the regulatory front. I'm interested in your opinions. Thanks.

Comment on Prospects for Payments Regulation Reform

2009-01-16T00:09:04Z

Hi Ken,
Good to hear from you. Thank you for your comment. There will be no lack of interesting endeavors if not successful reforms arising out of current circumstances. I intend to look at payments regulation in other countries as part of all this to see if that provides some perspective.

Comment on Prospects for Payments Regulation Reform

2009-01-15T19:42:24Z

Hey Broox,
Looking forward to your views on the direction of retail payment system regulations. Note the recent warning shot fired by Reserve Bank economists that takes the arguments for "harmonizing" regulatory schemes to the international level. With further industry concentration and shifts in credit quality, global schemes may have a near term opportunity to refresh their approach to payments risk management.

Comment on Prosper SEC Cease and Desist Order - What Were They Thinking?

2008-12-02T15:15:51Z

Thank you for the information, and referral to your blog, which I recommend to anyone who wants a deeper view into the issues.

Comment on Prosper SEC Cease and Desist Order - What Were They Thinking?

2008-12-02T03:00:21Z

Regarding your question about the quantity of noncollectable prosper loans, this info can be found at http://www.prosper.com/lend/performance.aspx where you learn that prosper has $22.5M of "charged off" loans, and another $6.5M of loans more than one month late.

PS: Many of the same sentiments you expressed can be found in http://fred93blog.blogspot.com/2008/11/prospercom-quiet-period-my-ass.html

Comment on Visa IPO - Big Changes?

2008-03-20T18:55:50Z

I certainly agree that there are value add services that Visa can develop, and they are doing so whenever possible. I guess my point is that you can change the legal structure of Visa but you can't remove the association dynamics. Thank you for your comment.

Comment on Visa IPO - Big Changes?

2008-03-20T17:01:38Z

Outstanding analysis and I heartily agree. Everyone seems to be looking for the "what's going to be different," when the bulk of the analysis should be on "what's staying the same." The obsession with the brand value will continue and that manifests itself most with issuer relationship (and it's a mutually-agreeable position, regardless of rumblings from large issuers). I think there is a balance there, however -- there has to be some level of "value added services" that can be developed and implemented without drawing the ire or raising the competitive hackles of issuers, no? Can't wait to hear more from you on this!