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Paper to Pixels
By Kenneth Cline
Check 21 poses challenges for large and small
banks alike, yet the entire industry will benefit from a swift transition
from paper to electronic processing.
"Fasten your seat belts" might be an apt phrase when
it comes to assessing Check 21's likely impact on the banking industry.
The legislation signed by President Bush in October 2003 may not by itself
constitute a full-scale payments revolution, but it will certainly help
provoke major changes in the way banks process payments.
Technically speaking, the Check Clearing for the 21st
Century Act is rather limited in scope, only requiring that financial
institutions be prepared to process image replacement documents, or IRDs,
by Oct. 28, 2004. But the expected repercussions of the legislation make
it a big deal indeed.
By hastening the proliferation of electronic imaging,
Check 21 places institutions in the position of losing efficiency in
their traditional paper-based payment operations even as they incur new
expenses for imaging technology. Mitchell A. Christensen, executive vice
president for payment strategies at Wells Fargo & Co., is bullish
long-term, but believes that the paper-to-electronic transition will
pose a financial drag on institutions over the next three years.
To overcome thorny technical issues, intermediaries
of all types and sizes will have to temper their competitive instincts
and work together closely, especially on so-called "Day Two" processing
issues involving exceptions, corrections and overdrafts. Overall, the
pace of the transition from paper to electronics will be strongly influenced
by the degree of participation across the industry.
The good news is that substantial cost savings are
on the horizon, perhaps more than $2 billion annually industry-wide,
reflecting the efficiency of processing electronic files versus paper
checks. But attaining that happy state will be expensive and challenging,
as Banking Strategies demonstrates
in the following special report.
Meeting the specific requirements of the federal law
has more to do with customer service than technology. But how will institutions
handle the larger imaging revolution? That question has institutions
convening task forces and designating Check 21 "czars" to plot payments
strategies. Each intermediary will need to figure out its role in a payments
system likely to be increasingly dominated by electronic transactions.
The more specific challenge is figuring out the approach
to imaging technology and its ancillary issues, such as image exchange
and archiving. In a recent BAI online survey, large numbers of the 225
respondents from financial institutions anticipated that Check 21 would
drive their strategies in image exchange and archive, check truncation,
electronic check processing, remote image capture at branches and remote
image capture at automated teller machines.
Cost Bubble
Although Check 21 is inevitably linked with imaging
in public discussion, the law itself is silent on the issue of whether
financial institutions should adopt imaging technology. It only requires
that they accept IRDs, which are paper documents that include a copy
of the electronic image of a check.
Banks can decide
for themselves whether to accept the electronic image
of the original check or the IRD (which looks
a lot like the original check). The problem, however, is
that IRDs represent 1) an intermediate step to full imaging,
and 2) an unsatisfactory intermediate step, since they
are not electronic.
One bank-owned technology consortium estimates that
mixing IRDs into the current paper check processing system will boost
per-unit costs to a range of between seven and 11 cents. That exceeds
the range of between six cents and eight cents that it currently costs
to process paper alone. Full-image processing, by contrast, would drive
those per-unit costs to below four cents.
Clearly, there is a powerful incentive to move beyond
IRDs toward full-fledged image processing. And that's where things get
complicated, and expensive. While many major banks have already installed
the technology necessary to transform paper checks into electronic images,
some technical hurdles still must be overcome before they can easily
exchange those files between institutions.
One issue involves image quality. The industry has
yet to agree on standards, which raises liability issues. What if one
bank in the processing chain deems the image quality of an electronic
payment to be unacceptable? How is the dispute resolved?
Another issue is Day Two processing, which refers
to the exception items, such as illegible checks and overdrafts, that
must be handled after the "clean" checks have run through sorter-readers,
typically a day later. Since these items still have to be handled manually,
in a paper format, the cost benefits of imaging on Day One are diminished.
Then there's the larger issue of declining check volume,
which inevitably drives up per-unit processing costs. As Christensen
explains in one of our articles, this places banks "in a difficult situation,
in that the volume of checks is declining at the same time we're being
asked to invest capital and resources in re-tooling the infrastructure."
Christensen says the paper-to-electronic transition
will turn into a net positive only when a critical mass of banks has
adopted imaging and new imaging-based products are helping make up some
of the revenue lost from the decline in check processing. One respondent
to the BAI survey summed up the situation succinctly when he predicted
that Check 21 would lead to reduced costs and improved efficiency "in
the long run, but a cost bubble in the short term."
Differing Perspectives
Another key finding of our reporting concerns the
differing perspectives of large banks and small banks regarding the opportunities
and challenges of Check 21. Large institutions, by and large, are better
prepared for the transition to electronic processing and express a higher
degree of optimism about its benefits.
This partly reflects the fact that the largest banks
have already made substantial investments in imaging technology. Likewise,
most have by now settled on their image exchange and archiving strategies.
So where 35% of respondents from banks with more than $5 billion of assets
in the BAI survey say they're "in the process of implementing a strategy" for
Check 21, only 19% of respondents from smaller banks make that claim.
It's also significant that respondents from large
banks were more likely to anticipate benefits from electronification,
such as new product development (84%), lower collection costs (69%) and
improved customer service (61%). The corresponding percentages for respondents
from banks with less than $5 billion of assets were 68%, 50% and 50%,
respectively.
That's not to say that small banks have nothing to
gain from electronic processing. Like their larger brethren, some expect
to earn incremental revenue by providing their customers with real-time
access to imaged statements. Atlanta's NetBank Inc. believes that digitizing
the deposits it receives at ATMs and the checks sent from merchants will
save several hundred thousand dollars a year in processing costs, allowing
it to shift more of that work from outsourcers to its own employees.
Other small banks expect to participate in the digital revolution by
going in the opposite direction and outsourcing their imaging activities.
Despite the differing approaches, banks of all size
share some common concerns. One is the need to help their customers through
the transition away from paper checks. In the short term, Check 21 is
as much about customer handling as it is about technology. The millions
of people who are accustomed to receiving their cancelled checks every
month, as opposed to imaged statements, are likely to be particularly
put off by the appearance of IRDs, even in a paper format.
So banks face an educational challenge, and potentially
a marketing opportunity as well Ñ if they want to migrate their
customers to electronic transactions. The key to allaying customer fears
and selling them on the benefits of imaging is providing appropriate
training for bank employees. More than two-thirds of all financial institution
executives responding to the BAI survey anticipated that Check 21 would
affect customer communications. "Customer and employee education will
be one of the biggest challenges to the industry," one respondent predicted.
A final concern that cuts across all asset size categories
is the need for the industry to harmonize its adoption of imaging technology.
It does no institution any good to get too far ahead of the crowd because
the benefits will be wasted. As Christensen says, "A payment, by its
very nature, creates an exchange of value between two partners. If one
partner isn't image-capable, you're stuck dealing with the paper."
In that light, it's encouraging that large banks have
been working effectively through industry organizations such as the Small
Value Payments Co., Viewpointe Archive Services LLC, the Financial Services
Technology Consortium, and the Electronic Check Clearing House Organization.
Smaller banks, meanwhile, are participating through their technology
vendors and the Federal Reserve. Everyone involved with these various
efforts seems to understand that electronic processing is something that
must be pursued on a cooperative basis if individual institutions are
ever to enjoy its promised benefits.
Mr. Cline is senior editor with Banking
Strategies.
Copyright © 2004 by Banking Strategies,
published by BAI.
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