The PSD 'what ifs'

Today's Innovation in Payments rountable, sponsored by the Visa Europe Research Fellowship at the Centre for the Study of Financial Innovation, was filled with many 'what ifs' in regards to the Payments Services Directive.

What if settlement risk increases as a result of all these potential new payment institution entrants?

What if Tesco decide to deal with all their payments via their own Tesco bank? (estimated to be six percent of the payment volumes in the UK)

What if mobile phones get into the PI game? What if independant ATMs for that matter?

What if banks move their payment business to a PI group in order to reduce their capital adequency requirements? (PI have a lower capital adequency threshhold, simple because they do not hold and invest deposits).

What if the banks don't take the PSD seriously?

What if payments is not actually a banking business at all?

And who would want to invest in becomming a PI anyway?

The PSD, supposedly, came into affect on Nov. 1st. However, just in terms of compliance (everyone shout out Sweden) we are a few months away from full EU acceptance. Hence the proliferation if 'What ifs' 'maybes' and 'should we be concerned' is because the post-PSD environment has yet to fully emerge.

The roundtable was started off by a speaker who said the main issue with the PSD will be discovering the "unintented consequences."

I can't help thinking the PSD conversations sound simliar in tone to all those discussions around another EU Directive that was supposed to protect the client with increased competition and tranparency - What if all the predictions, instead of unintended consequences, around Mifid had come true?