Sometimes it's not technology that beats you, it's probably just a document.

In the 2014 Alibaba Technology Forum, Ma Yun said in his speech, "Sometimes defeating you is not a technology, may be just a document," is the media that is Ma Yun's "Central bank document" the first response. To count down, from 2011 the central bank issued a third party payment license to start, this is the third time Alipay was "defeated by the document" Dangerous situation.

The first regulatory turmoil: Can Alipay get a third party payment license

As Taobao day Cat Checkout, Alipay in Alibaba, the great power of the empire of the importance is needless to say. The Alibaba IPO is valued at more than 100 billion dollars, but it does not include Alipay, the original asset in Alibaba.

As early as June 2009, Alipay's 70% per cent transfer of Alibaba, the US Yahoo and SoftBank, was a major shareholder, and, according to Mr Ma's own disclosures, the Board had a summary on July 24, 2009: Authorizing management to obtain payment licences. In 2010, Alipay's full equity transfer was completed, and Alibaba simply controlled Alipay through the agreement. After the central bank issued a third party to pay the licence, "Non-financial institutions payment Services management measures" stipulates that "foreign investment payment agencies, the scope of business, the qualifications of foreign investors and the proportion of capital contribution, etc., by the People's Bank of China separately stipulated, the State Council for approval." According to Ma Yun, because of this rule, if Alipay by the United States Yahoo and Japan SoftBank for large shareholders of Alibaba control, will not be able to obtain Third-party payment license. So will Alipay shift, "it's a tough but right decision."

So, in June 2011, Hu Shuli's article, "Ma Yun is wrong" to push the matter to the front desk, Ma Yun This matter with Hu Shuli text A lengthy discussion, in response to Hu Shuli's questioning. One of the key questions is whether the central bank has explicitly asked that Alipay not be completely divorced from Alibaba and will not be able to obtain a third-party payment license.

As for the central bank's policy, Ma said vaguely, "I have no way to do it, that is their consideration, I tried and tried." But what entrepreneurs have to do is to make the effort before Dafa is released, but it is our duty to post the law of Honour. Criticism is the work of your reviewers, and it is difficult for our clients to do so. But on the other hand, I understand that the security of the payment data is not an easy one for any country to give up, it is a security issue rather than a national problem. My openness is no less than anyone else's, but I understand that the future era is data competition. We have the economic data of the country. In the United States, we will encounter the same problem. ”

Ms. Hu further asked, "according to Central bank policy, will be put, Alipay can be approved in the future, back to Ali?" Is it a temporary transfer? To this, Ma Yun replied, "Hehe, you are a good reporter".

Return to the central bank's regulatory problems. Prior to the issuance of a third party payment licence in 2011, the equity stake in Alipay had been separated from Alibaba by agreement to maintain control. Rather than being embarrassed by the central bank's Prudential regulation, Mr Ma claims that very strict central bank regulation provides him with the best reason to leave Alipay completely out of control of Alibaba's agreement. From then on Tencent Tenpay, Sheng Changtong equivalent for internet companies to get third-party payment license, even if Alipay stay in Ali or continue to be controlled by Ali agreement, I am afraid that the central bank will not be able to get the license to "ban". Of course, is it because Alipay is the largest volume of the body to be more special supervision of "care"? Alipay has expressed a vague pressure on this. But it is hard to prove it from the central bank.

The second regulatory storm: Cod stopped by "well known" reasons

August 27, 2013, Alipay posted a short message: "For some well-known reasons, will stop all offline POS business." Alipay said that the original cooperative merchants will be properly handled, will not affect the normal business businesses. ”

To be exact, Alipay does not stop the POS business, but cod (C.O.D.) business. POS refers to the offline receipt, and recently stopped the two-dimensional code payment, is not part of the third party to allow the operation of the scope of payment licences. If the two-dimensional code payment is difficult to determine the line or offline, then Alipay's goods to pay POS machine is absolutely no doubt offline business. According to the March 2012 press release, Alipay invested 500 million yuan to promote the Electronic Business cod system, the entire line involved in the delivery of goods to pay market. Unlike a rapidly-halted two-dimensional code payment, the more pronounced cod business has remained low-key, and the official microblog announcement was halted more than a year later. Obviously, the reason for the microblog is that UnionPay.

Payment, need network to settle. Banks ' own bank cards can be settled through their own network, but the bank cards and POS machines from different agencies need a trans-bank network to settle them, so that bank cards of the banks may be paid to the POS of Bank B. This network is not easy to build, a bank and B bank does not allow direct pull root cable to each other, either through the People's Bank of the size of the trading system, or through the UnionPay system. Because Alipay as a third-party payment can be directly connected to each bank, so do not need a bank or UnionPay network, they can be settled. The only trouble is that some small banks do not have access to Alipay, so they need to borrow the bank's interface, bypass the people or UnionPay network to complete the payment.

Alipay will make UnionPay mad, not because robbed the business of POS, but to build a network of parallel settlement with UnionPay. Alipay does not have access to the network of UnionPay, it is natural that Alipay's cod business will also be settled through its own network. Alipay POS Machine Print out the line number is 999, which is not in the UnionPay network of institutions. There is no accurate news for UnionPay's punishment of Shanghai Bank's debit and credit agency number, but a reasonable assumption is that, because Alipay is paid less than UnionPay, it still needs to use the bank's interface for UnionPay network transaction. So, Alipay is not just and UnionPay business market, but want to bypass the root of the UnionPay settlement network, this direct digging competition for the foundation of the behavior, I am afraid there is no reason to ask the other party again to speak of the moral, can only desperate counterattack. Can analogy example has, moved the Penguin QQ Foundation 3Q War, as well as the payment treasure shielding micro-letter merchant and the micro-letter shielding Taobao outside the chain-we do not have the reason to request the micro-letter no longer to limit Taobao, also does not have the reason to request Alipay to continue to support the micro-trust

In a more recent step, does UnionPay have a network of POS under the monopoly line? From the beginning of the establishment of UnionPay, there is a monopoly. More than 10 years ago, it would be impossible to swipe a credit card to find a corresponding bank's POS machine, because banks are not allowed to settle each other directly. The establishment of UnionPay in the process, but also tested the banks directly linked to the central clearing, but the final solution is still a unified access to the UnionPay network. But that does not mean the central bank will necessarily favour UnionPay. On June 28, 2013, about two months before Alipay's own stop on cod business, the People's bank abolished and invalidated a batch of documents that were very favourable to UnionPay, and was seen as breaking the start of the UnionPay monopoly. The names of these five documents are as follows:

1. Notice of the People's Bank of China on the unification of the "UnionPay" logo and its holographic anti-counterfeiting mark (silver (2001)57);

2. Notice of the People's Bank of China on issuing < bank card networking Joint Business Specification > (silver (2001)76);

3. Guidelines of the People's Bank of China on standardizing and promoting the market development of bank cards (silver (2005)153);

4. Notice of the People's Bank of China on the issuance of the <2001 on the implementation of the joint work on bank card networking ((2001)37);

5. Notice of the People's Bank of China on further work on the networking of bank cards (silver (2003)129).

Even if you look at the file name, you can feel how good these files are for UnionPay. So the second regulatory turmoil began and ended very oddly. If the central bank is to be backed by UnionPay, as it did in 2014, it would have no reason to abolish a batch of documents that would be good for unionpay two months in advance. If it is UnionPay's own shot, but also only to access their own network of institutions to make restrictions, in addition to calling on regulatory authorities to stop Alipay violations, and there is no good way to deal with the original did not have access to pay Alipay network. Therefore, similar to the pressure of the previous third party to pay the licence, the regulator became "well-known" but no one knows the secret, so much so that Alipay is under the supervision of the Government, rather than a shield to help Alipay.

Third regulatory turmoil: Virtual credit cards and two-dimensional code payments

In the March 2014 regulatory turmoil, in fact, at the same time is three things: virtual credit card, offline two-dimensional code payment, limit third-party payment of transfers and consumption of the draft.

The problem with virtual credit cards is the lightest. Although Alipay and Tencent have cooperated with Citic, the two third-party payment companies seem to have completely forgotten that their authorities are the People's bank, only to have CITIC Bank make a credit card product for the CBRC. Now it seems that the possibility of the first release of the virtual credit card is very high. By contrast, Beijing-East Finance, a virtual credit card-like consumer finance business, began operating in January 2014 and has so far not been halted by any regulatory authority.

Two-dimensional code payment is the key to this call. Compared with the Alipay POS machine in the second regulation storm, the core problem is that the third party pays the enterprise to reach the offline receipts business. Just this Alipay and Tencent jointly promote two-dimensional code payment, momentum and strength is far from the year Alipay to promote cod business comparable, let originally will pay divided into online and offline central bank unprepared. For China, which is at a critical stage of financial reform, financial regulation remains rigid and prudent, and even if the amount of small innovations such as cod had been tolerated, it would never have left a radical line on overall reform. What's more, China's internet industry, which has always been modelled on foreign models, has suddenly surpassed other developed countries in the small area of internet finance, and it is natural that the rapid pace of development has led to more cautious regulation, both in terms of total trading and trading patterns.

In addition, while the central bank halted the two third party payment operations, there were two draft drafts that became hot news in a bizarre way. According to Mr Ma in 2011, "What entrepreneurs have to do is to make the effort before Dafa is released, but it is our duty to post the law of holiness." "However, the two documents issued to a third party payment company on March 11 and completed on March 13 have also become hot news in the afternoon of March 14." By contrast, the central bank's moratorium on virtual credit cards and two-dimensional code payments was issued to the People's Bank of Hangzhou Central Branch on March 13, and the contents of the document were exposed by the media and quickly became hot in the morning of March 14. Even more strangely, all the discussions about the document were based on documents issued to Hangzhou by the central bank, while documents sent to Shenzhen to stop micro-credit cards and two-dimensional payments were never seen.

As the two drafts that had already been sent to the third party were dragged until the afternoon of March 14, the contents of the limits on payments and transfers were mixed with the suspended documents, prompting many to think that the central bank would stop the balance treasure, triggering a stronger public backlash. More interesting is Alipay and Tencent's feedback. Since the balance treasure's purchase, redemption and transfer to the bank card is through Alipay's own settlement network, so if the two draft implementation, will certainly be subject to the enormous impact of the quota. However, the third party branch in this industry, the ability to establish an independent settlement network only Alipay, even the second Tencent Tenpay can not do completely around the bank and UnionPay two settlement network. By contrast, while relying on Tenpay as a background, the Tenpay has no ability to build a comprehensive settlement network like Alipay, which requires other settlement networks instead of being affected by the bill. In this respect, Tenpay's official statement is, "the opinion draft limits is the third party account payment and the transfer amount, the user in the financial management through platform buys the fund, is uses the bank card to pay directly, the Redemption Fund is through the bank card directly to present." "Tenpay, the second-most-ranked market, has more than 200 third-party payment companies that are less able to build their own settlement networks."

So, in the third regulatory turmoil, although everyone is defending a third party to pay for the industry, the beneficiaries of the defense are probably mainly Alipay.

As above, if the three supervision of the Storm Review and analysis, the viewer does not justify a stick to the central bank: said the central bank is not tolerant of innovation, not to mention that the suspension of the content is still a lot of room for discussion, the draft is not a short-term request to implement. There is no real concern about the sequence and steps of reform, but it is only in the form of certain articles that create news hotspots. Of course, it's understandable to think of a different position--a game between Alipay and the regulators.

To sum up, internet finance in China by leaps and bounds of development to now, regulation has become a topic around the past. Trying to be unregulated is absolutely impossible, and the only thing to discuss is the scope of regulation and the intensity of regulation. The internet industry is born with a winner-take-all characteristics, Alipay's mobile payment of the world's first, the scale of the balance treasure among the world's top ten funds, behind the valuation of more than billions of dollars above the Alibaba. Alibaba and Tencent are no longer small institutions, their behavior will have a negligible impact on the total market, such as the Chinese New year before and after the taxi subsidy. The greater the capacity, the greater the responsibility, when Alipay the giant into the financial industry, not only not to the identity of innovators to seek tolerance, but also should be more stringent regulation, trying to rely on a third party to pay a licence to kill personal financial business is not feasible. Under the realistic conditions of sub-industry supervision, financial market reform must be cautious, especially the business boundaries of financial institutions must be clear. Commercial banks cannot immediately open up mixed operations, and third parties pay no justification for automatic upgrades to super licences that can cover all personal financial businesses. Outside the financial core of commercial banks, Alipay and other internet giants involved in finance are also likely to cause global financial risks.

Back to the original question, the defeat of Ma is the technology, or documents? From the payment of treasure misses even said unclear source of the three regulatory turmoil, the document has not become the development of Alipay. On the contrary, the path choice of the development of the financial business and the game mode of the supervision Department are the key technical problems affecting the future fate of Alipay.