To meet the challenge of electronic money, the European Central Bank
proposes extensive regulation, including:
"i) issuers of electronic money must be subject to prudential supervision;
ii)electronic money schemes must have solid and transparent legal arrangements; …
v) electronic money schemes must supply the central bank with whatever information may be required for the purpose of monetary policy;
vi) issuers of electronic money must be legally obliged to redeem it at par value; and
vii)the possibility must exist for the ECB to impose reserve requirements on all
issuers of electronic money." [European Central Bank, 2000]
This, of course, does not deal with the problems raised by issuers outside its
jurisdiction. It is possible that issuers domiciled where there is less severe regulation,
particularly an absence of reserve requirements, might have a competitive advantage
over those regulated by the ECB.
However, it is also possible that the effect of regulation, and particularly deposit insurance, on the acceptability of e-money might offset such an advantage. In any case, the acceptability of non-bank issued electronic money will depend partly on users' perception of the financial stability of the issuer. At this point, data to judge that may not be easily available to the ordinary user. I inquired of PayPal whether they provided audited financial statements. The response to the inquiry was: "Thank you for contacting PayPal. PayPal do not [sic] provide any type of financial statement." Perusal of their statements filed with the SEC in preparation for their public offering suggested why they would not disclose them on request. Common equity was a negative $186 million as of September 30, 2001. While this was offset by preferred stock, it would likely prove disconcerting to users. On the other hand, this unease might not have a significant impact currently since the average user's account is under $20. However, for consumers and merchants to carry balances to facilitate larger transactions would seem to require greater transparency and confidence by users.