Finding a workable m-banking model

In the wake of technological advancement and the growing need to expand microfinance facilities to un-banked areas, bankers, regulators and mobile operators are in a hot discussion these days to craft a workable model for mobile banking, or m-banking, in Pakistan.
Quite naturally, they must be studying the different types of m-banking models tried and tested elsewhere in the region and around the world. The process of selection and the decision of whether to adopt or adapt is somehow complicated, as the choices offer different set of pros and cons - requiring different regulations and policies.
Crucially, the major issue is whether the regulators would allow mobile users to open a virtual bank account (via any retail agent) tied to mobile SIMs or whether they will make it compulsory for a user to open an actual bank account first before being offered mobile banking services.
For instance, in India, the guidelines put the onus of providing mobile banking services on conventional banks and that mobile payments service providers - i.e. cellular firms - can only serve as intermediaries in providing the technology framework for such services.
A similar hybrid model - one where bank co-operate with cellular firms - is being offered in South Africa by the name of Wizzit, where the bank and the mobile operator jointly offer m-banking services.
Indeed the direct involvement of banks makes sense, given its expertise to handle money and monitoring to check money laundering, e-money risks and the protection of consumer rights. But in case of m-banking, these benefits would come at a cost of relatively lesser penetration in the unbanked areas, as most of the rural population in Pakistan lacks access to bank branches.
On the contrary, true motivation to target the un-banked market can be achieved if regulators permit the opening of a virtual bank account tied to mobile SIMs, as telecom operators can potentially have greater knowledge of actual target market owing to their vast network existing in the far flung areas.
The non-bank model has been found quite successful in Kenya and Philippine, where services like M-Pesa and G-Cash (respectively) have been offered solely by telecom operators without any sort of bank intervention.
And given Pakistans resemblance to both these countries, perhaps the non-bank model can be adaptable in Pakistan as well. Branches per hundred thousand people in Pakistan and Philippine are 7.50 and 10.53 respectively, according to Financial Access, while a 2008 UN report noted mobile density in Pakistan is 10 percent higher than Kenya, meaning that there is enough need and the potential to sow the seeds of m-banking in Pakistan.
Yet, one lesson that needs to be learnt from the non-bank Kenyan model is that telecom firms can be left unmonitored in the sphere of banking. More recently, the conventional banking industry filed a suit against M-Pesa citing that its unregulated status puts customers at risk.
In short, the Joint Regulatory Committee formed by the State Bank of Pakistan and Pakistan Telecom Authority has plenty on its plate to deal with. But, while unnecessary haste in an uncharted territory may lead to bad policies, an unnecessary delay may create an unwanted monster.
The recent launch of Money Transfer service by Telenor Pakistan and Tameer Microfinance Bank, within their suite of easypaisa, shows that the industry is going to gather pace soon. And so the regulators must step on the gas.
Perhaps, the setting up of a separate m-banking regulatory institution can be considered in this context, while asking those telecom firms that are venturing into m-banking to list themselves at the bourses for better disclosure and public accountability to help avoid the too-big-to-fail syndrome.