[Editor's note: When it comes to payment the industry landscape is highly intransparent. The payment landscape is already very intransparent as it is, but regulations that directly or indirectly effect the industry are making the situation even worse. In his guest post, Atlas Interactive CEO and DTVM Board Member Marco Priewe explains how the dialogue between industry and government works, who is participating in it and how you can participate or gain advantages out of it.]
The association and the mission
In Germany, the association to represent interests of payment, gaming and media is the DTVM. DVTM stands for Deutscher Verband für Telekommunikation und Medien – German Association for Telecommunications and Media. The DVTM represents all companies involved in the value-added chain of telecommunications and media: service companies, network operators, service providers, resellers, technical service companies, media and publishing companies as well as consulting companies and collection agencies. The aims are protection and expansion of the functioning, innovative and competitive telecommunication and media market in collaboration with the market participants.
Marco Priewe, DVTM Board Member and Atlas Interactive CEO
Members of the association operate voluntarily for the purpose of the Code of Conduct (Germany) for Telecommunication and Media, released by DVTM. The Code of Conduct phrases standards of telecommunication and media branches and authorizes to help shaping the market. DVTM has about 50 members including ATLAS interactive, BT (Germany), Buongiorno, Cellfish Media, Colt, digame mobile, dtms, IN-telegence, mr. next id, net mobile, RTL interactive, Venista, ZED and Siemens Enterprise Communications.
A past example of DVTM action: handshake sms regulation
There are several examples how the DVTM influences the daily landscape of gaming transaction. For example, when the telecommunication act (TKG) amendment was politically discussed some years ago, the VZBV (Federation of German Consumer Organizations) argued to have a compulsory handshake for premium SMS transaction exceeding EUR 1.00 in the amended TKG. The DVTM was the only organization that argued against this and demanded from the legislative authority to have the limited set at EUR 3.00 only. The DVTM succeeded in finally convincing the legislative to set the handshake requirement at EUR 2.00.
Today, most gaming portals using methods of mobile payment use the end user tariff of EUR 1.99 / SMS. Meaning, the end user sends a text message at a price of EUR 1.99 and by just sending this message the payment is made. Without the engagement of the DVTM the TKG would have required a hand-shake procedure. In that case the end-user, wanting to pay EUR 1.99, would have to send a text message and in return receive a SMS-MT message, informing the end user about the price and asking him to confirm the message by sending a second text message. In that case payment would only be made if the user sends this second SMS-MO.
No need to say, that this complicated hand-shake process would have a disastrous effect on the conversion rate. Most likely, gaming portals would then chose to only charge EUR 0.99 per transaction (without hand-shake requirement). Just because of the engagement of the DVTM this initiative by the VZBV was averted. This example shows how important it is that industry members engage themselves in the DVTM, as it is more likely that the DVTM is heard by the legislative instead of individual voices.
A current case: standardized mobile payment window
One of the biggest issues today revolves around regulation of mobile payment windows. The German mobile network operators have announced that a standardized payment window will be introduced in January 2012. Today, an end user that wants to initiate a payment through WEB billing is provided with a payment window by the merchant or the payment provider, e.g. ATLAS Interactive. As of 2012 this will no more be possible. All merchants using WEB billing will have to use a standardized payment window that is designed and issue by the mobile network operator. So the payment window will have a completely different look and branding. Sure, this new regulation will eliminate fraudulent applications that e.g. hide the obligatory price information in a scroll-down menu.
On the other hand we fear that the new payment window will have a negative effect on the conversation rate of end users’ payment. We are, hence, opposed to this regulation that may have negative effect on the business case of gaming portals. The DVTM will try to intervene and start the dialogue with the mobile network operators. They need to understand that they have easier possibilities to eliminate fraudulent applications. We do not see a need to put the entire industry using mobile payments at a threat. Any game publisher or distributor may join the DVTM to help us in this initiative.
Benefits for small companies
Most of the companies do not have a big legal department, for them it is interesting to have contact person at DVTM. They can get regular as well as individual information about legislation and regulation and can place their own themes. At the same time they can benefit from the communication inside the association and with other members. But also companies with a quite big legal department are not that close to new legislation and the regulatory bodies as the DVTM. To influence the legal framework, there is a lot of lobby work to be done. It is of existential importance that the interests of companies have a strong and active representation.
Balance of interests
As Managing Director of Atlas Interactive I have a profound knowledge of the market, but as well of legislative and regulative obstacles and challenges. Together with other executives we try to find a good balance between the interests of consumers, politics and economy. The German Code for Telecommunication and Media (issued by the DVTM) is the best example to proof, that the economy accepts responsibility for consumer protection. The code of conduct, direct information at first hand and the communication with other members of the DVTM is the reason why we have been an active member of the DVTM for more than 10 years.
Join the club
It is not sufficient to sit and let others do the job – engagement including political engagement is the key. We, therefore would highly appreciate if other market players, especially from the gaming industry, would join the DVTM. In a rather small association they can be sure that they will be heard and that they can place their themes. I am convinced that the DVTM will succeed in representing the interest of the gaming industry and could, hence, avoid contra productive legal regulation. Anyone interested in this, may feel free to call me to discuss opportunities.