Thursday, April 8, 2021

Pakistan State Bank Governor on Fintech, Digital Currency and Stripe

State Bank of Pakistan is studying the issuance of central bank digital currency (CBDC), according to the country's central bank chief Dr. Reza Baqir. Recognizing Pakistan's growth potential, the San Francisco-based Stripe, valued at $95 billion, has recently invested in Safepay, a fintech startup in Karachi, Pakistan. Dr. Baqir spoke of both of these developments in an interview with CNN's Julia Chatterly. 

Central Bank Digital Currency (CBDC):

China's central bank is testing its digital currency in several major Chinese cities. The chairman of the US Federal Reserve has recently confirmed that the US Central Bank is working on digital dollar. The State Bank of Pakistan announced in 2019 that it was developing a digital currency. It seems that the popularity of Bitcoin has triggered serious worries of loss of control of the official financial systems among the central bankers around the world. China's substantial lead in digital currency could put it far ahead of the US in the future of global payments and financial settlement. It could eventually displace the US dollar and provide China with the immense global financial power that the US currently enjoys. 

Dr. Reza Baqir has recently confirmed to CNN what a top official of the State Bank of Pakistan, the nation's central bank, announced in April 2019: the institution aims to issue a digital currency (Central Bank Digital Currency or CBDC) by 2025.  Speaking at the launch of regulations of Electronic Money Institutions (EMIs), central bank officials said in 2019 that EMIs will be non-bank entities to be licensed by the central bank to issue e-money for the purpose of digital payments. Pakistan's finance minister Asad Umar and the central bankers said they are targeting Pakistan's economy to go fully digital by 2030. Here's what Governor Reza Baqir told CNN's Julia Chatterly:

“The benefit for us is twofold: Not only does [potential CBDC issuance] give another boost to our efforts for financial inclusion but, second, if the central bank issues a digital currency, it allows us to make further progress in our fight towards Anti-Money Laundering, towards countering terrorism financing. So, we are at a stage where we are studying it. We hope to be able to make an announcement on that in the coming months.” 

More recently, the State Bank of Pakistan launched Raast, a digital payment system.  It is essentially a pipe that is intended to connect government and financial institutions with consumers and merchants with each other to process payments instantly at very low cost. Raast will be boosted by Pakistan government's decision to use it to pay salaries, pensions and pay welfare recipients under Benazir Income Support and Ehsaas Emergency Cash programs. 

Stripe's Entry in Pakistan:

Stripe, a San Francisco fintech firm valued $95 billion, announced last month that it is entering the Pakistan market with an investment in Karachi-based Pakistani startup Safepay. Founders Ziyad Parekh and Raza Naqvi told Rest of World that they were taken aback by the interest from fellow Y Combinator alumni Stripe. “We were not expecting it and were really intrigued, as they have been a huge inspiration for us,” said Naqvi.“They (Stripe’s founders) understand that partnering up with people who are ambitious and want to tackle a problem is a much better way to enter a market than kind of going in there without any context,” he added. “At a founder-to-founder level, we spoke, and they understood what our vision was.”  

The State Bank of Pakistan recently launched Raast, a digital payment infrastructure that represents a great leap forward for the use of financial technology (FinTech) and financial inclusion in the  country.  It will also promote e-commerce in Pakistan. Undocumented economy poses a serious threat to the country because it creates opportunities for criminal activities and tax evasion.  Raast is part of the government's effort to modernize payment systems and document the nation's cash-based informal economy. 

Pakistan's Potential:

Pakistan is the world's 5th largest population with young demographics offering tremendous growth opportunity. Broadband subscriptions in the country have soared from 2 million in 2012 to 100 million now, according to the nation's telecommunications regulator. Ookla, recognized globally for its broadband speed testing, reports that Pakistan's average broadband download speed is 11.35 Mbps, while its upload speed stands at 10.7 Mbps. Thousands of kilometers of new fiber optic cable is being installed and mobile data usage in Pakistan has recently surged to 8,000 petabytes. Smartphone sales are also swelling. All signs are pointing to Digital Pakistan becoming reality in the near future. 

Pakistan's economy is overwhelmingly cash-based. More than half the population is unbanked. It offers a great untapped market for financial technology firms. Pakistan is also promoting digital payments to enhance financial inclusion and document the economy. Eliminating  interbank digital transaction fees during the covid pandemic has resulted in 100%-200% jump in such transactions.  

Summary:

Speaking with CNN"s Julia Chatterly, the State Bank of Pakistan Governor Reza Baqar said the Pakistani government is currently studying the idea of issuing central bank digital currency (CBDC). China is showing Pakistan the way with its CBDC. There will be an announcement on the country's CBDC in the next several months. Because CBDC is issued by the central bank, it can help the country fight crime and corruption. Pakistan is also promoting digital payments to enhance financial inclusion and document the economy. Eliminating digital payment fees during the covid pandemic has resulted in 100%-200% jump in such transactions. He said fintech companies and digital payment processors like Stripe are welcome to operate in Pakistan. It has the world's 5th largest population with young demographics offering tremendous growth opportunity.


Here's a brief video of Dr. Reza Baqir's CNN interview with Julia Chatterly:

https://youtu.be/BZ8MAi-_Qb4

9 comments:

Mayraj F. said...

The Chinese government has begun to issue blockchain-powered digital currency to its citizens. The Wall Street Journal reports that 750,000 recipients have been determined by a lottery system and can already spend their digital Yuan in stores and online using a special app.

App-based payments are already very common in Chinese brick-and-mortar businesses, so merchants were quick to adapt to the government’s new offer. Starbucks and McDonald’s are reportedly among those already accepting the digital Yuan, as is the Chinese Communist Party.

Ubiquitous digital payments and tight government surveillance have led to a plethora of payment data already available to Chinese administrators. This knowledge on how people spend money will only grow with the implementation of the digital Yuan, even though the country’s Central Bank has said it will limit traceability and create what it calls “controllable anonymity.” With the launch of the digital currency, every Yuan in circulation will either exist as physical or as digital currency. Analysts expect the Chinese government to raise the amount of digital currency in the future, thereby lowering the amount of physical currency available in the market. Some even think China plans to make all Yuan digital at one point.

China is only the second country and the first major economy to officially launch a blockchain version of its own currency. According to Bloomberg, the sand dollar of the Bahamas Central Bank launched last year and was already being accepted in stores in the capital Nassau. Bloomberg identifies four more countries – South Africa, India, Pakistan and Thailand, with concrete plans to launch their own official cryptocurrencies soon. Like some other phone payments, official blockchain currencies have the ability to reach the unbanked, making them interesting for the developing world.


https://thewire.in/world/china-becomes-first-major-economy-to-issue-digital-currency

Riaz Haq said...

Pakistan’s central bank exploring its own digital coin: Reza Baqir

https://nation.com.pk/09-Apr-2021/pakistan-s-central-bank-exploring-its-own-digital-coin-reza-baqir

Pakistan’s central bank is exploring its own digital coin, the Governor, State Bank of Pakistan Reza Baqir revealed in an interview on Thursday after China became the first major economy in the world to create its own digital currency.

Expressing his views on a central bank-issued digital currency, Baqir said, "we are at a stage where we are studying it. We hope to be able to make some announcement on that in the coming months.”

The SBP governor told that they have allowed a framework for digital banks to begin their operations in Pakistan. These are the banks, which don’t have a brick and mortar presence and are purely digital like challenger banks or neo banks.

The SBP governor said they are studying it (SBP’s own digital currency) as some countries such as China are already showing the way it benefits central banks.


It will not only boost the central bank efforts for financial inclusion but also allow it to make progress in its fight towards anti-money laundering and countering terrorism financing, he added.

Baqir didn’t share any details about the SBP’s own digital currency, but he said Pakistan is open to digital innovation.

“Stripe and other big payment providers are very welcome in Pakistan. It’s a market that’s waiting to burst as far as digitization is concerned,” the governor said while responding to a question on Fintechs.

Explaining he said when the SBP eliminated the IBFT fee in response to the Covid-19 pandemic, its impact was phenomenal. “For the quarter that ended in December, we had a growth of about 150% to 200% compared to a year ago on mobile banking transactions. For internet banking transactions that number is around a 100% to 150% growth.”

Pakistan is a market that is home to the fifth-largest concentration of people. They are young and tech-savvy that are very fertile for such digital innovation, he added.


Earlier this week, China created its own digital currency, a cyber yuan, which is controlled by its central bank that will issue this virtual money.

Riaz Haq said...

Pakistan: Central Depository Company (CDC) and National Institutional Facilitation Technologies (NIFT) signed an agreement to enable digital payments through NIFT ePay.

https://nation.com.pk/08-Apr-2021/cdc-signs-agreement-with-nift-to-enable-digital-payments

CDC is recognised as the infrastructure backbone of Pakistan’s capital market and it is the sole securities depository in the country, while NIFT is one of the largest payment processors in Pakistan.

This collaboration will enable the investors to use NIFT ePay services for investing into Mutual Funds using CDC’s digital platform” “Emlaak Financials.” Furthermore, the solution will also be facilitating CDC’s IAS account holders to make IAS payments through CDC Access portal.

The agreement was signed by NIFT’s CEO Haider Wahab, and CDC’s CEO Badiuddin Akber at the CDC’s head office.

NIFT’s CEO stated, “We are delighted to be a part of CDC’s newly launched initiative for the Mutual Fund Industry. We understand that the “Emlaak Financials” platform has an aspiring roadmap, and we look forward to playing our role in enabling the platform and in making this service a success. NIFT will always focus to partner for unique and innovative ideas which will uplift the digital transformation in Pakistan.”

At the signing ceremony, CDC’s CEO Badiuddin Akber said, “As we embark on this collaboration with NIFT, it gives us immense pride that we are engaging NIFT’s payment gateway for the first of its kind mutual fund aggregator platform , being launched in the financial landscape of Pakistan. The launch of this platform and its integration with NIFT’s services to enable secure and swift payments for mutual fund investors is in-line with CDC’s vision of enhancing efficiency and ease of doing business.”

Riaz Haq said...

Pakistan ready to adopt digital financial solutions on large scale, says Easypaisa CEO


https://nation.com.pk/06-Apr-2021/pakistan-ready-to-adopt-digital-financial-solutions-on-large-scale-says-easypaisa-ceo


“Pakistan is rapidly progressing when it comes to mobile broadband. Our country has enormous potential with respect to widening financial inclusion through digital solutions. Currently, 95 million people across the country use mobile broadband, a number which has grown by 50 million in the past 5 years. A majority of adults have broadband connections in Pakistan serving as a backbone to developing a digital payments ecosystem in the country.” said M. Mudassar Aqil, CEO Easypaisa/Telenor Microfinance Bank, while talking about Pakistan’s financial services landscape.

“96% individuals have a biometrically verifiable ID issued by the government, indicating that a robust regulatory framework is in place which is supported by credit bureaus. Despite these fundamental factors, 70% of Pakistanis don’t have access to financial services when the rails to address these challenges are in place,” he added. During COVID-19, digital payments witnessed a boom. According to the SBP’s quarterly report, 296.7 million e-banking transactions, valuing at PKR21.4 trillion, were carried out during Oct – Dec 2020, growing by 24% in volume and 22% in value compared to the same quarter last year.

“During COVID-19 industry numbers of digital transactions grew at an exponential rate. At Easypaisa, our annual throughput increased by 64% as compared to the previous year reaching PKR 1.5 trillion in 2020. Similarly, the number of active Easypaisa App users reached 3.44 million, registering a 54% increase in comparison to previous year.” he commented. Pakistan is predominantly a cash-based economy. However, things are changing as the use of digital payments is taking center-stage.

Mudassar opined: “The Pakistani economy is ready to adopt digital financial solutions on a large scale as opening a mobile wallet account on a smartphone or feature phone takes less than a minute. Roughly PKR 6 trillion or about one-third of the country’s deposits are in circulation. This is one of the highest percentages anywhere in the world and the only way to reduce this is for every adult in the country to have a mobile wallet. Furthermore, all retail outlets in Pakistan should be mandated by law to accept digital payments from mobile wallets. Tax incentives should also be introduced making digital payments cheaper than cash.”

Riaz Haq said...

China is now applying calculated doses of pain to shock Westerners into realizing the old, #American-led order is ending. #Chinese foreign policy chief lectured American diplomats in #Alaska. Then #China sanctioned #British, #Canadian & #EU politicians https://www.economist.com/china/2021/04/03/china-is-betting-that-the-west-is-in-irreversible-decline

Its gaze fixed on the prize of becoming rich and strong, China has spent the past 40 years as a risk-averse bully. Quick to inflict pain on smaller powers, it has been more cautious around any country capable of punching back. Recently, however, China’s risk calculations have seemed to change. First Yang Jiechi, the Communist Party’s foreign-policy chief, lectured American diplomats at a bilateral meeting in Alaska, pointing out the failings of American democracy. That earned him hero status back home. Then China imposed sanctions on British, Canadian and European Union politicians, diplomats, academics, lawyers and democracy campaigners. Those sweeping curbs were in retaliation for narrower Western sanctions targeting officials accused of repressing Muslims in the north-western region of Xinjiang.

China’s foreign ministry declares that horrors such as the Atlantic slave trade, colonialism and the Holocaust, as well as the deaths of so many Americans and Europeans from covid-19, should make Western governments ashamed to question China’s record on human rights. Most recently Chinese diplomats and propagandists have denounced as “lies and disinformation” reports that coerced labour is used to pick or process cotton in Xinjiang. They have praised fellow citizens for boycotting foreign brands that decline to use cotton from that region. Still others have sought to prove their zeal by hurling Maoist-era abuse. A Chinese consul-general tweeted that Canada’s prime minister was “a running dog of the us”.

Such performance-nationalism is watched by Western diplomats in Beijing with dismay. Envoys have been summoned for late-night scoldings by Chinese officials, to be informed that this is not the China of 120 years ago when foreign armies and gunboats forced the country’s last, tottering imperial dynasty to open the country wider to outsiders. Some diplomats talk of living through a turning-point in Chinese foreign policy. History buffs debate whether the moment more closely resembles the rise of an angry, revisionist Japan in the 1930s, or that of Germany when steely ambition led it to war in 1914. A veteran diplomat bleakly suggests that China’s rulers view the West as ill-disciplined, weak and venal, and are seeking to bring it to heel, like a dog.

In Washington and other capitals it is not hard to hear voices suggesting that China is making rash, clumsy mistakes. Surely China sees that it is souring public opinion across the West, they murmur. There is puzzlement about how China now views its recent draft accord with the European Union, the Comprehensive Investment Agreement, which it had appeared so eager to conclude. That pact’s ratification by the European Parliament is now on ice, and possibly entombed in permafrost, as a result of China’s sanctions on several Euro-legislators.

Riaz Haq said...

Globally, the value of all outstanding cryptocurrency has jumped to about $2.4 trillion — or more than the approximately $1.2 trillion of United States currency in circulation worldwide — from about $200 billion two years ago.

https://www.nytimes.com/2021/05/09/us/politics/cryptocurrency-regulation-sec-ripple-labs.html


As Scrutiny of Cryptocurrency Grows, the Industry Turns to K Street
Companies behind digital currencies are rushing to hire well-connected lobbyists, lawyers and consultants as the battle over how to regulate them intensifies.

When federal regulators late last year accused one of the world’s most popular cryptocurrency platforms of illegally selling $1.38 billion worth of digital money to investors, it was a pivotal moment in efforts to crack down on a fast-growing market — and in the still-nascent industry’s willingness to dive deeply into the Washington influence game.

The company, Ripple Labs, has enlisted lobbyists, lawyers and other well-connected advocates to make its case to the Securities and Exchange Commission and beyond in one of the first big legal battles over what limits and requirements the government should set for trading and using digital currency.

Ripple has hired two lobbying firms in the past three months. It has retained a consulting firm staffed with former aides to both Hillary Clinton and former President Donald J. Trump to help it develop strategy in Washington. And to defend itself against the S.E.C., it hired Mary Jo White, a former chairwoman of the commission during the Obama administration.

Ripple is just one of a long list of cryptocurrency companies scrambling for influence in Washington as the Biden administration begins setting policy that could shape the course of a potentially revolutionary industry that is rapidly moving into the mainstream and drawing intensifying attention from financial regulators, law enforcement officials and lawmakers.

“There is a tectonic shift underway,” Perianne Boring, the president of the Chamber of Digital Commerce, a cryptocurrency lobbying group, told other industry lobbyists, executives and two House lawmakers who serve as industry champions, during a virtual gathering last month. “If we don’t start planning and taking action soon, we have everything to risk.”

So far, cryptocurrency has been a highly volatile investment, but it is already starting to alter the way individuals, companies and even some central banks do business. Firms like Ripple, which is based in San Francisco, run cryptocurrency platforms that allow customers to make nearly instant global payments through a system that operates largely outside government monetary networks.

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The House this month passed a bill backed by industry lobbyists to create a working group of federal regulators, industry executives, investor protection groups and others to examine possible frameworks for a regulatory system.

“We need to get the big prize done,” Representative Darren Soto, Democrat of Florida and a member of the Congressional Blockchain Caucus, a group of lawmakers working with the industry to help promote cryptocurrencies, told the industry conference last month. “Which is the statutes and jurisdiction and definitions to create that certainty, to really let blockchain and cryptocurrency flow and improve in the United States.”

Riaz Haq said...

Pakistan to bring #cryptocurrency out of the dark. Pak has had a boom in trading & mining it. Pak govt has set up a committee to study cryptocurrency #regulation, which includes observers from #FATF, federal ministers & country's #intelligence agencies. https://www.reuters.com/technology/pakistan-moves-bring-cryptocurrency-boom-out-dark-2021-07-16/

Once a week Ghulam Ahmed, 38, takes time out from his cryptocurrency consulting business to log into a WhatsApp group with hundreds of members eager to learn how to mine and trade cryptocurrency in Pakistan.

From housewives looking to earn a side income to wealthy investors wanting to buy cryptomining hardware, many barely understand traditional stock markets but all are eager to cash in.

"When I open the session for questions, there's a flood of messages, and I spend hours answering them, teaching them basic things about cryptocurrency," said Ahmed, 38, who quit his job in 2014, believing it was more profitable to mine Bitcoin.

------------

"Half the members had no clue what it was and didn't even want to understand it," said committee member Ali Farid Khwaja, a partner at Oxford Frontier Capital and chairman of KASB Securities, a stock brokerage in Karachi. "But the good thing is someone set up this committee. The relevant bodies in the government who need to get things done are supporting it, and the promising thing is nobody wants to stand in the way of technical innovation."

The head of the country's central bank, Reza Baqir, said in April the authority was studying cryptocurrencies and their potential for bringing transactions happening off the books into a regulatory framework. "We hope to be able to make some announcement on that in the coming months," he told CNN. Baqir declined to comment to Reuters on the topic.

Even the education sector has caught on.

In February, one of the country's leading universities, the Lahore University of Management Sciences, received a grant worth $4.1 million to study the technology from Stacks, a blockchain network that connects Bitcoin to apps and smart contracts.

LEGALISATION AND INVESTMENT

These moves can't come soon enough for cryptocurrency advocates.

Institutions have at times treated those involved in the trade of cryptocurrency with suspicion, worried about possible associations with money laundering.

Ahmed said he has been arrested by the Federal Investigation Agency (FIA) and charged with money laundering and electronic fraud twice, though the charges have not held up in court.

On one occasion, he said, the FIA seized a cryptocurrency mining farm he had set up in Shangla, in Pakistan's northern Khyber-Pakhtunkhwa province, which ran on its own hydroelectric power. The FIA did not respond to Reuters' request for comment.

Waqar Zaka, a former TV host with more than a million followers on Youtube, has been lobbying officials for years to not only legalise the industry, but have the government invest in it. Zaka, like Ahmed, had set up a cryptocurrency mining farm running on hydroelectric power.

Now, Khyber-Pakhtunkhwa's provincial government has tapped Zaka and Ahmed to be on a committee studying how it can profit from such ventures. In March, the group announced it was looking into setting up new mining farms using Zaka's facility as a template.


Riaz Haq said...

Riaz Haq has left a new comment on your post "Pakistani-American VC At Top Silicon Valley Firm L...":

Digital technologies are set to transform the way people live and work in Pakistan. As we saw in the GSMA 2020 Digital Societies Report, which tracks the progress of 11 focus countries in Asia Pacific, Pakistan is advancing its societal, economic and digital ambition, as outlined in Digital Pakistan Vision. Indeed, our report’s digital society index tracked Pakistan in achieving one of the highest increases in its overall score.

https://dailytimes.com.pk/798868/pakistans-digital-transformation-2/


By 2023, the economic contribution of the mobile industry in Pakistan is expected to reach $24 billion, accounting for 6.6% of GDP .In an effort to stimulate this growth, Pakistan has recently moved forward with significant mobile services tax reforms.

Digital platforms, such as mobile services, have become the primary channel for a growing number of citizens to access public and private services, especially during the pandemic. Behind this development are the vital roles played by National and provincial policymakers, the Pakistan Telecommunication Authority (PTA) and Ministry of Information Technology and Telecommunication (MoITT), who have helped increase access for citizens high-quality connectivity and digital services. This has cultivated digital inclusion, e-commerce and a general entrepreneurial spirit for the people of Pakistan.

With a population of approximately 220 million, and more than 100 million people under the age of 25, Pakistan is well positioned to play a growing role in the global economy over the next decade.Pakistan’s mobile market has experienced rapid development over the last decade, playing a significant role in Pakistan’s growth. In 2018, the total economic contribution of the mobile ecosystem was worth $16.7 billion, equivalent to 5.4% of GDP.

In a post pandemic world, Industry 4.0 – otherwise known as the fourth industrial revolution – will help economies recover and become more resilient to future shocks. And technology, supported by mobile networks, will be at the core of Pakistan’s industrial development as it works to launch the fourth industrial revolution.

Pakistan’s recent policy actions offers a glimpse of this potential. But authorities must act together, creating the business environment necessary to realise these goals. A whole-of-government (WGA) approach will ensure better coordination of digital transformation initiatives across the public sector, complemented by private sector investment and innovation. We believe this holistic approach is a way for emerging and transition digital societies to leapfrog bureaucratic pain points.

Riaz Haq said...

Digital technologies are set to transform the way people live and work in Pakistan. As we saw in the GSMA 2020 Digital Societies Report, which tracks the progress of 11 focus countries in Asia Pacific, Pakistan is advancing its societal, economic and digital ambition, as outlined in Digital Pakistan Vision. Indeed, our report’s digital society index tracked Pakistan in achieving one of the highest increases in its overall score.

https://dailytimes.com.pk/798868/pakistans-digital-transformation-2/


A whole of government approach in Pakistan creates the start of a predictable investment and flexible regulatory environment. These measures, needed to achieve the goals of Digital Pakistan, include tax reforms as well as efforts to implement Right-of-Way (RoW) infrastructure policies. The success of these efforts will be measured by their implementation, along with the growth they support in the future.

Implementing tax reforms for industry growth and infrastructure policy Pakistan recently approved tax reforms that will stimulate mobile industry growth. These include gradually reducing Advance Income Tax from 12.5% to 10% in the next financial bill (FY2021-22); further reducing to 8% in the 2022-23 Finance Bill; approval of harmonization /uniform rate of taxes on telecom service; withdrawal of SIM issue tax; simplification of and exemptions for withholding tax to ease doing business; reduction of minimum tax for telecom services from 8 to 3%.

In order to fully realise the benefits of these tax recommendations, the Financial Bill (FY 2021-22) must be enacted into law. Similarly, we recommend policy makers implement Right of Way (RoW)and other policies that impact the infrastructure supporting digital and mobile access. Recently, a significant milestone was reached when policy makers in Pakistan approved, for the first time, RoW infrastructure policy. We commend this move and urge that these policies are implemented quickly. As technology evolves, unforeseen challenges can arise that may not have occurred to policy makers during their inception.

Spectrum roadmap and digital inclusion

Along with these crucial policies and regulatory modernisation initiatives, there are additional steps needed as Pakistan continues to build itself into a digital society. In particular, the development and implementation of a five-to-seven-year spectrum roadmap. Spectrum is the foundation for mobile services. Sufficient spectrum allows mobile networks to reach even more citizens in Pakistan and offer a better quality of service.

Digital Pakistan also includes digital inclusion as one of its policy objectives. Currently, it has a 54% mobile broadband usage gap , as defined by people who live within the footprint of a mobile broadband network but do not use mobile internet. A spectrum roadmap provides stability and certainty as it helps to create a more investment-friendly environment for mobile operators looking to build 5G and 4G mobile networks.



Industry and government stakeholders

A holistic, whole-of-Government approach speeds digitization and the adoption of new technologies in a more efficient manner. By removing barriers caused by siloed efforts from different ministries, Pakistan could more efficiently harness the capabilities of its existing 4G networks, while preparing for 5G. Another key piece in the digitization effort will be the solicitation of input from industry stakeholders. A transparent consultation process that offers parties the ability to submit thoughtful input has the potential to lead to an enabling regulatory framework primed for new technologies.