Thank you for joining, and welcome to Paytm's conference call to answer questions from the filing on the action of PPBL from RBI. From Paytm's management, we have with us today Mr. Vijay Shekhar Sharma, founder and CEO; Mr. Madhur Deora, President and Group CFO; Mr. Bhavesh Gupta, President and Chief Operating Officer; and Mr. Anuj Mittal, SVP, Investor Relations. A few standard announcements before we begin. The information to be presented and discussed here should not be recorded, reproduced, or distributed in any manner. Some of the statements made today may be forward-looking in nature. Actual events may differ materially from those anticipated in such forward-looking statements. Finally, this call is scheduled for 45 minutes. It'll have opening remarks by the management, followed by Q&A. During Q&A, if you seek to ask a question, kindly utilize Raise Hand feature on your Zoom dashboard. We will unmute your line and take questions in the respective sequence and within the scheduled time. For us to be able to identify you, please ensure your name is visible as your first name, last name, followed by your company name. We request participant to restrict to two questions per participant to allow more participation. Replay of this call and a transcript will be made available on the company website subsequently. With this, I would request Mr. Vijay Shekhar Sharma to kindly initiate the call. Thank you, and over to you. Thank you, everyone, for joining. Obviously, this is an important moment for all of us at Paytm and Paytm Payments Bank. We've seen the update from RBI, which was publicly released. So I have a one slide here to show the discussion that I can talk about. Actually, give me a second. Yeah. So this is the slide that talks about our compliance impact or relationship of OCL, that is Paytm, with Paytm Payments Bank Limited, and what we've learned and what we have next to be done. Important thing is that Paytm Payments Bank has received regulatory directive from RBI, and we are taking immediate steps to comply with the directions. The users of the Paytm Payments Bank can use the savings account balance, the wallet balance, and wallet balance, which is used in FASTag and NCMC, et cetera, account till February 29, and effectively, that means that they can continue to add money, et cetera, but after February 29, they cannot add incremental money to the bank account or savings account, and so on. OCL, as a payment aggregator for online/offline merchant, it already works with various other banks, and Paytm Payments Bank is one of the key banks in that. From here on, we are very clear that we will work with only other banks and not PPBL, and PPBL is just one of the various other banks any which ways. OCL has already been working with other banks since last two years, and especially when embargo had come to the payment bank, we already had started to work and accelerated the plan for movement to other banks, and other banks have actually already started working with us. So it is an important thing for me to tell you that we continue to decline and decrease the slant-wise dependency on Paytm Payments Bank, but there is still significant enough dependency, I would rather say there. And we now accelerate the plan and completely move to other payment bank partners. And remember, these are payments-related relationships, which means all banks have necessary technology and capability already there. And I'm very happy to tell you that we are genuinely overwhelmed by the support that we've received from the various banks, large banks of this country and our country, and those who are already a partner, and more additional large banks have reached out at very, very senior level to say that they will be very happy to help us and happy to execute relationships that we in past have been doing with Paytm Payments Bank. And we obviously, very clearly, we are going to take that as a step forward and work with current and many more incremental bank partners. Going forward, the keyword is that we will not work with Paytm Payments Bank, and that is what probably means that other banks will come. With regard to the direction on termination or nodal account of OCL, that is One97 Communications PPBL by Feb 29, OCL and PPBL are already in process of moving nodal account to other large commercial banks, and that will be done, definitely before the due date. OCL's marketing and financial services businesses, where we market and sell other services to the consumers, are not affected due to these directions, and these directions are towards the associate company, Paytm Payments Bank. It is important for me to point out that there will be requirement to have operational change for the merchant relationships that we have, where the merchants have relationship with Paytm Payments Bank, and those relationships need to be operationally changed, and there will be an operational change there. Overall, I can say that it is, on behalf of Paytm, I can say that it is, it is more of a big speed bump, but it is, something that we believe that with partnership of other banks and capabilities that we have already developed, we'll be able to see through in next few days or quarters as the case would be. So thank you so much, and with this, we'll take the question answers. First question is from Sachin Salgaonkar. Sachin, you may unmute your line and ask your question. ... Thank you. Vijay, I have three questions. First question, actually, can you help us understand what exactly went wrong where, I mean, for some time we were hearing from you guys that, you know, this should get resolved, this should get resolved. But when we look at some of the words being used of persistent, non-compliant, need continued material supervisory concerns, can you help us explain what is something where RBI is not fully comfortable, and what further needs to be changed from that perspective? We are in receipt of the same letter that is very public. If you would just ask all three of your questions, then we can answer it all at once. Sorry, Vijay. Okay. Yeah, that's right. Yeah. We do want to take a lot of questions, so we will suggest that, whenever you are asking questions, just put all three questions or two questions that you are asking. Got it. Okay, so that was first question. Second, Madhur, if you could help us understand how to quantify the INR 300-500 crore impact on annual EBITDA. I.e., how much is coming from revenue, how much is from EBITDA? And I presume this is for this year, right, you are looking for. And third, what Vijay mentioned in the opening remarks, the operational changes which are needed from a merchant perspective. Just wanted to understand what kind of changes are these, and how much time will it take? Okay, so I'll take the first one, Sachin. As you saw, the letter that is publicly sent there, there is another letter that bank has received. But based on that, I cannot foresee what we did not see or not see. There is obviously RBI beliefs, and we totally are believing of the fact that there is something that RBI would have seen. Have they sent us details? Answer is no, they've not sent us any details. So, something that is based on over the period, what different, different audits they would have done and their solutions based on that is the opinion that has come based on. So we don't know the exact nuance, what triggered or one line item. And then, Vijay. Mm-hmm. So, sorry. So how, what does one get a comfort that RBI should get comfortable going ahead with these changes, right? Because if you are exactly not clear, Paytm is not exactly clear in terms of where was, where RBI was not fully convinced, then, I mean, how do you look to fix those issues? Actually, the key word here is that it is in discussion with Payment Bank, and Payment Bank cannot share these facts with, let's say, parent or shareholders out there. So that's also one of the reason that we can't discuss this. This is a interaction between bank and payment bank, central bank and payment bank. Sorry, Sachin, if I can just clarify. The, the certain direction, as Vijay said earlier, the certain direction that they've given to Paytm Payments Bank with respect to their operations. If we are doing a service in partnership with Paytm Payments Bank, those services, and we'll come to your third question, would go through some operational changes and so on. But like Vijay said, going forward, we would work only with third-party banks, who don't face such issues from the RBI, and who also do provide these services to other consumer technology companies. As you may... I'm sure you're aware that, that is a pretty, standard business model in the industry, where consumer technology companies such as ours, who have a lot of app traffic, will work on payments products with, various large banks, right? In our case, we were doing, various things, with other banks, but various things also with Paytm Payments Bank, and those services, would be affected. So that's sort of the Paytm, point of view on this, about what we need to do going forward. With respect to your second question, the INR 300 crore-INR 500 crore that we mentioned is the worst case annual EBITDA impact. That does not take into account the expectation that we will be able to, you know, sort of continue all the businesses or that that are Paytm Payments Bank that we're dependent on Paytm Payments Bank for. That is primarily. There are primarily two lines of businesses that we do. One is Paytm Payments Bank has a wallet. For that wallet, we provide two services. One is that we are the app on which vast majority of customers come and add money to that wallet. On that, we make some revenue and some profitability. And the second is that we—so we are a payment provider, effectively. The second is that we also offer, as a part of our merchant services, where we provide payment services to merchants, we both online and offline, we also allow those merchants to accept Paytm Wallet. In those cases, the merchants pay us a revenue, and we pay an interchange effectively to Paytm Payments Bank. So the overall, the worst-case margin, EBITDA margin impact of that is INR 300 crore-INR 500 crore. We have called that an annual EBITDA impact. I do expect that we, over time, will be able to offset this, in a big way, but we have called that out as sort of an annual impact. Okay. Thanks, Madhur. Do you, Bhavesh, did you want to take the third question that Sachin asked? Sure. So, Sachin, the operationalization piece is, means two things, basically. So when you are a merchant, you have, and it's an offline and online merchant conversation, so I'll take both of them. But let's start with the offline merchant, where you see a Paytm QR, which is powered by Paytm Payments Bank, right? Now, that QR has a VPA, a virtual payment address, of the Paytm Payments Bank, so now that QR will have to be changed. The VPA will have to be changed to any other sponsor bank, and we have multiple sponsor banks anyway, work with us, large sponsor banks who anyways work with us. While we used to predominantly work in the offline space- ... with Paytm Payments Bank, but in large enterprise and online space, we work with other, other, other operators in the, in the UPI space, et cetera. So when we say operational indifference, we basically now have to work in making sure that the VPA is, is, changed to another bank. We have multiple options of the banks that we are currently in conversation with. We'll obviously conclude one bank, two bank, or, or a large number of bank, to make sure that we are able to do this exercise. This will be a large exercise, so it will be split into two parts. One, there is, a new acquisition, which is much easier, that the new acquisition can immediately start to happen on other bank VPAs. So we decide. So that decision will take in the next maybe a week or so, because there'll be some commercial involvement, et cetera. We have proposals to that regard, already in the system, so we are evaluating them appropriately. Then there will be, how do we move the existing merchants, who are accepting on UPI, to any other bank or banks? That discussion will involve discussions with regulator, NPCI, et cetera, that can it be a one-time movement or a case-to-case movement. We have had some discussions, but obviously they are yet to be concluded formally, and it will take maybe a couple of days more when we have more direction on how specific migration. Right. Bhavesh, one small question: Will the terms of VPA with Paytm Payments Bank and other banks be materially different and hence expensive for Paytm? No, it'll be largely similar because the fact is, that today, purely from a P2M, there is a UPI incentive component. Mm-hmm. So we have a commercial on sharing of incentive with the other VPA banks that we have, which is largely in the similar range that we have with Paytm Payments Bank. Got it. Thank you so much. Hello. Hi. Next question is from Vijit Jain of Citibank. Vijit, you may go ahead. Yeah. Hi, thanks. So just a clarification. First question is on the INR 3 billion-INR 5 billion impact that you're talking about, is that basically assuming wallet ceases to operate, is that it? Or are you assuming some kind of, you know, a smaller size of the wallet business? And does it also include, you know, different commercials as you move some of these relationships, including the nodal account, to other banks? And related to that, I would just request if you could break down, you know, your core net payment margins a little better, the 7-9 basis points a little bit better, so we have a better handle on that post these developments. So that's my first question. My second question would be, so if you need to, let's say, shut down PPBL, either because, you know, it doesn't take deposits to, has, lower reasons to exist going forward, could you take over the Paytm UPI and the Paytm Wallet products back into OCL? Are there challenges with that, if you wanted to do something like that? That's my second question. And, any commentary on the financial services side, from your, you know, partners, post this development? Those are my three questions. So, Vijit, let me take the questions in the reverse order. Okay. So we've been working with our various partners. So our equity broking and our insurance business obviously remains unaffected because they do this business independently of any relationship that they may have with Paytm Payments Bank, so that business is 100% unaffected. With the lending business, lending business has no relationship of any kind with Paytm Payments Bank, other than the fact that there would be merchants who may have taken a loan and have their repayments coming from a Paytm Payments Bank account, which is not a very large number. But I will give you a directional number, maybe about 10%-15% odd merchants, on a ballpark number, who would have the repayment setup happening from their PPBL bank account because they were taking settlements there. There we have to move their settlement accounts to any other bank account that they would like that to take the settlement, so the repayments can keep coming. That process is already on. It's not a very large process because we have about like 400,000 merchant loans. Even if you take say 15% of this, we're talking largely about 60,000-70,000 merchants. We have a 30,000 sales force on the ground, which is already in the market to make sure that those repayments and the settlement account changes, et cetera, are done on or before February 29. Same is on the personal loan side, that there is a much lesser number than 15% who have their ENACH or autopay set up through the PPBL account, and hence they have to be changed as mandated. That work obviously is also on. It will not be physical work, but will be done digitally. So we are on the, in the process of doing that piece. Earlier, the effort was to make sure that they are able to convert their autopay into other mandates or, with other banks that they have, and that effort is now got amplified further just to make sure that that exercise can get completed before twentieth of February. Beyond that, there is no operational challenge, for continuation of the lending business. Obviously, the new lending business will not have an option of, for the user, to have a PPBL bank account or the repayment bank account, and hence the new business can continue as it is. Having said that, as expected, because it's a material development in one of our associate companies, each lender have their own set of areas of concern and clarification that they seek from us. We are in the process of discussing and engaging with them on clarifying a lot of nuanced questions like you may have and others have as to what's the impact on the portfolio, what's the impact on the overall business? We've been able to answer all those questions, and now they have to process those questions and come out with their, their, further incremental questions or call to action. Till that time, we have proactively worked with our partners to say, "Till the time we are able to make these operational changes, let's pause the new origination of loans for that period of time, and once we are able to solve the operational things for existing and the new one, we restart." So there will be some disruption, and hence this INR 300 crore-INR 500 crore number that Madhur was saying will have some impact from coming in from lending that we will not be originating loans for maybe a couple of weeks before we solve for the operational challenges, and then we go back to normal. Correct. Yeah, sorry. Please say. Vijay, on the first question, on the INR 300-INR 500 crore, that does assume that the wallet business would shrink dramatically. I don't, I don't know if the number is zero, but shrink dramatically. Because if customers are not able to add money after February 29th, then obviously that would be a depleting balance, and very soon that would be a very small number. So it does assume that. We, if you look at... I, I don't want to get into a huge amount of detail on net payment margin, but if you look at our overall net payment margin, which is about 8 basis points last quarter, and we have roughly 70% UPI, 30% non-UPI. So that gives you a sense of what our non-UPI net payment margin is, and I would say that wallet is in line with that. Got it. And my last question was, you know, this was related to this wallet business. I'm just trying to understand if the wallet business could also work with a third-party bank. Is that at all possible? Mm-hmm. You know, the broader question around could you take Paytm UPI and Paytm Wallet products back into OCL from PPBL? What are the hurdles with that? Let me answer that question for you. So I don't want to get into speculative zone because this question is a bit speculative, what happens to the bank, et cetera. Because we currently are very focused in making sure that the management of the Paytm Payments Bank is fully in compliance with the directions of Reserve Bank of India. And once they have executed directions, they then obviously seek the guidance for next steps from there on. So, so what will happen from there on, et cetera, is a bit of a conjecture, so I would not like to go into that space. But having said that, the idea here is that there are a set of products that Paytm app offers to its users. It includes UPI, it include wallets, it include FASTags and NCMC, et cetera. Some of the products, like FASTag, is already distributed by Paytm for other banks already, right? So that will continue to operate in that manner. And commercially, those operations are better than the commercials that the bank could offer, just because those other banks are much larger. We will work under the guidance of the regulator, because some of those changes, if we have to now start acquiring or issuing handles for other banks, just like other consumer tech companies do, we'll need guidance from Reserve Bank of India. And the conversations have started as to how, what is the best way to make sure that the customers are least inconvenienced and the business can continue to proceed forward. And currently, the conversations are in a positive direction, but they will take some time to get concluded. But we are committed to make sure that we are able to offer alternatives to the customers on the app. Those customers could be Paytm Payments Bank customers or the customers who otherwise come to the app for other services and are getting acquired in the system. You also had a question about nodal. I think the question on nodal is a fairly simple one. We maintain multiple nodal accounts for various businesses that Paytm and the group entities do with large commercial banks, not just Paytm Payments Bank. We have three more banks in which we have already API connects on nodal businesses. All the three banks are very interested to make sure that these nodal accounts, which have been instructed to be shut down in Paytm Payments Bank, could be moved to one of those three banks. We are currently in discussion, both commercially and technologically, because there are some obligations of the product, looking at the velocity of operations in those accounts, which bank can offer us the best experience and commercial. But both of those decisions will be taken very, very soon, and we'll be able to migrate that account on a commercial basis, if better than what we have today. All right. Thanks, Bhavesh. Thank you. Next question is from Ankur Rudra of JP Morgan. Ankur, you may please go ahead. Hey, thank you. So a few questions from my side. First of all, you know, Vijay or Madhur, if you could just maybe help us understand how we should or you are interpreting the directions from the regulator. Is this because of the, I mean, the comments are... Do you feel that because of the nature of the linkages between OCL and PPBL, which were untenable in their minds or because of the inability to comply with the recommendations over the last couple of years? I think that's number one. Number two, you know, given the direction that you've chosen, that you're migrating to other banks, you know, it seems like the way it'll be, Paytm will be structured and many of the services will be similar to your fintech competitors. In that, if that is the case, then, you know, what do you think will be your competitive advantages with the other competitive peers going forward? Number three, you know, you mentioned you will be trying to transition customers on wallet and other prepaid instruments and merchants as well, where PPBL was the acquiring bank. The question is: Do you have adequate time to operationalize this to the other banks, given it's only, you know, a few weeks to go? And if you can, elaborate a little bit in terms of the process on a per consumer and merchant basis, if you have clarity there. Thanks. Ankur, let me take the third point first. The... I think I briefly touched upon that there is the merchant side. The user side is a Paytm Payments Bank ownership. Merchant is the Paytm aggregation ownership in online and offline, wherein Paytm Payments Bank is the acquirer for UPI and wallet, and then other banks are acquirer for debit cards, credit cards, and net banking. So the part of migration has three legs. One leg is that you should have a partner bank interested to own up even the UPI acquiring and wallet acquiring. We have enough and more partner banks who are interested and integrated with Paytm, so that that is sorted out. The second part is the commercial in that transaction similar, better, or lower than what we get today? I can assure you that the commercial is in the similar range that we get from PPBL. In some cases better, in some cases a bit lower, but on an average it's in a similar range. Now is the third part. One is that you do account-by-account migration, which is a bit time-consuming, and you rightly pointed it out that the time is short. Other is you do a one-time migration. We have obviously started discussions with the relevant authorities, both in RBI and NPCI, et cetera, who are helping us extremely well to see to it that how can this migration happen. And there are precedents in the past wherein we've seen that there were disruption in some other bank, et cetera, et cetera, in the past. These handles were able to get changed or UPIs were able to get changed. But we don't know at this point in time what will be the migration journey. I think we'll have more, better clarity in a week from today. But we are pursuing both the approaches, and we are very positive to be able to meet the timelines of this migration with least disruption. Before you move on, just maybe one quick clarification on that point. Will this entail any kind of reacquisition with fresh KYC, or can the existing KYCs be transitioned if that's required? Yeah, Ankur, that's the point I'm making. So those are nuances, because we are talking about 440 million merchants out there on UPI acquiring, although those merchants also do other acquiring. But, so it's a large set of migration to happen, so it needs guidance from both the NPCI and RBI, and the discussions have started. So what and how will they guide and appropriately guide us? We will see in maybe in some course of time next week. And whatever is the guidance that we get from them, we'll adhere to that guidance. The idea from both the sides, from our end and obviously from the other side, is to ensure that there is least disruption to merchants. There's a large infrastructure wherein the people should not get inconvenienced, so we'll do whatever is the best and whatever is the right approach regulatorily allowed to this matter. Ankur, your first question was about what kind of reasons existed. Can you just re-ask? Because I think Bhavesh actually touched upon your first part also. What Sure, sure. Sure, Vijay. The question was, you know, do you think the reasons for the comments by the regulator was because of the business structure or the linkages between OCL and PPBL? Or was it a specific inability to comply with the recommendations, maybe over the last 22 months since this matter has come to light? I think, it is a bit of both. There is no doubt about it, that, the very nature that payment business is significantly carried by parent, Paytm, in this situation, as you just heard us talking about it. So banks, bank did have dependency on Paytm for its some of the payments offerings, like wallet, et cetera. And, we, we were able to deliver a lot of comfort, but it seems like, which is the second part that you're asking, that they were not completely comfortable. So I would say a bit of both. Ankur, maybe I can just add, I think, this is sort of underpinning both your first and the second question, which is that by design, a bank has to make its decisions independently. And the relationships between Paytm and Paytm Payments Bank have to historically, whatever relationships we've had, have to go through thorough, arm's length process. So going to your second question then, yes, some of these partnerships may look very similar to the partnerships that consumer technology companies, technology apps like us have, with bank partners. Like I said at the beginning of the call, in some cases, we had those partnerships with other banks, in some cases with Paytm Payments Bank. Those partnerships over time will be with third-party banks, like Vijay mentioned at the beginning of the call. And the advantage that we will we have will... is the advantage that we always have had, which is that we know how to build great technology for our consumers, and we know how to acquire and retain customers and get them to do many, many things on the Paytm app, over time. We have advantages in the merchant side in terms of our product innovation and our distribution and our service and so on. Those are the advantages that Paytm has carried for many years and developed and expanded on. For some of these, we need a bank partner. Like I said, Paytm Payments Bank historically has been our bank partner on some of these products. Going forward, that would be other banks. Thank you. Thank you. Next question is from Biren Engineer from CLSA. Biren, you may please ask your question. Biren, you're not audible. Can we come back to him? Sure. Yeah. Hello, am I audible? Yeah. Hi. Next question is from Nitin Aggarwal of Motilal Oswal. Nitin, you may please- Hello? ... Yeah. Hi, thanks for the opportunity. So a couple of questions. One is that: do you think that you'll be able to retain most of the merchants that are there on PBBL and seamlessly migrate them to other bank? And the similar, question on the consumer side: so is one month going to be sufficient for this migration, you think? Maybe, the idea here is that, it is not necessarily something of a retention issue. It is an optionality to be given to the merchant, which is currently was Paytm Payments Bank, and we have to switch that to another bank, right? So as I said in a previous question, we are continuously discussing with the stakeholders, which is NPCI, Reserve Bank of India, et cetera, that how can we manage this transition in the most seamless manner, right? Once we have the direction from them that, "Yes, you can manage it," because there are precedent, there is a process to be able to do that, then this entire thing is going to be very, very quickly. And I think we'll have more clarity about this in maybe a week from now. But we are very confident that we'll be able to retain these merchants and the users that we have on our platform. Nitin, I wanted to add here that it has happened in past, in UPI's case, that a certain bank had a concern and then it was to be solved, and relevant stakeholders were able to take a quick decision to get this continuously to another bank. Because it is... If the architecture is made in a way that it is not stuck and locked into there. If it is interoperable payment instrument, it is easy to migrate. It is about, like you heard from us, the wallet, where there is a customer, the wallet customer, that is where the discussion and, step are needed more clearly. As far as the UPI is concerned, there are precedent of. Okay. And how difficult it is to move QR codes to another bank? And this hit of 300-5- Like I said, like I said, there is, there is something that has happened in past related to moving significant large UPI operators bank, and that got done, if you go back in that. So there is a precedent of this, by the way. Okay. This hit of INR 300 crore-INR 500 crore that you have talked about, is, is it a one time, or you think that this is going to be a permanent damage to the EBITDA? We think that's. We have said annually with Manish, but we've also said that that's a worst-case situation. So over the next year, this should be a INR 300 crore-INR 500 crore hit from where we were going to get to. But we think that in the near term, and certainly in the medium term, there'll be a number of offsetting things that we can do to reduce this impact. We have also mentioned that we do expect over time, our profitability to keep improving because many of the relationships that we have currently with Paytm Payments Bank, they're all solvable through third-party partnerships. UPI incentive, which we typically get in the Q4. Now, we will also get it because we have an underlying Paytm Payments Bank with us. But, we often hear that most other fintechs don't get that incentive passed on to them by their banks, partnerships. So do you think that UPI incentive will also, we will lose it fully or some part of it as we migrate to other banks? So, Nitin, as I mentioned earlier, that, we have commercial arrangements with other banks, where we get a share of UPI incentive. Similar, broadly similar, I will use the word, to what Paytm Payments Bank was to offer to Paytm, right? So I don't think, that we're gonna lose anything which is material in this. Yeah, there could be a 5%-10% impact, but nothing more than that.e Okay, sure. Thank you so much. Sure. Thank you, Nithin. We'll try with Biren again. Biren, can you please go ahead? Biren, you're on mute. Why don't we come back to him? He may have stepped away. Sure. Next question will go to Suresh Ganapathy. Suresh, you may please ask your question. Suresh, if you are speaking, you're on mute. Hello? Hello, am I audible? Yes, Suresh, you're audible. Yeah. Sure, so just wanted to check, out of the total nodal accounts, that OCL has in the system, what proportion would be with the Paytm Payments Bank, and what would be with the other commercial banks as on date, roughly? Just to understand the scale. Yeah. Yeah. It's entity and product level. So because Paytm has various accounts for various of its businesses, Paytm Payments Bank- Mm-hmm. has a Nodal Account for offline payments and online payments. Mm-hmm. There are other banks who have nodal accounts for, let's say, commerce business, or they will have a nodal account for some other, other lines of business, et cetera, et cetera. The important element here is that when you open any partnership or nodal account, for transaction banking, there is an integration which is needed, with that bank for them to be able to service a requirement. So now, for us to move this nodal account, as I said earlier, that we already have a proposal from not just one bank, but multiple banks... and we are now evaluating which is the proposal which is best for us to move these accounts into that bank and get the operation back in the system. While we have time till end of the month, but we'll do that much earlier. So, in the meanwhile, would say I go to a store and make a Paytm QR code payment, can I do, or it will take some time, it will be blocked for temporarily till the time the transition happens? I just want to give absolute clarity. The system is working, will continue to work as it was working in the past, and it'll continue to work. Even when we migrate the nodal account, there is not a process of migration. It will just be an API call, which will start to move from settlement account in PPBL to settlement account, let's say, with X bank or a Y bank, and everything else will operate. There'll be no disruption even for a single hour. Oh, so you are confident that you can get this done before February 29th, the deadline, right? Or whatever, I mean, yeah. Yeah. Yeah, much, much before that. It's a call that we have to take because we already have relationship and proposals. As Vijay started in this conversation, that we are very thankful to our other banking partners who have been very, very helpful in making sure that the continuation of our businesses that we do with them and expand it to what we were doing with PPBL, can be migrated to more than one of our partner banks, and we would obviously try to do with as much, as many partner banks as possible. This is purely, I would say, a paperwork process, which is not... Which is about a few day issue, not a month issue also. We'll see whatever best has to be done before the end. Suresh, I just want to tell you, when Vijay is saying we have to take a decision, it is rather our account, which bank we are opening kind of decision, not any other kind of decision. Yeah. Okay, and just one last question that I have. In general, about the customer of Paytm itself, right? There were 33 crore wallet users, which were housed, of course, in the Paytm Payments Bank. He could use the FASTag. You know, a lot of things you could give it to him, and therefore he loved being with Paytm. Now, and this question was actually asked, but how will that guy be in the overall Paytm ecosystem, considering that abruptly things have gone off? I'll just give you an example today. Vijay, what happened is that one of my colleagues went in a car and using his Paytm Wallet, tried to make a payment in the Uber, and that Uber wala said: "Mat payment karo, Paytm band ho gaya, humko nahi chahiye payment." A lot of miscommunication is also going on. How do you address these complex situation that you are currently facing? So I'm very happy to tell you, Suresh, that the kind of, let's say, if you were to monitor the wallet usage and exit of money versus incoming of money, it's not something which is very aberrant, actually. Which is very normal. So these kind of hearsay, conjecture, these things, we will continue to focus on communication. And like you said it, a lot of things go, end up becoming hearsay, and obviously, till the time we were not able to communicate, we ourselves had to take a decision, stock market communication, and so on. So we would become even further aggressive on communication. So more or less, communication should solve for it. If it is a fact that it, that thing that they are seeing, that thing they are seeing. Suresh, since this morning, we've had and even last night, we've had aggressive communication out to merchants, out to consumers, on the app, social, and all of that. So yes, it is an issue because there's a lot of sort of things that fly around when something like this happens, and then people have misinterpretations, and so on. So we're working very aggressively to inform customers and merchants that there's no impact right now. The ability of the management to retain the consumer in the ecosystem, considering that a lot of products now temporarily is taken away, I mean, those challenges- Suresh, I think- Yeah. There is no doubt about it, that customers love the deep integrated product offering. Correct. At the same time, I'm rather going to say that, other banks, it is just our, partnership with other banks that should be able to bring a lot of it back. That, that is what I'm trying to say. I mean, I'm not gonna say whether it is easy or tough, but- Okay ... it is, it is definitely not a very much complex thing to execute. It is just the method and logical architecture thing. Okay, very clear. Thank you so much. Thank you. Next question is from Manish Shukla of Axis. Manish, you may please go ahead. Yeah. Good evening, and thank you for the opportunity. Firstly, for the nine months of this financial year, what part of your payment volume was routed through nodal accounts at PPBL? So, that number would not be offhand available, but the Nodal Account, as we said, is for our offline payment business and our online payment business. So predominantly, our P2M GMV that we report gets routed through that Nodal Account. There could be certain deviations to that, to that GMV, not getting into detail, but that will probably be the thing, which will now be transferred to some other bank in the system. Okay. And of the payments, of the overall GMV for the, this year, what proportion would have been from wallets? Oh, very small. I think we've called this out very, very clearly, that wallet is a very important product. Customers love it because of its deep integration with FASTag and the fact that they love to use the product at the merchant level. But its pure-play impact to the GMV is very, very small, because UPI dominates 75%, cards dominate 15%-17%, et cetera. And then there's some loan instruments, as you know, and then there'll be wallet. So it's not a very high GMV-oriented product, but yes, it's a reasonably profitable product... because we get MDR and we get add money to wallet charges. So, there was a sharing of revenue, which will now get impacted till the time we are able to have an alternative available on the Paytm app for users to either open a new wallet with any other issuer through the Paytm app and/or migrate these wallets if that is a possibility as per the regulator. Last question. So the INR 3 billion-INR 5 billion potential impact that we are talking about, it will be in the merchant MDR line item. Is that the right assumption? So there are two things that we do for wallet. Customers add money to wallet, where Paytm provides a payment service to Paytm Payments Bank. And then, when customers use this wallet on merchants, third-party merchants, like, you know, on large online merchants or offline merchants or QR codes and so on, then Paytm earns an MDR, and it pays an interchange too. So the first part are payments that happen on our app, and the second part is payments that happen on a merchant website or an app. But all of this will be in payment services revenue that we disclosed, Manish. Sure. Thank you. Those were my questions. Thank you. Next question is from Biren Engineer of CLSA. Biren, you may please go ahead. Biren, I think you have to unmute yourself. I think there is some technical problem. We can go ahead with the next one. Sure. Next question is from Rahul Jain of Dolat Capital. Rahul, you may please go ahead. Yeah. Is my line audible? Yes, Rahul, you are audible. Yeah. Thanks for the opportunity. Maybe it sound slightly repetitive, but just to add up to this thought of INR 3 billion-INR 5 billion, kind of, a reconciliation. Since we say that our commercial on the payments would be similar also, we would be timely, ideally, we would be able to timely move to the alternative, so the disruption would be lower on the payment side. So is it purely coming from not able to lend for some period of time, and gradual impact of that? And also to from the wallet perspective, since we may also find wallet partners. So where is the bulk of this math add up adding up from? Rahul, as you said earlier, this does assume the worst case of if we are not able to migrate the wallet users. And if the wallet effectively, I think Vijay asked this question earlier, which is that if the wallet volumes become really, really small and all the margin that you're making on wallet goes away, then of course there'll be some corresponding marketing spend and so on, which would also go away, offsetting some of the, if you will, net payment margin loss. But this is the worst case for if you're not able to do any of those things. And then, on top of that, it does include some temporary impact potentially on our lending business. Yeah. So when you say, worst case, worst case is 5, and, 3 is, INR 3 billion is practical? Or is it like both, both end of it would, the actual impact would be even lower than this range also? We're keen to get out our range to investors. As you can imagine, I think we released this a few hours after, so it's hard to be very precise because there are certain linkages that if your wallet volumes goes down, then there are certain spends that you are doing on promoting certain payment instruments with merchants and so on, which could be savings down the road and so on, right? So it's not... So it was hard to come up with a very precise number, which is why we said INR 300 crore-INR 500 crore. And if we are able to work on offsetting the customer experience in a meaningful fashion, then obviously the worst case is worst case. You should expect, like Bhavesh said earlier, that there will be some initial, you know, sort of, operational work that we have to do, which may cause some short-term disruption. But we do think that a longer term, we should be able to offset a lot of these things and not be in this worst-case range. Yeah. And the clarification to Bhavesh's remark on the lending business impact. So if essentially a new loan is given to any consumer or merchant who may be having PPBL, but also another account, can lending distribution may continue to such prospects? Yeah. So, Rahul, as I said, there are two parts to it. The first part here is that we have to operationalize the fact that we have to make a few journey changes, wherein the dismantling of the fact that you can link your PPBL account, et cetera, has to go out of the journey, right? So that work is already on. The other piece here is that the users and the merchants who come in, they set up their e-mandate or auto payment, using the sponsor bank as Paytm Payments Bank, because it's a UPI or a NPCI service. Now we have multiple integrations, but we have to integrate those integrations over Paytm Payments Bank in our journey. So there are some operational changes which will take us maybe a week or two to do before we can kick-start the new business back again. And then, the existing business is just about making sure that the people who had set up their mandates from PPBL bank account are able to switch to another bank account, which work has already started. So I think the disruption will be there for a couple of weeks, and to that extent, we will have an EBITDA impact in our lending business. I don't want to shy away from saying that. But we are very hopeful that, let's say, by early March, we should be back to full normalcy, if not earlier. Got it. Got it. I wish you guys the best, assuming you become strong—come out stronger than earlier. Thank you. Thank you so much. We will extend the call by 15 minutes, that is till 4:30 P.M. Next question is from Pranav Gundlapalle of Bernstein. Pranav, you may please go ahead. Yeah, I have just a couple of questions. I think the first is on your card acquiring the POS machines business. How does that change that's similar to what is going to happen with your QR merchants or would be a bit more involved in terms of getting, shifting their current accounts, et cetera? That's the first question. Second is once you have the disconnect between Paytm app and the PPBL, would there be any loss in the type of insights that you used to get from customers based on their spending, et cetera? And therefore, you know, down the line, does it impact the underwriting or filtering ability of customers or your filtering ability of customers? And the third question is on, you know, the switchover to other banking partners. While the economics could be similar, is there a big difference in the level of integration that you could get with PPBL because it was a related company and would that lead to any sort of, you know, deterioration experience or any other changes that or risks that you see from that shift? Those are the three questions. Pranav, I actually want to take the last question where you were talking about that we had a special relationship with Paytm Bank or not. That's exactly what we solved in last two years, and we believe that we not only became arm's length, we became arm's length, meaning we rather had much stronger, I would say, stronger gap of no data sharing, no data knowledge, et cetera, with Paytm Bank, actually. So I would say that, we don't see that it'll be less in any manner whatsoever. That is the word that I want to use. Less in any manner whatsoever. So everything else of the Paytm works on various other nuances which are there and logically on our platform. Pranav, to the rest of the two questions, there was no data that Paytm was taking and getting from Paytm Payments Bank, in the past or in the present. I just want to explicitly clarify that. So at any point in time, a customer who is a customer using wallet or UPI handle of Paytm, Paytm Payments Bank, the data resides with Paytm Payments Bank, and there was absolutely no information which is available. All the models, be for growth for our, insurance business or our lending distribution business or any other thing that we used to do on the Paytm app, were built on insights that are available on the Paytm app for data which, regulatory and legally Paytm is able to consume and have it in the system, right? Understood. So that's one. So there is no impact on that piece at all, and it never has been. To your question on POS machines, I think the migration is absolutely the easiest there because POS machines... So let me split this for more clarity. So we do online payment gateway business. Online payment gateway business, Paytm Payments Bank only powers, for merchants, the UPI handle. Okay. But for credit card, debit card, net banking, it is anyways being done with various other banks, large commercial banks in the system. Paytm Payments Bank has no business or no relationship because that is, they are not in that business. What we have to do for online payment gateway is, which we already are integrated, now start to offer to all merchants some other bank handle, and that's a very, very quick switch. That's not even-- That's a 1-day, 2-day work, that instead of at acquiring @paytm, now you start acquiring at the, at the @XY, right? In the system. So that is number one piece on online gateway. So there is absolutely no disruption happening on the online payment gateway business. It continues to operate in the same manner it was operating earlier. Mm-hmm. Now, there is second part, which is the POS machine, as you rightly said. POS machine, again, we acquire POS businesses on behalf of various banks, including Paytm Payments Bank. Mm-hmm. Each POS machine, as a payment aggregator, we do multi-bank acquiring, right? Mm-hmm. We have an ability that when you swipe your credit card or debit card, we can acquire that instrument funding source, depending upon the right commercial with any bank. Right. We are multi-bank acquired by at least five or six banks on the POS. Paytm Payments Bank is one such acquirer- Mm-hmm ... and which anyways hardly acquired any credit card and does not acquire any debit card, largely acquires wallet and UPI, which again, we have to just switch the wallet UPI, which is not very, very complicated. Mm-hmm. As I said, the operationalization of POS migration and online migration is the easiest and simplest. The operationalization for pure play QR merchants is where we are seeking guidance from NPCI, RBI, et cetera, as to what is the most convenient and non-intrusive or obstructive way to be able to do so. Understood. That's very clear. Thanks much. Thank you, Pranav. Thank you. Next question is from Bhavik Dave of Nippon Mutual Fund. Bhavik, you may please ask your question. Hi. I hope I'm audible. Two, three questions. One is... Am I audible? Yeah, you're audible. ...Perfect. So, 2, 3 questions. One is, the discussions that we spoke about with various banks that we are in, I'm assuming that you mean, now onwards after the event has taken place, right? Bhavik, this is what I was trying to say in the beginning, that we already, since last two years, had started to do this, and the dependencies were of certain, certain products that were single bank equal to only Paytm Bank. But most of the payment business actually have become multi-bank, and the traffic allocation, et cetera, were different, different. So it's not because that it happened yesterday, we are starting today. Right. It actually has been going on, and that is why I was also saying that our current and potential bank partners proactively reached out to say that we can just continue to do more. Bhavik, in that extension, I just want to give one explicit example, so that it's very, very clear, that for the last maybe about 18 months, we have been issuing a very large private bank FASTags to the Paytm app, in fairly large quantity, along with Paytm Payments Bank FASTag. And now we have switched to ensure that our customers who are coming to ask for FASTag are only getting that bank's FASTag, and we'll add a lot more banks into that capability fairly soon. Similarly, other products which Paytm Payments Bank was offering, we have to now start to integrate those products with other banks because they were always an interest, both operationally and commercially from other banks. But we were, not very, very keen because it was, it was working fine the way it was working fine. Now, with this guidance, we will now start to engage with them and to start to integrate with them. So it's not as if, as Vijay said, we will start today. It's been there. We have agreements, we have commercial discussions on most of the businesses. Yes, it will take operational integration and migration time. That will be a minor disruption, but we have to go through the process, and hopefully we can work through the process and make sure the disruption is the least. Sure. And second question is on, on the governance and the compliance bit, where, wherein, when we look at the Paytm Payments Bank, right? It was a payment bank, not much in terms of, a, business that needed to be done. It was a deposit-taking entity, and there was no loans given out, and it was a very simple business model. Yet RBI had to take stern action in terms of compliance. What gives us the comfort, or what are we doing to get one step ahead and make ourselves at OCL a little more compliant or go, highly governed in some sense, so that we don't face any challenge, here? Because that's a regulated entity, so RBI had a direct control. OCL, how do we keep ourselves in, like, the thick of things in the sense, how do we keep the governance standard up there so that there's no other disruption that comes in? Because last week we saw one more article about the NACH, NHAI and the FASTag bit, and now this comes through. So, how do we keep things crystal clear when it comes to governance and compliance at OCL as well? Just would love to hear your thoughts on that. Yeah. So, Bhavik, one of the most important thing that probably in 2019, as the board and I, when we were having a discussion, decided that we would augment the compliance and risk capability of the organization dramatically. If you know, we now have a group compliance officer position, which is filled by a very able, capable female. And then earlier, it used to be that independent teams used to have their own compliance methods and sort of their own business leader reporting, but now we have an oversight on the group compliance. In fact, I'm very happy to tell you that the amount of work that we've done in payment bank, although it has not achieved the fruitful results like you and I are seeing today, but I can be telling you that there is a dramatic improvement, wherein one of the audits from regulator, it actually was said that we have seen material improvements, and that is... It was very humbling for me to hear, and there were many nice and positive words in different, different conversations. I do want to tell you that also. So we did keep look at compliance as a core business model approach instead of a layering as an addition. The important thing for us to remember is that if we do not make compliance and risk as a core part of the business, then it does not become the bigger business that we ambition-wise carry it. And that is why whether you look at risk management also, credit risk or fraud risk or every other thing, we've built lots of technology and capabilities, and that is why you saw even though those personal loans and payment traffic kept growing and our fraud ratio dramatically reduced, our operational risk systems and capability dramatically improved. So I'm very proud to say that today, the technology stack that we have for operational risk and compliance is actually the world-class. Except like what we are seeing today is what is very sad and bad that we have this kind of outcome, which is safe pacing. As far as group is concerned, as well as the entity is concerned, we look at now compliance first, technology second approach. Sure. And last question is, with seeing that almost 80%, in the sense the payment business now gets impacted, which was not earlier, and we'd already seen lending business, getting a little bit getting slower, considering the macro environment. How do we look at costs, right? And that's one lever which can maybe control the loss of EBITDA or profitability that we are seeing for FY 2025, 2026. How do we think about cost in the entire scheme of things? Do we think about cost more now because of this event as well, because there are too many things that are going around and revenues are challenged in a big material way? Do we continue to spend the way we were and invest in the business to create maybe new channels of growth? How are you going to balance this eventually over the next couple of years? That is what I want to understand. Thanks. The best part is, Bhavik, that we don't have new incremental channels to be discovered or- ...let's say, risky marketing or sales head dollars, we pushed on those. So we are sort of clear about what our sales, marketing, and spends are. Those are actually very capped and so on. So overall, when we reduce the number of things that we do, we see dramatic improvement in the cost. And that is the first approach that we have taken since the listing, and we continue to prune the number of things that we do. So what it brings is actually, like, in a derivative way, what you've said it is going to happen, that there will be a better cost advantage. We always had more people to do fewer things, forward-looking also, but now we will do it with partners, so much less cost. Sure. Thanks. Bhavik, you may have seen this sort of totality from us over the last two or three quarters, and very, very specifically in the last quarter- Yeah that we think that there is massive EBITDA expansion opportunity for us out of operating leverage because the indirect costs, in particular, will—while we have attention on direct costs as well, of course, but indirect costs in particular, the growth of that should slow down very dramatically. And we have talked about various factors. Vijay just mentioned one. We have talked about the role of AI, where we, I have to say, we are very early adopters of these in the Indian context and maybe even global context. And we are seeing just huge amount of efficiency and productivity, improvements across the board. And in addition to that, just a very sharp focus and discipline on cost, because, you know, the scale at which we do things now, improving our processes, improving our efficiency can—has a very meaningful impact. So that's, that is an area of a huge amount of attention even before this. And if this has revenue pressure, then we would also obviously re-look at the cost once again. Sure. Thanks. Thank you. Next question is from Preethi R.S. of UTI Mutual Fund. Preethi, you may unmute your line and ask your question. Hi, thanks, Vijay. So my question is, basically on the solution that you're offering, with the migration to other banks, will that resolve the problem from the regulator point of view, without addressing the issue at PPBL? So the response to the compliance lapses, I think are not satisfactory. That's the root of the problem. Is it on data storage, KYC or tech dependency? It is an associate company, and it's. And if the MD could be on this call, if they could address what exactly is the issue, because RBI possibly views OCL and PPBL together as one entity, and they could, of course, send out a diktat on PPBL since it's an RE. So could you please elaborate on that, either on this call or if there's other platform? I think we definitely need answers on that. Yeah, Bhavesh, go ahead. No, I think it was addressed to you. But, Preethi, I can take a stab at this question that you asked from the bank point of view. So the difference, we today work with other large financial institutions, be it mutual funds, insurance companies, lending banks, lending NBFCs, et cetera, in a very, very compliant and robust manner. And, I just want to say that we've been very cautious both, as a DNA that we've built over the last couple of years, and through the learnings of the associate engagement that we have of Paytm Payment Bank, of what is the approach regulator expects, from a company of our size and scale as to how should we be managing the regulated products. So, in that spirit, when we engage with other banks, we feel very, very confident that that part of solutioning, of how we want to operate with other banks, products that we currently are taking from Paytm Payments Bank, and I just gave you an example of Paytm FASTag, or we do credit cards, or we do loans or et cetera, et cetera, is very well established. The challenge of what we understand thus far is very clearly articulated for that the bank, in its conduct on variety of elements, being a young bank at the beginning and then obviously growing in very large size and scale, wasn't able to satisfy the size it has to the regulator of the controls, be it on technology or in compliance, to as much satisfaction that the regulator may be seeking. That's our understanding of that. And obviously, there are a lot more details available with the bank, and as and when we can get privy to those details, we'll be more than happy to have a discussion with you. But we have, we have always maintained at OCL that we would like to operate with regulated partners on the way they want to regulate and operate the business, not the way we operate the business. And hence, our all other partnerships that we do with other banks and NBFCs or broking companies, et cetera, has been very, very successful, and we feel confident that that will continue to happen. And we will learn from this. I don't want to say that there is zero learning from this process. We'll learn from this. We are continuously engaging with the regulator and other beneficiaries and other stakeholders in the system of how these things could have been done better and should be done better. And in that entire process, making our entire company far more stronger and far more compliant, so that we do not have any other situation ever in the future. Preethi, I've always learned from these interactions and notices of regulator, that there is a lot better that we could do, and definitely the growth of the bank was one of the factor with respect to the various risk and control compliance methods that it had put in place. That is, the beginning of the conversation was. I'm happy to tell you that based on that very factor, we changed the management, not just in the bank, but also in the Paytm and various other relationships that we have with other financial institutions, also were based on these kind of insights that we were actually able to handle. I definitely want to tell you there is a learning and lesson in this and all other interactions that we've had, and we will not let it go without getting that learning and lesson and buy it completely into it. This is an opportunity for us to come stronger, better, abler, and capabler for regulator's eyes, and we believe that we are going to make sure that everything else apart, this is the gain that we get out of it. You can be very sure that when we look at ourselves in future and look at this event, we will see it as the event that make us and that made us superior and better than anyone else in the industry. I just want to address one point, Preethi. I think there may be this impression that Paytm and Paytm Payments Bank is one, but by design and by structure, it is not, and it cannot be. You know, an associate company. First of all, it's an associate company, and second, it's not an associate company in the sense that it's a bank. And first and foremost, for a bank, is that it has to follow the governance that a bank is supposed to follow. Which is to say that it has to have its independent management team, which reports to the board. There are matters that have to go to the committees of the board, where it can only be independent directors. It has to also have independent compliance and risk teams, and so on. Yes, there might be that impression. I'm not saying that may not happen. But by design and structure and by reality, it just does not function like that and cannot function like that. If one did try to make it function like that, I think you are really in a bigger problem because you are breaching the spirit of governance of how a bank should be governed. So hopefully there's acknowledgement of that. It is a tricky situation in that sense because an associate of yours has to make independent decisions, but if those decisions and those actions then are sought and found to be incomplete or wanting from the regulator, then obviously it has reputational risk on all of us. Thank you. Great. Thank you. So that was the only question I had, but we would definitely want to hear from your associate company, you know, on this, on this matter, because it overnight has become so material to the company, right? Thank you. Thank you. Thank you, Preethi. Next question is from Jayant Kharote of Jefferies. Jayant, you may please go ahead. Yeah. Good evening, everybody, and thanks for the opportunity. First question is on the nodal account for merchant payments, moving to other banks. So does this affect the product or user experience for the merchants in any manner? Like, I know we are perhaps the best on fund settlement time, early morning, 8:00 A.M. So, more qualitatively, does this would you be able to replicate the same product experience for the merchants? That's the first question. And second question is, if I understood correctly, most of the immediate operational transitions can be solved digitally or are B2B in nature, and there is some physical effort needed, like the one you called out on the 60,000-odd merchant loans. So I mean, we do have a capable 30,000 employee force. Do you want to call out any other areas in the next one month where you think you'll need, sort of a slightly intense physical effort? These are the two questions. Yeah. So, Jayant, the nodal account decision, as I said, is exactly hinging on the point that you raised out. And thank you for bringing that detailed, nuanced understanding of the product. That today, the ability of the current nodal technology backed by Paytm Payments Bank has a lot of flexibility, et cetera, et cetera, is not to say that that is very unique to it. It needs to be assessed appropriately by us technically, and the teams are on it with two or three large banks. To just to test it out that it works in the manner we want it to work, and that's the reason we're seeking. It may take a week or 10 days for us before we announce the decision to move to which bank, et cetera, because that's a technical feasibility going on. But it is not something which is very complex. We know what product is available, and we will, I would say, 99% get the similar product, because banks are very, very keen to develop something, further on top of what they have, just to accommodate this massive opportunity that they could get, because there's a huge float in that account. To your, to your other piece on physical force. So yeah, I gave you one nuance of the lending business, but wherever, there are, as I said, there are merchants who have PPBL as their settlement bank account. They have a DIY flow on the app who are being nudged, that you can now go and make a change of your settlement bank account from PPBL to some other bank that you have, because we know that they will have-- they have multiple bank accounts. And only the ones who don't do it, let's say, through digital effort, even after multiple reminders, will need a physical interaction, for which we have a large sales force which will anyways do it, so that the merchant keeps getting the settlement in the bank account that they like. But it is more at the merchant end, that they would not want their settlement to get stopped after twenty-ninth February, so they will need to have an active bank account available to them, and we are making sure that we're able to do it digitally. Some bit of physicality will get involved, but it's not a complex ask. We'll be able to do that in maybe about 10 days. This is only for the 6 lakh odd merchants that are there on PPBL of our total 40 million, 4 crore base? No, so it is on a 4 crore base. Obviously, the active rates of this 4 crores is less than 4 crores. And of that base, I can give you a broad sense, maybe about 12%, 13%, maybe 15% of them have a settlement account as PPBL, which will have to now change to any other bank account the merchant carries. So yeah, it is a math which is not materially large, but it is large, but not materially large. Most of it is being done DIY. The commercials do change their bank accounts naturally also, and they can do it on the app with a simple login process. But if they do fail to do so in the time that we are stipulating, which is around fifteenth or twentieth of this month, then we obviously will have a physical nudge to make that happen. Great, great. Thanks a lot, and best of luck, the whole team for this. Thanks. Thank you. Next question is from Sumeet Kariwala of Morgan Stanley. Sumit, you may please go ahead. Thanks. Thanks for the opportunity. I had two questions. The first question is on the wallet business. As you try to restart and you try to tie up with some other bank to offer wallet-related services, how will that work? Will you need a PPI license? Because I understand the current PPI license is with Paytm Payments Bank. And can you run that business without a PPI license as a distributor of a wallet product for a particular bank? And if you can do that, how will the economics change, and so on. So just trying to get some clarity. As you try to restart this business, can you... And if you restart this, say, for example, one year down the line, can this entire INR 300 crore EBITDA impact be pulled back? So, Sumit, let me clarify. Yes, you're right. PPI license is of Paytm Payments Bank, and then there is a wallet on top of it, right? Now, there are two parts to the answer. One part here is, anyways, Paytm Payments Bank was barred from issuing new wallets for the last two years. So even on the Paytm app, we had not switched on an option for users to come in, sign up on a new wallet of any other third-party PPI issuer or a bank, right? So now the intention here is that we will now start issuing other, PPI wallets of any other issuer to the app as a new, as a new wallet, right? And the commercial will largely be similar because it's an interchange defined by the NPCI, and there is an admin charge defined by the payment aggregator. So there is no commercial change per se into that part, but obviously it will be new acquisition. On the existing wallets that the bank has, the bank will have to find out a way as to how that process of ring-fencing those users can be. And that conversations bank will do by itself, hopefully with the regulator, as the time goes by, so as to ensure that the least disruption to people who've been using the wallet of Paytm Payments Bank can they be given an option to switch over to any other bank with least disruption, right? And if there is a facilitation Paytm can provide, we will obviously participate. But our current focus is to ensure that we are able to switch on new acquisition of wallets like we've done for FASTag already, and new acquisition of handles, et cetera, et cetera. While the migration of existing, will need direction from RBI and the work the bank will have to do with them, and whatever facilitation Paytm can provide, we would obviously participate in that journey. Very clear. And some data related clarification. So, you've given the impact on EBITDA an estimated number, worst case number. If I were to try and back calculate this at the revenue level, I was making some assumptions, will it be fine to assume that 15%-20% of the payment-related revenues are getting impacted over here? No, it would be lower than that, Sumit. So like we've mentioned that, if you think about this number and if you think about... And these are all sort of somewhat preliminary, although we feel confident of the range. But just to talk about how we get to that math, if you talk about this number and then you say, "Okay, the net payment margin impact should be slightly higher than this," because whatever the net payment margin impact is, will be offset by some other savings in marketing and cash back and so on. So the net payment margin impact will be somewhat higher than this. And like I mentioned earlier, our net payment margin from non-UPI is in the 25-30 basis points zip code, and wallet is also in that zip code. So, that's how you sort of get to the revenue number, or certainly to the GMV number. Thanks. Very helpful. One last small question. Any potential thoughts on how the MTU might get impacted, like, 3-4 months down the line? Or you don't think there'll be a dramatic change to that number because UPI is driving a lot of stuff over there? Last question, please. Thank you. So Sumit, the MTU, MTU number is based on both the fact that customers can come on the Paytm app and do UPI transaction. Wallet was a very, very small subset of MTU, as you know. 97%-98% of the transactions people do primarily will be UPI-led. So as we find a solution to migrate the @Paytm, which is powered by Paytm Payments Bank to any other issuer of that handle, we don't see that there is going to be any material impact on the MTU. More importantly, is that we then start to grow from there on, because because of the embargo, the bank could not offer certain products, and because of our partnership expansion with other banks who could offer all the products, maybe in a six-month period from today, we will be in a position to not only regain what we may end up losing for the next maybe couple of months, but start to grow furthermore because of new acquisition opportunity will that will emerge, which was not there for the last two years because we were working on some products with PPBL. Just to give you one illustration, for example. Yeah ...on FASTag. After the embargo, we did start partnership with one other bank, and that has been very successful. Of course, it is a win-win partnership. It is, it is beneficial for Paytm, and it is beneficial for our bank partner. So those sorts of things can also be done for other products. Got it. Very clear and helpful. Thanks a lot. Thank you, Sumit. That was our last question for today. Thank you, participants, for joining the call. You may now disconnect the line. Thank you so much. Thank you. Thank you, everyone.