5. No independent ombudsman. In many countries, due to the novelty of the phenomenon and especially the easy assimilation or confusion with e-commerce, mobile payments seem to be a “no man’s land” where the service provider would be both the judge and party, in any case of dispute with individual consumers or consumer rights groups. 6. Lack of currency. Although Mobile payments may allow parties to make economic exchanges, they do not take the form of legal tender in the sense that they lack the status of other payment instruments such as cash, which is a medium of exchange that is authorized, adopted and guaranteed by the government. At best mobile payments have to be backed by the issuer’s promise to pay. 7. Dormant assets. What happens to consumers’ money when they lose touch with it is an important issue in mobile payments, just as it is in financial services such as bank accounts, pensions and insurance policies. The exact definition of when money/assets become dormant needs to be determined. In mobile payments the treatment of dormant assets in the case of number termination, loss of phone and death is not adequately addressed. Although the amounts that can be stored in e-wallets, e-purses, credit on phones and potentially in other areas such as apps, are relatively small on an individual basis, the aggregate amounts could total hundreds of millions of dollars, maybe billions in due course as mobile payments increase their share of payment transactions. There is a variety of reasons for assets becoming dormant. For example where access codes are known only to the owner of the phone and money stored in the e-wallet is no longer available in a bank account, this could be lost forever should the main owner pass away. Our colleagues in Kenya have reported such instances. In banking and insurance there are usually clear regulations, policies and practices on how to address the issue of dormant assets. In mobile payments this needs to be resolved so that the consumers’ assets always belong to them and there is a clear, simple accessible mechanism for recovering them. The first step is to determine who has control over dormant assets in the various mobile payment mechanisms and what is happening to those assets now.