RCBC's 30-Transfer Cap on Free InstaPay Flagged as Non-Compliant by BSP

Rizal Commercial Banking Corporation (RCBC) announced on Friday, July 3, that InstaPay transfers through its mobile banking apps would be free starting July 4, but the Bangko Sentral ng Pilipinas (BSP) has flagged the bank's fee structure as non-compliant with new regulations. The Yuchengco-led bank's offer includes a 30-transfer monthly cap for RCBC Pulz users, with a P10 fee applied to transfers exceeding that limit or below the P100 minimum transaction amount. BSP Deputy Governor Mamerto Tangonan told reporters on Friday that the central bank had already spoken with RCBC president and chief executive officer Reggie Cariaso, stating "that's not compliant with the [circular]." The issue stems from BSP Circular No. 1238, which takes effect on July 4 and establishes a pricing framework requiring that fees for transfers to other banks (off-us) cannot exceed fees for same-bank transfers (on-us) plus the switch fee of approximately P1.50. The circular aims to reduce digital transfer costs across the Philippine banking sector and promote financial inclusion.

BSP Deputy Governor Challenges RCBC Fee Structure

BSP Deputy Governor Mamerto Tangonan told reporters on Friday that the central bank had already spoken with RCBC over its fee structure. "We talked to Reggie," Tangonan said, referring to RCBC president and chief executive officer Reggie Cariaso. "We said that's not compliant with the [circular]."

RCBC announced that InstaPay transfers through RCBC Pulz would be free starting July 4, but customers may make only up to 30 free InstaPay transfers per month, with a minimum amount of P100 per transaction. Transfers below P100 or beyond the monthly free allocation will still be charged P10. DiskarTech users will get free person-to-person InstaPay transfers with no minimum amount and no monthly cap.

Tangonan noted another issue: RCBC announced free InstaPay transfers but said nothing about PESONet. "It's person-to-person transfer. But person-to-person, there's InstaPay, there's PESONet," he said in a mix of English and Filipino at the sidelines of a BSP book launch on Friday.

BSP Circular No. 1238 Pricing Framework Explained

BSP Circular No. 1238 takes effect on July 4 and sets a new pricing framework for fund transfers with the goal of bringing down fees for banks and e-wallets.

Asked if there should be no limit on free transfers, Tangonan explained the circular's pricing logic: "If you read the circular, all it says is the pricing mechanism. So, all we say is that whatever you charge, the price of your off-us transaction must be the same as your on-us [or] cannot be more than your on-us price plus the switch fee. That's all it says."

If transfers within the same bank are free, then transfers to another bank or e-wallet should generally cost only the switch fee. For InstaPay, that switch fee is industry-wide and around P1.50.

Tangonan stated directly: "Bank A to Bank A, free. And then, if you want to maintain that free Bank A to Bank A, free, when you do Bank A to Bank B, it should be [just] plus switch."

BPI's Zero-Fee Model as Comparison

Bank of the Philippine Islands (BPI) eliminated transfer fees entirely under the new framework. BPI-to-BPI transfers were already free, so under BPI president and chief executive officer TG Limcaoco's reading of the circular, charging for transfers to other banks would mean charging only around P1.50.

"We said, why would we still charge P1.50? You're just needling the customer. But P1.50, will it make a big difference for us now? No," Limcaoco said in a mix of English and Filipino. "We think this is great for financial inclusion. If banks are willing to give on-us for free, why wouldn't you give the P1.50 also?"

BSP Enforcement Timeline and Next Steps

Tangonan said institutions covered by the circular have until July 4 to comply. Asked what enforcement action would mean if they don't, Tangonan described a ladder that starts off easy but can get less pleasant: "First, there's a friendly reminder. And then, there's another reminder, less friendly."

When asked what would happen if other banks start using a model similar to RCBC's, Tangonan said, "Well, we'll talk to them." Asked whether the BSP had already told RCBC to change its mechanism, Tangonan left reporters with a teaser, "Just wait for tomorrow."

The timing is not ideal for RCBC. The bank is entering the second half of the year under closer scrutiny after Moody's Ratings revised its outlook on RCBC's credit ratings to negative from stable, citing expectations that the bank's solvency metrics could weaken as asset quality deteriorates.

RCBC has said it is entering the second half from a position of "deliberate strength" while taking steps to protect its balance sheet in a more challenging macroeconomic environment. "My objective remains the same — to protect, scale, and elevate the strong franchise that is RCBC," Cariaso said during the bank's 2026 annual stockholders' meeting.

FAQ

What did RCBC announce on July 3 regarding InstaPay transfers?

RCBC announced on Friday, July 3, that InstaPay transfers through RCBC Pulz and RCBC DiskarTech would be free starting July 4. RCBC Pulz customers may make up to 30 free InstaPay transfers per month with a minimum amount of P100 per transaction, while transfers below P100 or beyond the monthly cap will be charged P10. DiskarTech users will get free person-to-person InstaPay transfers with no minimum amount and no monthly cap.

Why did BSP Deputy Governor Mamerto Tangonan say RCBC's fee structure is non-compliant?

Tangonan stated that RCBC's structure does not comply with BSP Circular No. 1238, which takes effect on July 4. The circular requires that the price of off-us transactions (transfers to other banks) must be the same as on-us transactions (same-bank transfers) or cannot be more than the on-us price plus the switch fee of approximately P1.50. Tangonan told reporters the BSP had already spoken with RCBC president Reggie Cariaso about the non-compliance.

What is the BSP's enforcement timeline for the new transfer fee rules?

Institutions covered by BSP Circular No. 1238 have until July 4 to comply. Tangonan described an enforcement ladder starting with a "friendly reminder" and escalating to "another reminder, less friendly." When asked whether the BSP had told RCBC to change its mechanism, Tangonan said "Just wait for tomorrow."

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