Access to the NFC functionality on the Android platform alone cannot generate the necessary choice, competition, efficiencies and innovation in integrated mobile wallets in Australia, banks argue in another follow-up submission to the Australian Competition and Consumer Commission in their application to negotiate collectively with Apple over access to Apple Pay.Commonwealth Bank, National Australia Bank, Westpac and Bendigo and Adelaide Bank wrote to the Australian Competition and Consumer Commission in July, seeking authorisation to engage in "limited collective negotiations with providers of third-party mobile wallet services."The negotiations would cover competition, best practice standards and efficiency. But the latest submission focuses on access to the NFC chip.Under current arrangements, iPhone NFC payments at the point of sale can only be made via the Apple Pay payment mechanism, which validates payment card credentials and initiates contactless payment.The ACCC asked the banks to comment on the case of US bank Capital One, which launched a proprietary mobile wallet in September that links to the Apple Pay payment mechanism.The banks' submission said: "The additional integration is not a substitute for access to the iPhone's NFC function. It is not as quick and convenient as a fully integrated solution."For example, using the new Capital One wallet on the iPhone, a customer who wished to check their account balances and available credit may need to verify their identity at least twice - first when opening the wallet and again when paying through Apple Pay."It does not take much additional inconvenience to discourage users from returning to an application," the banks said.They also argued that there was a large customer segment that would prefer a financial institution rather than a technology company to be trusted with their payments.The submission said lack of access to iPhone NFC functionality reduced the addressable market, limited commercial viability and affected the consistency of service offerings. Customers with iPhones would be treated differently to customers with Android phones.One of Apple's arguments is that it has only 40 per cent of the smartphone market in Australia. The bank's response is that Australian download revenues are more skewed towards the iPhone that the worldwide average, with 70 per cent of combined Apple App Store and Google Play Store revenues attributable to Apple. If these revenues are reflected in customers' tendency to make mobile payments, then the importance of iPhone customers to the success of mobile wallets is clear."Competition between handsets cannot be expected to provide sufficient competitive constraints," the submission said.On the question of non-integrated access, such as NFC stickers, the submission said they did not substitute for integrated NFC access or provide the same public benefits. The same goes for other workarounds, such as wristbands, QR codes and Bluetooth beacons.The mobile phone cannot send instructions to, or receive instructions from the sticker. The sticker's antenna cannot be disabled. By contrast an NFC controller integrated into a mobile device can communicate information about an NFC payment to an app running on that device without the need to communicate through the payment network or the