Sometimes a regulator can be too safety-conscious. The Reserve Bank has outed itself as one such regulator, saying its rules governing access to the credit card system are so restrictive they exclude the bank itself.
In 2004 the RBA stripped Visa and Mastercard of the right to decide for themselves who could issue and receive their cards, saying the system had to be open to any "authorised deposit-taking institution" supervised by the Australian Prudential Regulation Authority or to any member of a new class of "specialised credit card institutions" regulated by APRA.
The RBA's problem is that it isn't such an institution. It provides banking services to the Commonwealth government and many of its agencies, but it is unable to issue Visa cards and Mastercards in the same way as other banks. And it would like to. If it could, Australians might be able to pay their taxes by quoting their card numbers or to pay ASIC fees.
One possibility would be to submit to regulation by APRA, but the RBA would find that a little strange. Another would be to use one of the private banks to deal with the card companies on its behalf, an only-slightly more dignified solution that it is using for the moment.
Instead, its consultation paper released on Tuesday proposes revoking the access regime, allowing Visa and Mastercard to once more decide who they allow to issue and accept cards in their name, knowing that as an organisation with an impeccable credit rating it is likely to be on the list.
The paper makes the point that Visa and Mastercard are not what they were. A decade ago they were owned by the banks and keen on restricting access to their infrastructure. Each is now a public company, keen to expand business.
The change would make it easier for non-banks to issue so-called "pop-up cards" that can be used just once, sometimes as part of promotions in the travel industry, sometimes so that employers can have greater control over their employees' expenses.
The bank also proposes a third course, which is to keep the access regime in place but to broaden it to include "all entities conducting banking business in Australia" - a definition that includes itself.
Removing all restrictions would allow retailers such as Coles and Woolworths and big service companies such as Qantas and Telstra to issue cards in their own right, without partnering with a bank.
The Reserve Bank has asked for responses by July 8.