PayPal and other supposedly high-cost payment providers have "cost Australian merchants A$125 million in the 2013 financial year," Visa International said in its submission to the Financial System Inquiry.Visa listed four other payments providers as beneficiaries of "unregulated payment systems [and able to] impose higher merchant charges."These were American Express, Diners Club, China UnionPay and Google Wallet as well as PayPal.Visa said these five had "disproportionately grown at the expense of regulated payments systems, resulting in an estimated cost to merchants of more than $770 million over the last 10 years."There is an underlying regulatory flaw in the Payments System (Regulation) Act, namely that the mechanism that leads to regulation is not automatically applied to all payments systems."Visa said there was a "subjective discretion to the RBA to choose what is and what is not a 'payments system' which in turn sees some systems regulated and others left unregulated even though they are fierce competitors in the marketplace."American Express is the run away beneficiary of the RBA's model for payments regulation, Visa believes."We see a compelling case that the majority of new market share attained by Amex since 2003 is attributable to the expansion of these non-regulated, four-party, companion model cards," that are issued by banks, Visa said.Visa proposed that the Act "be structured so that all such payments systems are automatically required to seek a license prior to commencing operations in Australia.It also wants "all interchange and interchange analogues equally regulated. "