keep their secure element in the SIM
If the secure element is in the SIM and so managed by companies that aren't banks, and aren't subject to banking law, does that mean that in case of fraud the punter is unprotected? Does delegating this function to the SIM mean that said punter has also violated bank rules on keeping secret info secret, and so isn't protected by the bank either?
Sounds like a losing proposition for the user, to me.