If you are a BANK… you can do anything you want to on a PIN DEBIT network (you control).. For example, First Data owns STAR.. they are leveraging the Star network with Cardspring to transfer non payment information (offers/incentives). This is a great example of how to construct a solution within the constraints of existing networks
WFC is brilliant here. By leveraging their primary asset (customer relationships) they have jumped to the top of the line in a new ability to deliver services, and capture unregulated payment revenue. Think they need to work quickly to ensure retailers see an upside to expanded Amex transaction volume (see payment enabled CRM).