Payments network Visa announced a private label digital commerce app yesterday, noting that more than 40 banks have already implemented it, or are soon to.

Visa has said it will go to war with PayPal in ways “you’ve never seen before” — and it turns out one of those ways may be in the mobile wallet space. Payments is so dynamic (or messy) that everyone seems to be competing with everyone else, while also working together: PayPal, Square, the card networks, First Data, Dwolla, the big banks, even Starbucks.

Visa CEO Charles Scharf said last week that in payments if you’re not a friend you’re a foe, and sometimes even if you’re a friend, you’re a foe. PayPal drove transactions for Visa, Scharf said, but also disintermediated them, so on balance, it is a foe.

By this measure, Visa has a lot of enemies. But it also has more than 40 friends using its app, whose functionality is configurable by the issuing institution. The app includes mobile payment functionality using host-card emulation, an Android-only capability, as well as realtime transaction alerts that are configurable by the user, card controls, and a locator service for contactless payment locations, as well as issuer ATMs. Cards also provide balance and account transaction history, funds transfer capability, and fraud management solutions, said Joe Vause, Visa’s vice president, issuer processing and enablement.

On the roadmap are integrating offers and rewards, peer-to-peer payments using a debit card, and instant digital issuance in case of fraud.

Visa does not refer to the app as a wallet app, but rather a “commerce” app, but the focus is keeping the issuer’s card top-of-wallet for payments, which is more of a challenge with Apple Pay, Samsung Pay, and Android Pay.

One intriguing aspect of the new app is that it has the potential to incorporate Visa’s mobile location confirmation service, a fraud prevention tool that checks to make sure a user’s smartphone is near the POS registering a transaction. The tool has reportedly seen little adoption, but this commerce app, already live with banks, may change that. The tool will also help with adoption of Visa Checkout, Visa’s checkout solution for m-commerce, the company said.

The app containing so many different features, with more to come, is really more of a platform, said Todd Brockman, senior vice president of issuer processing at Visa. “The mobile app essentially expresses the platform,” he told Bank Innovation. Thad Peterson, head of emerging payment products at Aite Group, commented, “It’s more a platform than a product, and one of the challenges that I think a lot of people are having is that we’ve worked in a product-focused world, so it’s challenging to move to a space where it’s about tools and not products.”

The app is linked to the issuing bank’s mobile app in a manner similar to TD MySpend, which is downloaded separately from the TD Bank app in Canada, but is linked to it, although a user may move between the two, more or less seamlessly. TD MySpend is built with Moven technology, and the similarities don’t end there. The Visa mobile commerce app provides many of the same capabilities Moven arguably pioneered.