OPEN BANKING: PSD2's self-defeating requirements need addressing for true Open Banking to exist

We've noted before that the implementation of Open Banking (via the EU's Second Payment Services Directive or PSD2) may not be going according to plan. As a reminder, European legislation -- PSD2 is supposed to expose incumbent banking data via structured APIs to third party providers (TPPs) that want to build upon banking information and money movement. In theory, this lowers the stickiness of bank accounts, allows data to travel safely into aggregators and apps, and lays the groundwork for financial bots and agents that make shopping decisions.

Surely, neobanks would benefit from the ability to see and move these traditional assets. Well, maybe not. According to a new report by Fingleton and the Open Data Institute for the Open Banking Implementation Entity (OBIE), "The narrow focus of the Open Banking APIs limits their potential to drive wider competition in the financial sector, for example by helping customers shop around for better interest rates on savings accounts or cheaper mortgages." Additional examples of where the PSD2 mandate failed TPPs included (1) the lack of refund functionality, and (2) the lack of functionality for customers to pre-approve payments to a merchant -- similar to a subscription debit -- instead of a customer having to manually authorize each payment,

The remedial actions for the OBIE included (1) mandate "variable recurring payments" making it cheaper for merchants to receive customer payments, (2) revised customer consent rules to remove the need for customers to re-authenticate with each TPP through their bank every 90 days, and (3) the extension of Open Banking -- beyond current accounts -- to a more diverse range of products such as mortgages, insurance, pensions, and savings accounts. Subsequent to the report's publication, the OBIE announced the initiative to create "Premium APIs" that provide a commercial incentive for banks to address the above listed failures. Those are going to need to be some considerable incentives to get the incumbents to budge. Hopefully, if the TPPs trying to build experiences don't want to deal with incumbent infrastructure, there is always Bitcoin. 


Source: ODI & Fingleton (Open Banking Report for the OBIE)

INTERNET OF THINGS & APIs: The Internet of Things wasn't really a thing

Look, we love our buzzwords as much as you do, but this one has gone on long enough. The Internet of Things (IoT) is one such buzzword that is synonymous with product design, connectivity, infrastructure, and the future. Pretty broad right? To enforce this point, IoT can be simply defined as a network of interconnected digital devices in order to exchange data. Doesn't this sound like the definition for the internet? Effectively the Internet of Things is purely a term of scale, in which the "things" are any device that can be connected to the internet. The issue of scale has resulted in a mass of tech companies -- such as GoogleAppleLGSamsung, and Huawei -- each building and protecting their own IoT solution vertical with which they compete. An example of such verticals that fall into the scope of IoT include automated temperature, lighting, and security controls for your home, or fleet tracking and driver safety controls for a logistics company. For a consumer, having multiple apps to control the functions of their home is no better than using the analogue controls IoT sought to replace. For regulators, ensuring the safety, reliability, standardization and efficiency of each solution has massively hindered the deployment of IoT across the globe.

The assumption that the future of technology relies on faster, better, newer, and more hardware is debatable. Something that big tech companies like Apple are starting to realize. Rather, the future of technology should be centered around machines working together to make magic. How this is achieved is via the gatekeepers enabling the solutions -- Application Programming Interfaces's (APIs). Essentially APIs store and dispense both data and services for hardware and software. Enabling the data source(s), the data consumer(s), and the tech manufacturer(s) the opportunity to compete within the foreign land of tech platforms (i.e., App stores and e-commerce). This generally means prices fall and economic rents go to fewer winners that have strong APIs, integrations, and a nimble balance sheet. Consumer facing services such as ZapierIFTTT, and Signalpattern form part of an emerging segment, allowing for consumers and businesses to connect devices and services together to build truly innovative solutions. Similarly, payments Fintech InstaReM launched an API-based digital B2B platform enabling companies to create their own branded credit cards. Via APIs to InstaReM's card-issuing platform, customers are said to have greater control over the creation, distribution and management of card accounts -- a Visa-supported parallel to Brex.  

For the network of interconnected digital devices in order to exchange data to succeed device manufacturers need to open their APIs, like items on a menu, and users assemble them together into the perfect meal. The level of inter-connectivity we are talking about here is, for example, when the machinery in a factory stops operating whenever a maintenance person swipes into the main floor, or your car's navigation depended on your calendar, financial well-being/budget, and personal well-being (taking scenic routes when stressed). That is truly an internet of API-enabled things. READ MORE.


Source: Nordic APIs (APIs power the Internet of Things)

NEOBANKS & FINTECH: Ride-hailing apps are becoming the Uber of Fintech

Steve Jobs defined a key distinction that stuck with many entrepreneurs -- is your company a Product or a Feature? It's bad to be a feature -- you are just one widget in someone else's platform. It's good to be a product -- you fit into many environments and use-cases. What we are observing now is that Fintech product is being transformed into a platform feature by non-Fintech players -- specifically ride-hailing apps like Uber, Lyft, and Grab. 

These ride-hailing giants have built their empires by making the burden of payments a truly seamless experience for their customers. Which is why the potential for them to expand into Fintech and financial services far outweighs the need for new forms of transportation -- autonomous human-carrying Uber drones or Lyft trains. The kicker being that their robust platforms and/or large customer bases create ripe cross-sell opportunities. 

Take Grab -- the $14 billion-valued ride-hailing giant that acquired Uber's Southeast Asia business last year. Since then, Grab has faced growing competition from Go-Jek -- its +$9 billion-valued rival who is backed by Google, JD.com, and others. Forcing Grab to earmark financial services as a core pillar of its strategy for regional dominance over Go-Jek and financial incumbents who are disadvantaged by the lack of financial services infrastructure and unified credit scoring. Since then, Grab has partnered with Mastercard to launch a prepaid card to target the unbanked, spun out its own financial arm -- Grab Financial Group, which brings group payments, rewards & loyalty, and insurance to its drivers and customers, and recently announced a co-branded credit card with Citi. 

Uber's initial foray into financial services was the launch of Uber Cash -- a digital wallet allowing credit to be added in advance via prepaid cards. Since then, the popular ride-hailing app has partnered with Venmo for payments, Finnish-Fintech Holvi for offering financial services access to its drivers, Flexible car-leasing startup Fair for car leasing, a credit card in partnership with Barclays for loyalty and promotions, and a recent hiring spree showing signs of a potential New York-based Fintech arm -- much like that of Grab's. One of the interesting outcomes from such an arm would be the potential for a native Uber bank account, which would help remove the ride-hailer's reliance on the existing banking system -- Card processing fees alone cost Uber $749 million in 2017 -- to get paid and pay its drivers. Such a move would see Uber partner with cheaper and more agile low-profile FDIC-insured banks such as Cross River, Green Dot, or Chime, rather than have its own charter or partner with larger institutional banks. This is likely, as US-based ride-hailing companies such as Uber and rival Lyft have come under scrutiny by lawmakers to consider their drivers as employees rather than "independent contractors". Both Uber and Lyft argue that such a move would be cripplingly expensive -- Quartz estimates the cost to be $508 million and $290 million respectively. Our question is, to what extent would native bank accounts offset these potential employee-related costs?

Fintechs such as Square and Stripe are prime examples of digital startups that have used their enrolled bases of small merchants to cross-sell other services. Ride-hailers are starting to take note by replicating this model -- using their extensive base of both drivers and riders to build out their own ecosystems.


Source: Grab (via Business Insider), Grab Financial (via TheDrum), Uber (via Business Insider), Uber Credit (via Techcrunch), Uber-Lyft wage concessions (via SFChronicle)

PAYMENTS: E-Commerce sales growing at a "solid" 12.4% vs. Retail's 2%. What is driving this?

Last week was made great by the release of Mary Meeker's Internet Trends report. If you haven't seen the 2019 version yet, what are you waiting for? Time to read 334 slides in 30 minutes. The key takeaway we remember from last year was the broad digitization of commerce, with E-commerce living in the web and in our mobile apps, plus the augmentation of the physical space with embedded digital commerce. See entry 1 above. 

Ecommerce is still very much a highlight of this report. Specifically, the fact that US ecommerce sales growth is noted as being “solid”, reaching 12.4% year-on-year growth in Q1 of 2019, up from 12.1% in Q4 2018. Similarly, physical retail sales are noted as “solid”, albeit growing more conservatively at 2%. Additionally, customer acquisition costs were found to be rising to unsustainable levels.

What we found most interesting about the reported ecommerce growth in 2019, is its sources where not only from the expected channels i.e., offline sales shifting to online, or search-directed sales on ecommerce websites. Rather, Meeker’s report tells a story of retail becoming a feature that is integrated into apps and services of every kind, and ecommerce reaching new communities and demographics: (1) Social apps -- like Kakao, Line, and Instagram are increasingly integrating transaction and ecommerce features. The monetisation of features embedded in large scale attention platforms makes sense.(2) Ecommerce platforms are making delivery a focal point of their offering. Much of the friction on these platforms lies in the delivery phase of the customer's journey with either cost or time creating negative experiences. Data-driven and direct fulfilment is growing rapidly with agile and low cost third-party platforms -- such as Rappi -- helping to remove such friction points. Enabling local merchants to expand their online presence, and improve access of their ecommerce platform to customers in entirely new and traditionally inaccessible markets. (3) Online grocery formats in China are competing for consumer wallet share. Here, Meeker showcases the sheer variety of grocery retailers competing using different formats for customers to access them i.e., digital-only stores, physical stores with a native digital app, digital-only stores that leverage a franchised community of retail partners to provide the goods and deliver.

It's always good to know we were right. As our 2019 predictions state "customer acquisition costs will rise and the digital model will become more competitive as servicing costs commoditize at a cheaper price point. What we mean is that if everyone -- including large operating businesses -- will understand how to market to and serve Millennials, driving away the arbitrage opportunity Fintech companies have had to date". We'll take that!


FINTECH: From mobile networks in Africa to global eCommerce platforms, marketplace banking is on the rise

It has long been the promise of regulations like PSD2 or plain old web-forced transparency, that banking information and products get popped out from behind the curtain and made to compete within the foreign land of tech platforms (i.e., App stores and e-commerce). This means prices fall and economic rents go to fewer winners that have strong APIs, integrations, and a nimble balance sheet. The promise is a utopian Fintech ideal in which one’s cash, savings, debts, bills, tax, investments, and assets exist in a single platform that is fast, secure, and globally accessible. And where the long tail of banks evaporates into commodity providers as their regulatory and distribution moat falls away. The symptoms of this happening aren't difficult to find either.

Take open banking platform Plaid – a US-based data aggregation platform that powers authentication and banking detail provision -- not "personal financial management" only -- for any tech startup that wants your bank account and routing number. The platform has built a major open financial data infrastructure for over 15,000 tech startups such as Venmo, Acorns, Robinhood, and Coinbase. It goes without saying that these startups Such success has driven the platform to the shores of the UK, in which it is already connected to over eight of the largest digital-only banks. The claim is that the platform will give UK Fintech businesses access to 70% of all personal current accounts and promote the democratization of financial service offerings to customers between the US and UK. Essentially, these open banking platforms -- Tink and Bud included -- aim to be the Amazon Web Services for financial service companies.
A less obvious but just as important example is in eCommerce, where marketplaces like Amazon are partnering with financial institutions to shift the flow of retail into its walled garden -- Bank of America for merchant lending, American Express for SME credit cards, JP Morgan for checking accounts, and so on. The goal here being to monetize a sticky business customer (SME) within the eCommerce platform over and over again -- remember the cross-sell is bigger than the sell. We found two noteworthy new developments in this department. (1) African mobile network operator MTN is building a digital marketplace platform to offer everything from financial products to household goods. The platform will be bootstrapped to MTN's existing mobile money app MoMo, with hopes of it becoming a leading full service banking and eCommerce platform, offering loans, savings accounts, insurance, as well as third party products. The reach of such a digital service would be massive with MTN operating in 22 countries with over 200 million customers. Compare that to the "Amazon of Africa" eCommerce giant Jumia's 4 million customers across 14 countries and you have yourself a juicy competitive advantage situation. 

(2) eBay has just announced a partnership with Santander to offer loans to its 200k SME customers – similar to the Amazon BoFA cooperation. The vision is that eBay have proprietary data that that could indicate SME revenues before those revenues even materialize -- for example: the traffic on product pages by consumers on the eBay website. Here the story is the same where financial institutions are leveraging the customer base and stickiness within eCommerce platforms to sell their products, with the intention to either up-sell or cross-sell them to higher margin products at a later stage.

Overall, it is clear that there is a movement to consolidate financial products and services into digital marketplace platforms is afoot. Should this concern existing banking incumbents? Not entirely, as such institutions still hold the resources sufficient to rapidly spin up their own Fintech startup -- Goldman Sach's Marcus and Well Fargo's Greenhouse. For those that don't, and rather partner with Fintech marketplaces -- the incumbent becomes the client of the Fintech -- the risk is clearly commoditization. Why would anyone choose the pain of shopping for and opening a third-party bank account, if one comes pre-installed in our virtual shopping assistants? Here, Fintech's have their cake and get to eat it.


Source: Novobrief (article), Plaid screenshot (Plaid Blog), MTN MoMo (MTN Cameroon)

NEOBANKS: JP Morgan Chase's Finn proves that digital banking is tougher than you think to get right

JP Morgan Chase's Finn -- is a bit of a hybrid -- a digital app loaded with features suited for its millenial target market, as well as, a digital branch mechanism to transfer customer's funds to new Chase checking and savings accounts. The reason for this was to attract customer's that sought to bank with Chase, but had little to no access to a branch. The digital banking app launched in 2018, and soon proved that the Chase brand was in fact best positioned to provide that combination of services to Finn's 47,000 customers.

Three important takeaways from this: (1) Consumers who open accounts with digital banks don't do so because they want a bank with no branches. A higher value is attributed to better financial management tools, rewards, and interest rates. (2) A differentiated service offering than what exists in the market is critical to garner significant adoption rates amongst a younger target market. Finn didn't offer its consumers -- nor existing Chase customers -- anything they couldn't get elsewhere. (3) A lack of understanding the market you are attracting, is probably the cause of poor uptake. In a recent poll by Cornerstone Advisors research – Finn had clearly tailored its market to the wrong demographic with just 7% of 20-something Millennials and 6% of 30-something Millennials said a digital bank would be in their consideration set. Contrast that to the 9% of Gen-Xers and 7% of Boomers who said they would consider a digital bank.

This is Fintech at its best -- multifaceted, difficult, iterating on a solution to cater to the largest customer demographic as possible. Access and democratization are its core values, even if it is not decentralized nor truly disruptive. The kicker is if you get this wrong, then call it a day. 


Source: Finn Bank (Via Chase), Insight Vault Q4 2017 (via Cornerstone)

CRYPTO: Coinbase's new Visa debit card wants to assimilate cryptocurrency and fiat accounts

We still believe that the absolute largest roadblock to economic activity using cryptocurrency is the barrier to entry in user experience (followed closely by financial instrument packaging and bank buy-in). And in our write-up of Samsung's crypto phone gamble, we stressed that there should be no difference -- from the customer view -- in using a credit card in a digital wallet, and using a self-custodied digital asset. Well it seems the folks over at Coinbase were paying attention, as last week the crypto trading website unveiled a Visa debit card that lets users buy things with fiat money converted from cryptocurrency stored in their online Coinbase wallets. Users can take advantage of the full neobank treatment with Coinbase's app providing nifty visualisations on your spending behaviour, and security controls such as disabling the card if it gets lost or stolen. The card will only be available in the UK, with a wider European release to come later this year. UK users can expect to be charged a 1 percent transaction fee and a 1.49 percent conversion fee, totalling 2.49 percent for every transaction using the card (2.69 percent in Europe and 5.49 percent elsewhere). These fees seem high when we compare them to the C2B credit card transaction fees for US-based retail and online merchants at 2.2 percent and 2.52 percent respectively, per $100 transaction -- as outlined in our latest Payments keystone report. The big question is -- is this new? and our answer is not really. Revolut, amongst others, has offered the ability to make transactions using cryptocurrency for well over a year, however, the merchant doesn't actually receive bitcoin, rather the app does a conversion back to fiat to make payment. From a transaction standpoint, we see Coinbase as no different, as they are simply taking exchange custodied wallet holdings and converting them at the spot rate to make payments. Cryptocurrency-native transactions are difficult because the distributed ledger (Blockchain) requires each transaction be verified through network consensus before it is finalized, which for Bitcoin is 10 minutes -- imagine waiting 10 minutes for the credit card machine to print the transaction slip?. What is notable about Coinbase's card is that it helps cryptocurrency adoption by assimilating one's crypto holdings at Coinbase with their fiat holdings at a bank, promoting a better user experience than before.


Source: Coinbase (Coinbase Card via Twitter), ComputerWorld (Coinbase Card)

NEOBANKS: Monzo and Tandem seek massive new raises whilst RBS's Bó seeks to shake things up

Just months after raising £85m in a Series E fundraise, it seems as though neobank Monzo's aspirations for US dominance is being assisted by means of a £100 million in further funding, in a new round led by US-based VC and accelerator Y-Combinator. Such a raise would see the coral-carded digital bank valued at around £2 billion, positioning it on par with rivals N26 and Revolut. Whilst neobanks who focus on current account products like Monzo drive massive consumer adoption yet are inherently loss making, those who build lending and savings products through credit cards such as Tandem Bank, have lower user adoption rates but higher revenues (£5.1 million in 2017 compared with Monzo's £1.8 million). As such, it's not surprising that Tandem Bank are looking to secure an investment in the next three months, which is likely to be larger than the £80m it raised when it took over Harrods Bank last year. And in true neobank fashion, the ex-Harrods bank is looking to expand into continental Europe over the coming year. Finally, RBS has just exposed their neobank play with Bó -- a new online-only bank RBS has created, similar to Goldman's Marcus, to rival the likes of Monzo, N26, and Revolut. The specific target market being the 17 million UK residents with less than £100 of savings in their bank accounts. With the aim of this to “nudge” users towards ways of saving money by providing them access to a “marketplace” of different providers — from rival financial services companies to energy companies. Should Starling be worried?, only if they didn't help RBS build it, which they did. I won't say we called it, but have a revisit to our 2019 Fintech prediction, and see for yourself.


Source: Techcrunch (Monzo), Fintech.Global (Challenger Bank Analysis), Finextra (Starling help RBS)

GAFA: Snap seeks to colonize the web one Tinder profile at a time

From camera-mounted sunglasses that failed to be welcomed in any social setting, to Bitmoji's creepy cartoon depictions of reality, it seems like Snapchat's parent company - Snap has tried it all to stay relevant. Especially, when Zuckerberg's army of clones - boasting an impressive 1 billion daily story users vs Snap's 186 million, threatens the story-based core social media model of the app,. Well, it seems Snap has yet to be snapped. At its recent partner summit, the social media company announced its launching StoryKit - a plan to allow apps like Tinder the ability to embed Snapchat stories into their app. The incentive being enhanced engagement and security for the partnering app, whilst Snap additionally benefit from the data they gather from users using their native camera. Quite the colonization strategy you might say. Then again, with the day-to-day data privacy-exploitation headlines streaming from Facebook HQ, it's a no-brainer that advertisers, content creators, and businesses alike are looking to alternatives such as Snap to save them from being victims in the Facebook apocalypse. 


Source: Statista (Social Media Stories)INMA.org (Storywars)

ONLINE BANKS: $22 Billion from Fiserv for First Data, creating a Public Banktech utility

In one of the most massive Fintech headlines in recent history, core processing company Fiserv is buying merchant acquirer First Data in a $22 billion stock deal. Much of the thinking about the combination is about scale (12,000 financial services clients plus 6 million merchant locations) and synergies ($900 million in cost, $500 million in revenue). The combination is well engineered in a spreadsheet, and has the strategic rationale of defending a competitive position by vertical consolidation -- "if we own all the Payments and Banking products, we'll touch all the clients". Some folks also mention the pressure on revenues across the industry, as Fintech start-ups create transparency and competition in the space. Consolidating business lines in such an environment makes sense, though perhaps this is an afterthought at the scale we are talking about.

There are two angles we want to consider. The first is that enabling financial technology -- i.e., the infrastructure needed to manufacture something financial -- trends towards both utility and monopoly over time. It is a utility in the sense that it should be dirt cheap, easily available, and nobody in their right mind would want to rebuild one (also note utilities are public, as in owned by the government). It is a monopoly in the sense that a single player should win the whole market, consolidate all the costs, and charge only at the margin. As technology evolves, the threat of entry by new players like Alipay and Whatsapp is almost as scary as the actual entry of such players. The infrastructure provider would be wise to compress their own margins to make entry by smarter, faster, better players unattractive. A corollary to this line of thinking is that the long tail of small banks and credit unions rent software from utilities, while firms like JP Morgan and Goldman Sachs get to hire AI PhDs from Google. 

The other lens to think about is where the innovation and associated growth happen. We recently re-discovered 2015 slides from venture firm Andreessen Horowitz, which showed how the flow of investment value in technology -- i.e., the investment returns for taking on some risk -- are happening in large part in the private, and not in the public markets. Said another way, private market valuations no longer have a meaningful ceiling (thanks to SoftBank and Tencent), and therefore private investors get to capture all the capital gains from fintech disruption. To go public merely is to monetize those private gains, whereas in the past going public meant getting capital for growth. That means we expect Payments and Banking industry innovation to stay private, and for large players like Fiserv and First Data to rent or acquire them, rather than lead and source them. 


Source: Business Wire (Press Release), Andreessen Horowitz (Presentation on Venture), Company Websites for screens

ONLINE BANK: Killing the Banks Softly with Plaid, Cross River, and Open Banking

A great set of symptoms this week for the theme of banking-as-a-service / open banking. To recap, due to regulations like PSD2 or plain old web-forced transparency, banking information and products are getting popped out from behind the curtain and made to compete within the foreign land of tech platforms (i.e., App stores and e-commerce). This means prices falls and economic rents go to fewer winners that have strong APIs, integrations, and a nimble balance sheet. The long tail of banks evaporates into commodity providers as their regulatory and distribution moat falls away. Maybe true, maybe just a fun story!

Symptom number one is the $100 million raise of Cross River Bank, of which 75% came from private equity firm KKR. Cross River provides the balance sheet to Affirm, Coinbase, and TransferWise. Those companies in turn are building credit-as-a-service into points of sale (think Stripe), custody and banking for digital assets (dozens of millions of users), and the destruction of international money transfer margins. Finance is correctly integrated as a product/feature within a much more meaningful and long customer journey. This means customer ownership leaves the product manufacturer and goes to the point of actual economic activity.

Symptom number two is the $250 million fundraising into Plaid, a data aggregation company, backed by Mary Meeker as her coup de grace from Kleiner Perkins. Remember Europeans, there is no PSD2 in the US, so we have to screen scrape the information out of the protesting bank hands. In the early 2000s, a number of data aggregators were built, the winners of which were Yodlee (bought for $500mm-ish by Envestnet), ByAllAccounts (bought by Morningstar), Finicity and a few others. Plaid's venture valuation of $2B+ boggles the mind, but the answer is in the product. It powers authentication and banking detail provision -- not "personal financial management" only -- for the hungry host of Silicon Valley. Any tech startup that wants your bank account and routing number goes to Plaid, not to Yodlee. Thus is built a major open financial data infrastructure for tech companies in the US. And in Europe, open banking is progressing bit by bit, with the largest incumbents opening the door to barbarians. It's a fun story.


Source: Payments Source (Cross River), Open Works (APIs), CNBC (Plaid), Fortune (Plaid) 

ARTIFICIAL INTELLIGENCE: Machine Readable Regulations


We started with two difficult entries to highlight how the major platform shift technologies, blockchain and AI, are bringing out some of the worst impulses in human beings to take advantage of each other. And further, these tendencies become enshrined in software -- from decisions learned out of data, to bots endlessly begging to steal your money. From this perspective we pivot to Regtech, and in particular to projects that we think could be antidotes for the malaise.

The first is an effort by the FCA to explore offering regulations in a machine readable format. That means that a regulator would provide standards and perhaps even executable code that could plug into Fintech software stacks. Imagine Python's Django, but with a regulatory module that pre-packages data formats for compliant reporting. Similar ideas have been floated by self-regulatory organizations in Crypto, looking to build into tokens the ability to determine regulatory requirements, like accredited investor status or KYC/AML. But to do this at the level of the regulator is far more meaningful because (a) there is way more law that needs to be translated, which relates to real rather than imagined economic activity, and (b) this regulation is a result of an established governance process, which is still immature in decentralized communities. Imagine putting all of the FCA on Github and satisfying requirements through something like the Digital Asset Modeling Language. Compliance costs would actually become trivial.

But now is a moment of transition. Case in point, last week we attended the fifth London cohort of the Barclays Techstars, where a RegTech startup called Audit XPRT introduced their automated audit and compliance solution that uses machine learning to extract structured rules from unstructured paper documents. The aspiration is to reduce compliance-related costs ($270 billion) by 90% and achieve 5 months of work in 5 minutes. Another example is Governor, which creates dashboards of real-time tracking across Risk, Compliance and Corporate Governance. Or take Suade, which tags existing data with an overlay that maps to regulatory requirements and provides apps out of the box against which the data can be checked, no disruption to the bank’s current architecture. It may feel slow, but the law's getting digital.


Source: Github (Ethereum proposals), FCA (machine readable initiative), Digital Asset (DAML), Thomson Reuters/Tabb Forum (Infographic), SuadeGovernor (infographic), AuditXPRT

REGULATION: The GDPR Battle over Data and Identity - IBM or Crypto

Source: Text of GDPR,  Truata   (click to enlarge on both),  Pillar Project

Source: Text of GDPR, Truata  (click to enlarge on both), Pillar Project

GDPR is about to hit Europe. The regulation is designed to reverse the power dynamic between large tech and finance companies, that gather and save user data, and the individuals whose data is at stake. The regulation creates a right to be forgotten (on the Internet!), the right to move personal data between companies, data protection standards, and other consumer-friendly amendments. The implementation of such regulation is massive, and IBM and Mastercard are teaming up by creating a company in Ireland called Truata to deal with the change.

Mastercard has immense amounts of financial data. IBM has cloud, blockchain and artificial intelligence capabilities. Will it thus be the tech and finance giants that solve the very problem the industry has created? Or can this be done better by the Crypto economy? Open source movements have for decades tried to solve the data question in favor of consumers -- see for example the FreedomBox project or the Ello social network. But there was not the financial leverage to re-engineer the entire direction of power and information on the web.

Source:  Truata

Source: Truata

Crypto projects like Pillar, on the other hand, are motivated to create user-controlled wallets of private data which can be tokenized and then submitted as part of some particular economic activity. This can include medical records, financial activity, KYC/AML and government data, attention and browsing information, and so on. When such information sits at an address controlled by a particular owner with a particular wallet on a blockchain run by a decentralized, shared, distributed network (rather than one company), the promise of what GDPR is trying to accomplish becomes technically trivial. Of course the user can allow or revoke access to her data at will, and move it between different services securely! We think regulators would be well served in understanding this data architecture instead of being upset about the enabled rise of digital assets.

Source: Text of GDPR,  Truata   (click to enlarge on both),  Pillar Project

Source: Text of GDPR, Truata  (click to enlarge on both), Pillar Project

FINTECH: Prediction Surprises for 2017 and a Year in Review

It's prediction season. But before we get into 2018 and the coming trends (which we'll publish on January 2nd), we wanted to grade ourselves on 2017. How did we do in thinking about the future, relative to what happened? And more importantly, why? None of the prediction text is edited -- we add a subjective accuracy verdict, rationale for the score and an update on the sector.

Top 2017 predictions ( Published on January 03, 2017 )

(1) Revival of Cryptocurrency. 10 countries will have issued central-bank backed cryptocurrencies, and Americans will still not understand why that's important. And a multi-billion dollar enterprise will finally try to use the public Bitcoin blockchain as an application layer. 

Verdict: 85%

We got this one mostly right. At the end of last year, several African countries were looking into using a private labeled blockchain system to run their own crypto currencies, and we thought that would revitalize interest. Today, Russia is working on the cryptoruble, Japan the J-Coin, the US Federal Reserve isat least thinking about it, as are SwedenChina, and many others. Not to mention Venezuela. What can also be highlighted as progress are the capital markets settlement coins between large financial institutions, and the role of Ripple in developing international payments. Certainly the ASX announcement of adopting Digital Asset Holdings for its core trading system resonates here as well. What we were wrong about is just how much reach crypto currencies had into the lives of regular people, and the wealth transfer implications of the public blockchains (at least $400 bilion worth). Certainly none of the central bank issued crypto coins are yet worth anything when compared to Bitcoin.


Source: Cointmarketcap

(2) What Roboadvisors? Almost all roboadvice assets will be (by %) at Vanguard, Schwab, and Bank of America. Every large firm in the wealth management business will have gone digital. And we will see a large tech firm unexpectedly acquire an Acorns or Digit, and totally scare everyone that they're getting into finance.

Verdict: 90%

Ah, you have to feel bad for the unicorn roboadvisors. Betterment, Wealthfront and the rest have been in this game since 2008 or so. And yet, while their assets have been creeping up to about $5 to $10 billion each for the independents, powered by hundreds of millions in Fintech venture capital, the incumbents are putting up a massive fight. Vanguard alone has more than $65 billion in its digital hybrid, Schwab is likely over $20 billion, and of course Morgan Stanley,Bank of America Merrill LynchWells FargoDeutsche Bank and most others are in the game. And that's not to mention the asset managers, like BlackRock launching its digital wealth division. We haven't seen an acquisition of Acorns or Digit, but the partnership between PayPal and Acorns certainly looks like the right theme, and reminds us of Ant Financial and Baidu.


Source: Atlas (mid-2017)

(3) APIs Everywhere but Disappointing. In a watershed moment, every single large retail and corporate bank will have a Developer portal with open API keys. However, most of those APIs will do nothing other than pull information. Actionable APIs will be too expensive to use, but Venture Capital firms will overfund companies that tell a story about how to tap into them.

Verdict: 60%

So maybe we were a year early with this. The PSD2 (European regulation) date is in January 2018, and by then European banks are mandated to share APIs with the world. We thought that means banks would get ready and open up in advance, but instead we have a smattering of portals from select providers. This Daily Fintech thread has done a nice job of collecting those available. And there are many non-bank financial APIs, for example collected by Programmable Web orLetsTalkPayments. Still, we get a kick from seeing a Deutsche Bank developer portal site open to all. What's happened with this theme instead is (1) the creation of a few bank-as-a-platform startups as a venture backed investment (e.g., Cross River Bank in US, ClearBank in UK), (2) some existential hand wrangling by traditional banks as they watch Amazon move into lending and Apple move deeper into payments, and (3) Ethereum becoming the world's API and programming language for things like crypto-banks.


Source: BBVA

And here is the long form update on all the themes we track and the lessons we've learned this year.

Digital Wealth Management (Roboadvice)


  1. Angel and small Series-A funding into B2C roboadvisors will be pretty much $0. Series B funding into digital wealth management companies more broadly will be a little more than half that of 2016. 
  2. One digital wealth company from the second generation, like Acorns, Stash or Digit, will get bought for a ridiculous amount by an unlikely and surprising bidder.
  3.  Almost all roboadvice assets will be (by %) at Vanguard, Schwab, and Bank of America. 
  4. Everyone will start saying "artificial intelligence" instead of "roboadvice" but none of the business fundamental will have changed

Verdict: 75%

The higher granularity than in the top 3 predictions makes us more wrong. Indeed most roboadvisor funding and interest shifted to micro-investing services (e.g., StashAcorns) and financial chatbots (e.g., Earnest, Trim, Cleo). Instead of AI for roboadvice, people do say micro-investing or chatbots. The underlying business change, however, is that those services have now customers/users numbering in the millions. That implies very small accounts (about $1,000) at very large scale. And nobody has been bought just yet at a massive price.


Blockchain and Digital Ledgers


  1. Bitcoin, the technology and not the $ value of the digital currency, will be relevant again, and will see at least one multi-billion dollar company leverage its public blockchain 
  2. Big banks will try to patent troll their vertical solutions on top of the open source projects (Hyperledger, etc.) and will feel a sense of false confidence. It will be the year of lawsuits between the incumbent and startups communities, and open source will win.
  3. A blockhain-based production ready system,in either trading or money movement, will replace the legacy tech stack of a multi-billion dollar firm. It will actually increase costs in that year, and observers will draw the wrong conclusions even though the firm is more competitive in the long run.

Verdict: 90%

Still feeling pretty good here. While the Bitcoin $ value did become extremely important (climbing towards $20,000 at one point as futures on CBOE were about to launch), the technology of the blockchain has catalyzed over $4 billion in Ethereum-based token launches and thousands of related startups. Banks certainly are trying to patent their enterprise blockchain solutions, but that is unlikely to matter in the long run we think as open source code bases grow exponentially.


Artificial Intelligence


  1. Intel and AMD will keep making hadware chips optimizing for neural networks, and will drive the execution speed of image recognition and similar tasks to be 10x faster than what we have today 
  2. Real time video face recognition and editing will become a consumer toy. The first instance of someone releasing a viral video impersonating a politician using face-overlay and voice-replacement technology will get a massive negative backlash from conservative thinkers
  3.  A political movement against unemployment caused by self-driving cars, chatbots, and other AI products will rise, but it won't be able to articulate its concerns in a way our political system understands or can address

Verdict: 80%

It wasn't Intel and AMD, but NVIDIA that experienced the most growth resulting from their neural network hardware and developer resources. There is an arms race in determining who will power all our self-driving cars, trucks and augmented-reality devices. That race is not yet over. In terms of image editing and forgery of people's visages, check outFaceApp, which allows you to morph gender, age and other variables in real time. And as this Verge story describes, such algorithms ("deepfakes") are now being applied to adult content. This dangerous technology has not yet hit the mainstream and crossed wires with fake news and propaganda bots, but we have a better idea than ever just how dangerous AI-based communication has become, and the political effects it has had


Neobanks & Challenger Banks


  1. Incumbent banks will wake up and come down extremely hard on challengers and neobanks. They will fight them on mobile apps, chatbots, instant payments, and user experience. You won't be able to tell apart the website designs of new and old firms. 
  2.  Startups will try to do everything to become financial supermarkets. Expect to see lending, payments, banking, data aggregation and insurance combined in an attempt to grab at least some consumer attention. Regardless, neobanks will struggle getting to any scale beyond 10,000 early adopters.

Verdict: 75%

We were right that all established banks will trend towards becoming neobanks, with native mobile apps, chatbots and digital capability. One example of this is payments app Zelle vs PayPal owned Venmo. We also got the trend of unicorn Fintech startups becoming financial markets generally right (though it was easy) -- see SoFi, N26, Paypal/Acorns, or across to China as Ant, Baidu and Tencent build the Fintech of the future. We were wrong on the magnitudes. Incumbents aren't particularly scared of Atom or Monzo, as the tech banks struggle to get licensed or funded. The real story in licensing is the ability to hold deposits to lend out -- you know, to have a business model. The other part we missed is the scale of early adopters. Revolut has a million customers, as does Transferwise. You can say that those are international payments apps, to which we say, yes, you mean global banks?


Financial APIs & Banks as a Service


  1. In a watershed moment, every single large retail and corporate bank will have a Developer portal with open API keys. However, most of those APIs will do nothing other than pull information. Actionable APIs will be too expensive to use, but Venture Capital firms will overfund companies that tell a story about how to tap into them.
  2. BBVA and Santander will retain their position as marketing leaders of a BaaS offering, and we will start to see apps using their infrastructure.
  3. Someone will write a malicious app that crashes one of the API stores, generating tons of press and cyber security premiums.

Verdict: 60%

APIs are coming not with a bang, but with a whimper. 2018 will be the year where APIs really get test and implemented by incumbents, so we were off here. BBVA and Santander indeed do maintain their marketing positions, reinforced in a quantitative study we've done on bank innovation. But JP Morgan and Barclays also matter. And the biggest security breach of the year wasn't from these APIs, but from horrible security procedures at Equifax, exposing over 140 million Americans.


Chatbots, Conversational Interfaces


  1. Virtual assistants will start to appear in business locations, from banking branches to shopping experiences. People in customer service from a major brand will be laid off.
  2.  Amazon Echo, Google Siri and Google Home will start a nuclear war over the connected smart home. Like with its other products (Kindle, Fire), Amazon will lose its lead, especially as self-driving cars develop their own AI assistants. 
  3.  Facebook will get into the hardware business through an acquisition, and Messenger/Whatsapp will gain a physical form

Verdict: 60%

Hmm, maybe too much science fiction juice in this one. 2017 did see millions of hardware sales of virtual assistants -- Google Home vsAmazon Alexa has Amazon in the lead; Apple HomePod is nowhere. But anthropomorphic AIs are still in early development. As an individual data point, the incredible human renders from Soul Machines are starting to emerge from the uncanny valley. Not so much for the robotic Sophia, who despite being granted citizenship in Saudi Arabia is still a pretty creepy robot. And we're not aware of any hardware acquisitions yet to give the brand-name AIs tangible form. Amazon did buy Body Labswhich does 3D scans of human bodies, but that's probably to sell clothes in Augmented Reality.


Democratization, Regulation and Crowds


  1. As consumer protection is rolled back, equity and real estate crowdfunding experience major scams that lead to a public backlash.
  2.  Crowdfunding technology ends up creating asymmetric benefits for those already in power (think about who can really use Syndicate investing on Angellist, stock earning estimates from Estimize, or invest in Numerai's crowdfunded AI hedge fund). Income inequality becomes sharper despite equality of access to cheap investments.

Verdict: 100%

This happened in a surprising but big way with the crypto economy. Consumer protection did not exist at all as Initial Coin Offerings raised increasingly more capital in 2017, fulfilling on the original promise of crowdfunding. The year ended with over $4 billion in ICO funding. Scams and hacks proliferated, from the $170 million Parity failure, to fraudulent ICOs being shut down in China, to the hundreds of millions of crypto locked up in the Tezos litigation. And of course, the story would not be complete without the huge concentration of mining power in Bitcoin, the 170 crypto funds trying to profit from the opportunity, the billions "created" in the Bitcoin Cash fork, and the general distribution of wealth in favor of crypto whales. Black swan outcome.


Bitcoin & Cryptocurrency


  1. 10 countries will have issued central-bank backed cryptocurrencies, and Americans will still not understand why that's important 
  2. Another massive Initial Coin Offering like that of the DAO, over $50 million, will get people's heads shaking again. This one won't get hacked. Traditional Venture Capital firms will have invested 10% of the amount.

Verdict: 100%

Again on the ball here, especially around ICO funding. Think about Filecoin, the CoinList powered SAFT launch where venture investors put in $50 million at $0.70 per coin and regular investors bought $200 million worth at $2.50 per coin (give or take). That's a 20% allocation of the overall raise to private investors, and a massive uptake by the public. More generally, ICOs are a 10x increase on all annual venture investment into blockchain and Bitcoin companies.




  1. Venture investment will continue to pour in, increasing by over 50% globally.
  2. There will be a major exit at a price point comfortably above $100 million to a legacy insurance company
  3.  A scandal, either on the underwriting or regulatory side, like the licensing issue with Zenefits, will hit an insurtech startup and lead to renewed finger-wagging

Verdict: 70%

According to Coverager, venture investment in Insurtech sat at $4 billion in both 2016 and 2017, so the theme is not seeing increased YoY activity. But it's not falling off either. In terms of acquisitions, there is healthy appetite in the sector to modernize and own software assets, with over$10 billion being spent on M&A. One example that fits the bill isTravelers buying Simply Business (online broker for small business insurance) for $490 millionCVS acquiring Aetna is certainly a big deal, but that has more to do with the state of healthcare in the US than artificially intelligent drones powered by machine vision. There is also something to be said for China's Ping An Insurance going public at a $200 billion valuation, but it is a stretch to tie that to the predictions above.

And on the scandal point we did get it directionally right. SoFi, which does have an insurance offering via partnership, got into the news on account of the CEO's sexual harassment allegations, which led to his resignation amid the broader transformation of our society with the #MeToo movement.


Generational Shifts


  1. Generation Z will become a bigger buzzword than Millennials. Banks will wonder whether then Snapchat generation even knows if banks exist. 
  2. Valuations in the Gig economy (AirBnB, Uber, Task Rabbit) will crater, due to poor exit opportunities in the public markets and a churning contractor force dissatisfied with the lack of stability and benefits

Verdict: 50%

So Gen Z is definitely on the radar, and includes everyone born after around the year 2000. But Millennials still reign. The brightest example is Olaf Carlson-Wee, the 27 years crypto-king of Polychain Capital. And the gig economy is still around. Despite setback for companies likeUber in London, most private unicorns are continuing their journey, and the crypto economy in particular is adding more steam to pinballing valuations. The perceived failure of Blue Apron's IPO (falling from a $2 billion offering to $800 million), however, does create a cautionary example.


Attention Economy


  1. Snapchat holds on to its lead with younger demographics by understanding its customers better than anyone else, resulting in a flashy public exit that leads to multiple new businesses being started in the Los Angeles ecosystem, many of them in VR film
  2. One of Google, Apple, Facebook, Microsoft and Amazon will get into financial services in a way that makes financial incumbents extremely anxious, and will create public outcry. Financials will fail to understand why the tech firms are pursuing what seems like a dead end, but is really a way to engage with users and get more data

Verdict: 80%

Snapchat certainly did go public, at $24 billion, but has since fallen to $18 billion. But unlike the GAFA tech giants, it has not been perceived as an artificial intelligence leader, and its bet on Spectacles has not gone the way it wanted. But the big tech firms have indeed gone further into finance -- from Amazon's SME lending, to Apple and Facebook messaging payments, to Google's machine learning and financial cloud. We would highlight Amazon's digital lending moves as particularly threatening to incumbents, given their higher quality data for automated underwriting.


Virtual and Augmented Reality


  1. Millions of virtual reality headsets will hit homes across the United States, leading to an explosion of VR apps powered by Valve's Steam store, Playstation, and Google. 
  2.  A multi-billion dollar investment firm will open a virtual reality branch with live customer service, potentially on Google Earth or another VR world
  3.  Payments in VR will go live in Asia first, and will set the default behavior for the rest of us to follow. Credit card networks will open VR incubators or invest in VR companies.
  4.  Augmented Reality will still be mostly unknown to consumers, but will see multi-million dollar contracts between enterprise clients

Verdict: 85%

This is one is almost right, helped by Apple's latest hardware. Millions of VR headsets have indeed been sold to American consumers, but the general sense is that VR is not ready for mass adoption. Augmented Reality, however, has absolutely landed in the hands of consumers in the form of iPhone X, which comes with a ARkit, a development kit of software engineers. Ikea, Amazon and other retail apps are thinking about how to implement AR commerce, which we continue to think will drive payments activity. And of course, don't forget Alibaba's $20 billion revenue "singles day" shopping spree, in part powered by this technology.


Internet of Things & Wearables (IoT)


  1. Unsexy businesses in the "old economy" of manufacturing physical objects will position themselves as technology companies that generate terabytes of proprietary data. Hedge funds and other investors gladly pay for that data, repeating the experience of expert networks.
  2.  Self-driving cars continue to beat performance expectations and end up in production-mode on roads all across the world, leading to unemployment and outrage. Governments, trying to stem the bleeding, file lawsuits against tech companies for breaking regulations. It doesn't work.

Verdict: 50%

Broadly speaking, Alternative Data is a big growth area with many companies looking for ways to monetize their internal data exhaust. But the role of old manufacturers is perhaps not as drastically helpful as we had hoped (yet). As for self driving cars, we got it backwards. For some reason, the US House of Representatives is in favor of looser regulations for self-driving cars, and had passed a bill as such. Perhaps the auto industry as a whole, and not just Tesla, is seeing this as a way to boost its fortunes. And the cars aren't quite in production mode at scale, but may hit the roads by 2020.




  1. Human addiction to technology will reach a new height. People will spend more than 12 hours a day on their screens.
  2. The cost of sequencing the genome for an anonymous consumer falls to $25. Genome data can be made available between services via API.
  3.  3D printed organs will be implanted into human patients successfully.
  4. Scientists will claim they have simulated a full rat brain, which will become easier due to newly available hardware. There will be no implication in the physical world from this discovery.

Verdict: 65%

Yep. People now spend 12 hours per day on media. The cost of sequencing a genome is somewhere between a $1,000 and $70, depending on granularity. Organs are not routinely 3D printed yet, but a Wisconsin company offered to implant NFC chips into its employees. And no, there are no stimulated rat brains yet -- but here's a worm brain in a robot body and optical neural nets on a silicon chip.

ARTIFICIAL INTELLIGENCE: Amazon Lex for Wealth Management & Banking

Source: Amazon Lex

Source: Amazon Lex

We believe that bank-as-a-platform is inevitable for any meaningful financial institutions, and that it is more likely to be a narrow, utility-like platform than the dominant iPhone app store. A strong enterprise tech platform like Amazon is the main vector that would compress financial institutions from large manufacturers and distributors to regulator-facing APIs.

In wealth management, roboadvisor Betterment uses 20 different applications on AWS. In this excellent article, Financial Planning discusses how Amazon's conversational interfaces can become prevalent across the industry. What starts as a conversation about payments can turn into a conversation about financial products, planning, investing, trading and retirement. And talking, or even chatting, is far more natural than thumbing through buttons on the glass screen of your phone. But perhaps advisors can use the technology to their advantage, or build skills and applications to live in the Amazon ecosystem.

In banking, take a look at ING, and its vision of voice-activated digital assistants. The combination of open banking mandated by European regulation PSD2 (i.e., all banks have open APIs) and natural language processing means that data is free. Building the first voice-based financial data aggregator can create a lead generation engine for deposits and lending. Or it can commoditize all financial product manufacturing.

OPEN BANKING: Money2020 Copenhagen Learnings

Source: Money2020

Source: Money2020

We just came back from Money2020 in Europe, Copenhagen. It was a packed event with entrepreneurs, executives from financial services companies, and a few large tech companies (e.g., Google & Samsung). Our first takeaway is the difference between the American and the European events. The Las Vegas conference is organized chaos, with a sea of hustlers and deal makers trying to get access to hard-to-access investors and incumbents. Europe felt different, as if there already was a club with both incumbents and Fintechs in it, collaborating to build a more efficient infrastructure, and not looking to disrupt market share. More people wore suits.

Second, PSD2 in Europe will open up bank data through APIs in about half a year. GDPR will require privacy protections that many companies are hard-pressed to honor. This means that Fintech solutions targeting these areas are in direct demand. Conversations about open banking, and what will happen with bank-as-a-service, were paramount with speakers like Chris Skinner excited about solutions like ClearBank (UK clearing bank with APIs) and solarisBank (German BaaP solution). The US is lagging in such conversations, probably because banking in the 50 states is marginally better than banking across European countries with different regulations and rails.

Last, we presented the Autonomous NEXT view on how digitization will effect startups, financial services companies and high technology firms. Our presentation raised the question of how GAFA think about financial services and where that fits into the attention economy. We established that digitization has reduced revenues by roughly 50% across impacted industries, and the remaining revenue became digital, subject to winner-take-all dynamics. And although it's unlikely that tech firms will target the manufacturing of financial products as a standalone, it is likely that they will own much of the financial data of the world via enterprise blockchains, and control the client interaction through emerging communication interfaces.  Check out the slides for the presentation here.


Ideas are more powerful than the sword, and this one in particular is a direct preview of our future. As artificial intelligence and API-accessible data grow into conversational interfaces (voice/chatbot), we will rely more and more on bots to do our bidding. Not only will we ask bots to do things for us, but we will have bots representing our preference graph talk to other bots. Already, 8% of Twitter is automated accounts talking to each other. The CTO of HubSpot agrees in this thought-provoking article, suggesting how bots may one day replace APIs. Any B2C company that doesn't have a Facebook Messenger or Slack strategy is missing the bus, as we are already on the second derivative of the idea.