financial APIs

DIGITAL WEALTH: Schwab abandons desktop wealthtech as industry moves to open banking and investing platforms

We weren't planning to write about traditional wealthtech, but man, it's hard to pick your jaw up from the floor after reading this. Schwab Advisor Services, a $1 trillion assets under custody business, is selling its desktop portfolio management technology PortfolioCenter (which manages 2,300 advisory firms) to Envestnet for an "immaterial" price. The cost to Schwab of trying to pull those users into the cloud from desktop was higher than giving away the business, which generates about $10 million in revenue. Schwab retains its cloud version of the software, PortfolioConnect, as part of confusingly named AdvisorCenter. Reminder that one of the larger Envestnet shareholders is BlackRock, both a competitor to and manufacturer for Schwab's offering.

Fidelity paid up $250 million to buy eMoney, a cloud-based chassis for digital wealth management in 2015. The industry's conclusion was that custodians were going to be providers of technology in a freemium model, giving away tech and making money on capital. The independent wealthtech software houses (Orion, Black Diamond, ENV, AdvisorEngine, SigFig) could be in trouble. The Schwab sale of its client base given the cost of management legacy tech is enlightening. At the core, custodians are horizontal financial product platforms, enabling brands (e.g., RIAs, Cryptofunds) to deliver services to their customers. Sounds a lot like the other things happening in finance, which is open banking and data aggregation platforms building API-first layers. Can't be API-first with a desktop executable file!

So then what does a real platform look like in 2019? One take is something like Plaid, but we've discussed it before. Instead, take a look at Cambr. A joint venture between a community banking private equity firm (Stone Castle) and a core processing company (Q2), deposit products into tech apps are one integration away. Another version of a conceptually similar play is DiFi -- Digital Financial, previously Market76. Or, if we go one level down, every single bank participating in European open banking initiatives is becoming a financial product platform. See the awesome ranking Innopay has done of these below. And last, Apple itself. The hardware maker owns a massive attention and payments footprint, and is enabling none other than Goldman Sachs to launch a credit card. Apple is the platform, Goldman is the brand. We can see why Portfolio Center isn't super exciting. 

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Source: RIA Biz (Schwab sale), Schwab website, Fintech Platforms (CambrDiFi), WSJ (Apple & GS), Innopay

ONLINE BANK: Lessons from Monzo's annual report and £33M losses

We love unfair comparisons, but there's a reason behind the madness. Crypto currency exchange Binance is on track to print $1 billion in profits this year, while neobank Monzo has a £33 million loss to show for its £109 million in venture funding. Here's another one: Coinbase now has about $20 billion in addressable (custodied?) assets, while Monzo has £71 million (<£150 per account). One way to think about these companies is (1) store of value in crypto currency, vs (2) facilitating payments and commerce via fiat. And in this way the comparison evens out. The crypto companies to date have failed in making BTC a medium exchange, instead choosing to take economic rents through capital markets. The neobanks have hit the wall of trying to get profitable at scale, though Monzo's 750,000 users and £2 billion in facilitated payments transactions points the way. Looking at Revolut, we see about 2.2 million users and $18.5 billion of transaction volume. That's a medium of exchange story.

Two more thoughts on neobanks. The burn should slow down and economics seem likely to improve. On the revenue side, consider that most of the neobanks (Monzo included) started out as pre-paid cards that you load, with a nice mobile interface. That's pure cost, because the Fintech has to pay a third-party for each card while making no revenue of any kind. So Monzo's conversion from pre-paid card to current account under a banking license matters, because they can actually make spread revenue on deposits. On the cost side, the neobank claims to have reduced the cost of maintaining an account from  £65 to £15 -- pretty good operating leverage, but for the upfront cost of acquiring the customer. Since the market is crowded (Revolut, Starling, N26, B Bank, Finn, etc.), we expect venture funding to continue fueling the turf war.

And second, the implementation of Open Banking 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 parties 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 blog Open Banking Space, major barriers stand in the way erected by incumbents: "(1) lack of rich data or functionality on the account information APIs, (2) a regressive method coupled with very poor authorisation journeys on the banks’ platforms, (3) technical challenges such as that posed by a lack of immutable transaction IDs’, and (4) the absence of any bank-provided, data rich testing environments." Who will get blamed for this end of the day? The apps trying to build experiences, not the incumbents. But if you don't want to deal with incumbent infrastructure, there is always Bitcoin. 

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Source: Problems in Open Banking, Monzo (current accountsAnnual Report), Coin Telegraph (Binance), Treasury XL (PSD2)

ARTIFICIAL INTELLIGENCE: Machine Readable Regulations

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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.

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

REGULATION: Wells Fargo Forbidden From Growing by Federal Reserve

Source: CNN Money

Source: CNN Money

In the legal tradition, civil courts can do one of two things: (a) make a party pay damages for injury resulting from a particular action by that party, or (b) prevent the party from taking an action in the first place through an injunction. Meaning, they can make you pay for your mistakes with money, or put you in time-out. The Federal Reserve has just put the entirety of Wells Fargo in time out by forbidding it from growing until it fixes the mistakes that led to its scandals (like opening 2 million fake accounts, aggressive sales tactics, etc). Wells has already paid $185 million in fines, so this is a cherry on top. The firm can add no more assets over the level it had at end of 2017.

This move is a potent reminder of sovereign power, and how it could be effectively used. All this noise about scams, fraud, crypto, and Ponzi schemes -- all this can hit a wall. Every exchange can be shut down. Every bank can be unlicensed. Sovereigns have teeth, and they should not be afraid to use them (for the right reasons of course). This is far easier to do with well regulated centralized entities, like one of the world's largest public banks; decentralized crypto may survive even such an attack. Other examples of sovereign power can be seen in the transformative European legislation of PSD2GDPR and MiFID II. These regulations force open bank data into accessible APIs that support fintech, create a personal right to be forgotten that forces a company holding your data to delete it, and separate investment research from trading to prevent inducements. 

Similar force could be used to deal with propaganda bots and the overreach of the big tech companies. We know that GAFA are dealing with millions of fake accounts (not unlike Wells). But these accounts manipulate information, public opinion, commercial outcomes and financial investment. From this point of view, Facebook's block of crypto-related ads is self protection, trying to prevent the system from being coopted for financial manipulation and regulatory response. See how the New York state Attorney General is going after the firm that manufactured fake accounts. We can also look at the healthcare alliance between Amazon, JP Morgan and Berkshire in this light -- a way to start remedying social unrest resulting from automation and increasing concentration of wealth, a first step to universal income.

One solution is fairly simple. Until Facebook, Google/Youtube and Twitter get their social news problems under control, they could be restricted from adding new accounts over the level of 2017 year end. Now that would be one way to fix the attention economy.
 

OPEN BANKING: Regtech as Point of the Spear

Source: Latham Watkins, IFLR

Source: Latham Watkins, IFLR

We really enjoyed the International Financial Law Review conference on Fintech in Europe. It was refreshing, surprisingly, to hear about innovation from the point of view of the lawyers, who focused much more on the nuts and bolts of deploying technology in a highly regulated market. Knowing the Fintech sandbox can save years of wrong-headed effort. We highly recommend you review the notes from the sessions.

A couple of conversations stuck with us. First, you are likely familiar with PSD2, which is forcing banks in Europe to adopt an open-API approach to customer payment data and access. But, although PSD2 would enable Fintech companies to get data from APIs, it impedes screenscraping and requires data protection. This could be a net loss for startups according to Davis Polk and neobank Monzo. Separately, everyone agreed that Regtech as a category will only be successful if its startups solve real problems, and that those startups should be led by a team that has industry experience and knowledge, and not just hustlers. Lastly, the conversation around intellectual property that startups own pointed to a key issue in Fintech. How many startups that focus on customer experience actually have a patent? Are they missing out, or do they just not have any valuable intellectual property (and are therefore not defensible in the long run)?