FDATA ANZ and our members are pleased to offer this submission in response to the request for feedback on the proposed amendments.
Following recent notification by the UK Government, we are delighted to announce that the Global Open Finance Centre of Excellence (GOFCoE) has been successful in acquiring a seed fund of £23m by way of grant, to cornerstone its investment strategy.
This major award is part of a much larger funding strategy to build a world-class global utility for Research and Development in this domain; GOFCoE will be seeking to quickly build on this cornerstone investor with private sector involvement from both within the UK and international markets. The initial goal is to double the funding. The long-term aim is to make GOFCoE self-sustaining as an industry utility.
As Open Finance initiatives proliferate throughout the world, FDATA has developed considerable capability and influence to shape the fundamental policy, governance and technology elements that are vital to successful delivery and for a healthy, competitive ‘Open’ market.
As PSD2 came into force in Europe in early 2018, it became apparent that there were various things which the marketplace desperately needed but for which there was no obvious focal point or leadership to make these assets available. To respond to these gaps in market fulfilment, FDATA prepared a paper and developed a strategy for solving some of these issues: GOFCoE, originally announced to the market at the FDATA Global Summit in December 2018. FDATA has developed relationships with key partners, including Fintech Scotland and the University of Edinburgh (UoE), to build out its capability. UoE as the lead partner, has resourced a small team to develop the business plan, funding requirements, governance arrangements and strategic vision to make it a reality. The team has done a tremendous job and I thank them for their great work.
The primary driver for the selection of the UoE (and surrounding academic and financial technology cluster), is its world-class strengths in supercomputing and data science. It has proved to be an outstanding partnership of the willing, fully committing to the vision of problem-solving through international collaboration and making its resources and funding available to kick-start the programme.
Regulators across the globe have also been engaged in the design and ideation of GOFCoE.
GOFCoE aims to provide leadership, coordination, research, and capability to develop the benefits of Open Finance and to help safely unlock the potential of customer data as a force to improve lives. GOFCoE is set up to be an industry, regulatory and academic collaboration, and focusing on areas of the market that can only be really solved through collaboration. Some examples include:
- A Financial Data Sandpit of pseudonymised financial data contributed from multiple market verticals to help banks, fund managers, insurers and fintechs to more rapidly develop hypothesise, prototype algorithms, test business models and work with regulatory sandboxes to develop proof points.
- A Global Economic Observatory – a longitudinal study of how humankind earns, spends and saves through the lens of both consumers and businesses. This observatory will draw a wide variety of private sector and public sector data sets to provide an unprecedented research and policy capability including looking at things like how people manage unfair credit or prepare for a long life.
- An Algorithmic Bias Test Laboratory – a new capability to assist financial services practitioners reduce discrimination, providing assurance of compliance and ethical standards in their algorithmic distribution of products and services.
- A Global Open Finance Technical Standards Working Group – creating a digital library of the output of national and international agencies developing API standards, coupled to a working group of those agencies seeking to develop harmonisation of security standards for data sharing, digital identity, conformance testing and interoperability across markets. The OpenID Foundation will be a key partner in this initiative.
- An Economic Crime Unit – providing an international collaboration environment to enable enhanced pattern recognition research and development to reduce money laundering and fraud.
- An Education and Training Programme – running courses in machine learning in financial services, data ethics and data governance.
In the coming months, GOFCoE will be spun out of FDATA and the UoE into an independent entity, while continuing to be hosted on campus at the university. The intention behind this evolution is to put it into an internationally diverse governance framework. Although it is very much intended to support firms), regulators, policy makers and academic research, it is critical to its success that it remains independent of these actors, not perceived to be controlled by one nation state, and is positioned always on the side of the end customer. To that end, trust, market neutrality and ethics have a special meaning for the GOFCoE ethos.
Since its earliest origins in 2013, FDATA has lobbied for the rights of consumers and businesses to share their financial data with regulated actors of their choosing and to represent the interests of members in the delivery of Open Finance. GOFCoE is a major new international collaboration, a research and development facility through which Open Finance objectives will be supported, with a suite of practical capabilities for companies to work with.