Please find below FDATA’s formal submission of response to the EBA’s Consultation on Revised Guidelines on Money Laundering and Terrorist Financing Risk Factors. Due to the limitations of the response form provided online and the lack of option to attach supporting evidence, we take this opportunity to send our analysis and position via email.
FDATA successful in collaborative bid for £23m GOFCoE funding
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.
About 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.
FDATA Successful in Collaborative Bid for £23m GOFCoE Funding
FDATA Successful in Collaborative Bid for £23m GOFCoE Funding
June 26, 2020, Edinburgh, Scotland: Today, FDATA Global Executive Chairman Gavin Littlejohn announced in a letter to FDATA membership the association’s success in acquiring £23m in funding for the Global Open Finance Centre of Excellence (GOFCoE) to advance Open Finance across the United Kingdom, Europe, and around the world.
Following recent notification by the UK Government, I am 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 market place 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. Since then, FDATA has developed relationships with key partners, including the University of Edinburgh (UoE), to build out its capability, resourcing a small team to develop the business plan, funding requirements, governance arrangements and strategic vision to make it a reality.
The UoE, chosen for its internationally recognised strengths in supercomputing and data science, has proven to be an outstanding partner, fully committing to the vision of problem-solving through international collaboration and, making its resources and funding available to kick-start the programme.
About 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 human kind earns, spends and saves through the lens of both consumers and businesses. This observatory will source 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 (including FDATA members), 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. I will join the initial board of directors and work with them to ensure that this market positioning goal is achieved.
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 you to work with.
Member Spotlight: Fintech Growth Syndicate
Since its founding in 2016, Canada’s Fintech Growth Syndicate (FGS) has won multiple awards and helped companies transform through corporate innovation. FGS is a trusted innovation firm for large international and Canadian corporations, visionary startups, multi-stakeholder organizations, academic institutions, and governments.
FGS’s deep fintech and financial services expertise sets it apart from other advisory firms. With a mission to revolutionize Canada’s fintech ecosystem until it becomes the best on the planet, FGS launched Maple by FGS – Canada’s most exhaustive fintech ecosystem platform.
FGS tracks and analyzes over 1,200 fintechs in Canada and uses data to help companies quickly explore customer needs and untapped business models.
FGS is actively engaged in the fintech ecosystem, staying up to date with regulatory changes, Open Banking initiatives, payment modernization updates, and more to advise and represent stakeholders’ needs in the financial industry. Along with being members of FDATA, FGS is a member of the Payments Canada Stakeholder Advisory Committee, Canadian Lenders Association (CLA), Canadian Innovation Exchange (CIX), Financial Data Exchange (FDX), and the Canadian Prepaid Providers Association (CPPO).
Innovation is at the core of what FGS does – its dynamic team of fintech experts, innovators, and designers create growth strategies for Canada’s largest companies by looking at their external and internal forces, what their customers want, to provide recommendations for products and solutions. They embrace a culture of experimentation and learning focused on minimal investments to assess, define, test, refine, and validate new products.
FGS hosts a podcast, The Disrupticons, intending to explain how various innovations—from artificial intelligence to digital banking to Open Banking—will disrupt the financial services industry for the benefit of the average citizen.
FDATA North America Statement on Mastercard Acquisition of Finicity
FDATA North America Statement on Mastercard Acquisition of Finicity
Contact: Kerrie Rushton, (202) 365-6338, [email protected]
June 23, 2020, Washington, DC: Steve Boms, executive director of the Financial Data and Technology Association (FDATA) North America released the following statement regarding Mastercard’s acquisition of Finicity:
“Mastercard’s acquisition of Finicity is the latest sign that open finance is the future of consumer and small business financial services. As we have seen in every other market that has implemented such regimes, establishing a legal right in which consumers and small businesses can access and share their financial data with trusted third parties is paramount to implementing open finance frameworks. FDATA North America continues to urge U.S. policymakers to follow suit.”
ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances. Existing FDATA North America members include: air (the Alliance for Innovative Regulation), API Metrics, Betterment, Direct ID, Envestnet Yodlee, Experian, FGS, Fiserv, Flinks, Interac, Intuit, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, TransUnion, Trustly, VoPay, Wealthica and others.
FDATA North America Outlines Competition Issues Surrounding Open Banking
FDATA North America Outlines Competition Issues Surrounding Open Banking
Contact: Kerrie Rushton, (202) 365-6338, [email protected]
June 2, 2020, Washington, DC – Today, the Financial Data and Technology Association (FDATA) of North America released a paper – “Competition Issues in Data-Driven Consumer and Small Business Financial Services” – on competition issues surrounding open finance and the financial data access competitive landscape in the United States. The paper’s release came in conjunction with a virtual presentation by FDATA North America Executive Director Steve Boms and Duane Pozza, partner at Wiley LLP. Click here to watch a replay of the webinar.
Consumers and small businesses in the United States have become increasingly reliant on financial services and products offered by financial technology (“fintech”) providers. Currently, as many as 100 million Americans utilize fintech tools to improve their financial wellbeing. Regardless of the type of product or service offered by fintech firms, all rely on the ability of the consumer or small business to grant them access to their financial data, which is typically held at a financial institution.
The paper, “Competition Issues in Data-Driven Consumer and Small Business Financial Services,” outlines how restrictions on consumer-directed access to individual financial data raise serious competition concerns in the market for data-driven financial services.
Competition Issues in Data-Driven Consumer and Small Business Financial Services
Highlights from “Competition Issues in Data-Driven Consumer and Small Business Financial Services”:
- The innovation in financial services is powered by consumers and small businesses granting permission for access and use of their data, often in conjunction with cutting edge machine learning and other data analytics technology.
- As consumers and businesses face a deteriorating economic landscape, it is critical to maintain competition in the market for these data-driven financial services.
- Competition issues cannot take a back seat as the regulatory and technological framework in data sharing continues to evolve. As open finance develops, competition laws provide a critical backstop to ensure that existing competition in the market for data-driven consumer financial services is not stifled.
ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances. Existing FDATA North America members include: air (Alliance for Innovative Regulation), API Metrics, Betterment, Direct ID, Envestnet Yodlee, Fintech Growth Syndicate, Flinks, Intuit, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, TransUnion, Trustly, VoPay, Wealthica and others
Regulatory Sandbox joins other regulatory initiatives and brings optimism to fintechs in Brazil
Despite the turbulent year, a major movement of regulatory and infrastructure updates planned for 2020 is following its course
The portuguese version of this article can be found at FEBRABAN’s Noomis platform in the link: https://bit.ly/bdnoomis6
FDATA North America Submits Comments to US CFPB on Consumer Financial Protection Law
May 27, 2020, Washington, DC – Today, FDATA North America submitted comments to the US Consumer Financial Protection Bureau’s (CFPB) Task Force on Federal Financial Law following its Request for Information on options to harmonize, modernize, and update Federal consumer financial protection laws.
FDATA North America Welcomes Four New Members
FDATA North America Welcomes Four New Members
Contact: Kerrie Rushton, (202) 365-6338, [email protected]
May 26, 2020, Washington, DC – The Financial Data and Technology Association (FDATA) of North America today announced it has added four new members, boosting the organization’s roster of member companies and organizations united behind the notion that consumers and small businesses should have full utility over their own financial data.
“The North American movement in support of open finance continues to grow,” said FDATA North America Executive Director Steve Boms. “As they shelter in place, consumers and small businesses depend more than ever on access to financial services products and services delivered to them digitally. Millions of individuals, families, and businesses are facing unprecedented financial hardship and policymakers must focus on how to build a system that makes it easier for their constituents to bank online, gain access to capital, and plan and manage their financial futures. Open finance is that solution and that’s why our coalition is growing.”
The following organizations recently joined FDATA North America:
- Experian is a global leader in consumer and business credit reporting and marketing services. The company supports clients in more than 80 countries.
- Fiserv is a global provider of financial services technology that delivers superior value through targeted innovation. It serves thousands of financial institutions and businesses of all sizes.
- Fintech Growth Syndicate is a Canadian innovation advisory firm. It tracks and analyzes data from more than 1,200 Canada-based fintechs to help companies better respond to customer needs.
- Interac Corp. is Canada’s payments and digital information exchange that operates a world-class debit payments system with secure, broad-based acceptance, reliable technical infrastructure, and a 36-year history of bringing the ecosystem together.
These firms discussed the importance of FDATA North’s mission to advance data access and open banking in North America:
- Experian: “FDATA gives Experian insight into the policy issues affecting an important and dynamic industry that is critical to helping facilitate greater access to fair and affordable credit for consumers and small businesses,” said Vice President of Governance and Strategic Initiatives. Paul Haddon “Experian Boost is a great example of how consumer-permissioned data can help consumers improve their credit score.”
- Fiserv: “As both a data aggregator and a banking platform provider, we see how our clients can empower consumers by providing access to information that enables better insight and control over their financial lives,” said Senior Vice President of Client Engagement Matt Wilcox. “Through participation in initiatives such as FDATA, Fiserv is committed to furthering secure access to data to benefit both financial institutions and consumers.”
- Fintech Growth Syndicate: “As a member of FDATA, FinTech Growth Syndicate (FGS) is excited to have the opportunity to advocate for the development and implementation of a consumer directed finance framework that is good for all market participants,” said CEO and Founder Sue Britton. “Canada has a vibrant and large FinTech ecosystem, with traditional financial institutions, new entrants and incumbent technology providers; each essential but all needing access to the market and the ability to fairly compete and serve the needs of Canadians.”
- Interac Corp: “Interac is pleased to join FDATA, an organization committed to advancing financial data and technology discussions across a range of public and private sector stakeholders,” said Vice President Of Strategy, Trends & Emerging Solutions Oscar Roque. “By contributing learnings from our 36-year history as a leader in Canadian payments, Interac looks forward to working collaboratively to bring the ecosystem together to address the needs of Canadians now and in the future.”
Existing FDATA North America members include: air (Alliance for Innovative Regulation), Betterment, Direct ID, Envestnet Yodlee, Equifax, Flinks, Intuit, Kabbage, Mogo, Morningstsar, M Science, MX, Petal, Plaid, Questrade, Quicken Loans, TransUnion, Trustly, VoPay, Wealthica and others.
ABOUT FDATA NORTH AMERICA
FDATA was heavily involved in the UK Open Banking Working Group in 2015. In 2016, the working group’s output was published by Her Majesty’s Treasury as the Open Banking Standard. FDATA North America was founded in early 2018. Its members collectively provide tens of millions of consumers in Canada, the United States and Mexico with aggregation-based tools to better manage their finances.
FDATA North America Submits Letter to House Financial Services Committee on Consumer Financial Data Privacy
May 21, 2020, Washington, DC – Today, FDATA North America submitted a letter to the U.S. House Financial Services Committee on consumer financial data privacy. In the letter, FDATA North America highlights that, as the leading trade association advocating for consumer-permissioned third-party access to financial data globally, the most effective way to ensure data privacy is to give consumers and small businesses the tools to control their financial data.
FDATA North America Letter on Consumer Financial Data Privacy