Six Reasons to Have a Fintech Strategy


fintech-7-23-19.pngFinancial technology, or fintech, is rapidly and dramatically changing the financial services landscape, forcing banks to respond.

Banks are taking different approaches to capitalize on the opportunities presented by fintech, mitigating the risks and remaining competitive. Some of these approaches include partnering with fintech companies, investing in them, investing in internal innovation and development or creating or participating in fintech incubators and labs. Some banks focus on a single strategy, while some mix and match. But many have no plan at all.

The board of directors oversees the bank’s strategic direction and provides senior management with risk parameters to exercise their business discretion. Fintech must be part of that strategic direction. A thoughtful and deliberate fintech strategy is not only a best practice, it is a necessity. Here are six reasons why.

1. Fintech is Here to Stay. Bankers who have seen many trends come and go could be forgiven for initially writing off fintech as a fad. However, fintech is wholly reshaping the financial services industry through digital transformation, big data, cybersecurity and artificial intelligence. Fintech now goes far beyond core systems, enhancing capabilities throughout the bank.

2. Customers Expect It. Demographics are changing. Customers under 40 expect their banking services to be delivered by the same channels and at the same speed as their other retail and consumer services like online shopping and ride-hailing applications. Banks that cannot meet those expectations will force their younger customers to look elsewhere.

3. Competition and Differentiation. Community banks may not be able to compete with the largest banks on their technology spend, but they should be competitive with their peers. Developing and executing a thoughtful fintech strategy will enhance a bank’s identity and give them a competitive advantage in the marketplace.

4. Core Systems Management. Banks must have a strategy for their core banking systems. Replacing a legacy system can take years and requires extensive planning. Banks must weigh the maintenance expense, security vulnerability and reduced commercial flexibility of legacy systems against the cost, potential opportunities and long-term efficiencies of the next generation platforms.

5. Fiduciary Duty Demands It. A board’s fiduciary duty includes having a fintech strategy. The board is accountable to the bank’s shareholders and must create sustainable, long-term value. Director are bound by the fiduciary duty of care to act in the best interest of the bank. Given fintech’s rapid expansion, heightened customer expectations and the need to remain competitive, it is prudent and in the long-term best interest of the bank to have a fintech strategy.

6. Regulatory expectations. Boards are also accountable to bank regulators. The Office of the Comptroller of the Currency issued a bulletin in 2017 to address the need for directors to understand the impact of new fintech activities because of the rapid pace of development. The OCC is not the only regulator emphasizing that insufficient strategic planning in product and service innovation can lead to inadequate board oversight and control. A deliberate fintech strategy from the board can direct a bank’s fintech activities and develop a risk management process that meets regulatory expectations.

The best fintech strategy for a bank is one that considers an institution’s assets, capabilities, and overall business strategy and allows it to stay competitive and relevant. Not having a fintech strategy is not an option.

“The Best Strategic Thinker in Financial Services”


strategy-7-19-19.pngThe country’s most advanced bank is run by the industry’s smartest CEO.

Co-founder Richard Fairbank is a relentless strategist who has guided Capital One Financial Corp. on an amazing, 25-year journey that began as a novel approach to designing and marketing credit cards.

Today, Capital One—the 8th largest U.S. commercial bank with $373.2 billion in assets—has transformed itself into a highly advanced fintech company with national aspirations.

The driving force behind this protean evolution has been the 68-year-old Fairbank, an intensely private man who rarely gives interviews to the press. One investor who has known him for years—Tom Brown, CEO of the hedge fund Second Curve Capital—says that Fairbank “has become reclusive, even with me.”

Brown has invested in Capital One on and off over the years, including now. He has tremendous respect for Fairbank’s acumen and considers him to be “by far, the best strategic thinker in financial services.”

I interviewed Fairbank once, in 2006, for Bank Director magazine. It was clear even then that he approaches strategy like Sun Tzu approaches war. “A strategy must begin by identifying where the market is going,” Fairbank said. “What’s the endgame and how is the company going to win?”

Fairbank said most companies are too timid in their strategic planning, and think that “it’s a bold move to change 10 percent from where they are.” Instead, he said companies should focus on how their markets are changing, how fast they’re changing, and when that transformation will be complete.

The goal is to anticipate disruptive change, rather than chase it.

“It creates a much greater sense of urgency and allows the company to make bold moves from a position of strength,” he said.

This aggressive approach to strategy can be seen throughout the company’s history, beginning in 1988 when Fairbank and a former colleague, Nigel Morris, convinced Richmond, Virginia-based Signet Financial Corp. to start a credit card division using a new, data-driven methodology. The unit grew so big so fast that it dwarfed Signet itself and was spun off in 1994 as Capital One.

The company’s evolution since then has been driven by a series of strategic acquisitions, beginning in 2005 when it bought Hibernia Corp., a regional bank headquartered in New Orleans. Back then, Capital One relied on Wall Street for its funding, and Fairbank worried that a major economic event could abruptly turn off the spigot. He sought the safety of insured deposits, which led not only to the Hibernia deal but additional regional bank acquisitions in 2006 and 2008.

Brown says those strategic moves probably insured the company’s survival when the capital markets froze up during the financial crisis. “If they hadn’t bought those banks, there are some people like myself who don’t think Capital One would be around today,” he says.

As Capital One’s credit card business continued to grow, Fairbank wanted to apply its successful data-driven strategy to other consumer loan products that were beginning to consolidate nationally. Over the last 20 years, it has become one of the largest auto lenders in the country. It has also developed a significant commercial lending business with specialties like multifamily real estate and health care.

Capital One is in the midst of another transformation, to a national digital consumer bank. The company acquired the digital banking platform ING Direct in 2011 for $9 billion and rebranded it Capital One 360. Office locations have fallen from 1,000 in 2010 to around 500, according to Sandler O’Neill, as the company refocuses its consumer banking strategy on digital.

When Fairbank assembled his regional banking franchise in the early 2000s, the U.S. deposit market was highly fragmented. In recent years, the deposit market has begun to consolidate and Capital One is well positioned to take advantage of that with its digital platform.

Today, technology is the big driver behind Capital One’s transformation. The company has moved much of its data and software development to the cloud and rebuilt its core technology platform. Indeed, it could be described as a technology company that offers financial services, including insured deposit products.

“We’ve seen enormous change in our culture and our society, but the change that took place at Capital One’s first 25 years will pale in comparison to the quarter-century that’s about to unfold,” Fairbank wrote in his 2018 shareholders letter. “And we are well positioned to thrive as technology changes everything.”

At Capital One, driving change is Fairbank’s primary job.

A Former Regulator Shares His Advice for Boards


regulator-6-13-19.pngDeveloping a positive relationship with regulators is important for any bank. How can banks foster this?

There’s no one better to answer this question than a former regulator.

Charles Yi served as general counsel of the Federal Deposit Insurance Corp. from 2015 to 2019, where he focused on policy initiatives and legislation, as well as the implementation of related rulemaking. He also served on the FDIC’s fintech steering committee.

In this interview, Yi talks about today’s deregulatory environment and shares his advice for banks looking to improve this critical relationship. He also explains the importance of a strong compliance culture and what boards should know about key technology-related risks.

Yi, now a partner at the law firm Arnold & Porter, in Washington, D.C., spoke to these issues at Bank Director’s Bank Audit & Risk Committees Conference. You can access event materials here.

BD: You worked at the FDIC during a time of significant change, given a new administration and the passage of regulatory relief for the industry. In your view, what do bank boards need to know about the changes underway in today’s regulatory environment?
CY: While it is true that we are in a deregulatory environment in the short term, bank boards should focus on prudent risk management, and safe and sound banking practices for the long term. Good fundamentals are good fundamentals, whether the environment is deregulatory or otherwise.

BD: What hasn’t changed?
CY: What has not changed is the cyclical nature of both the economy and the regulatory environment. Just as housing prices will not always go up, [a] deregulatory environment will not last forever.

BD: From your perspective, what issues are top of mind for bank examiners today?
CY: It seems likely that we are at, or near, the peak of the current economic cycle. The banking industry as a whole has been setting new records recently in terms of profitability, as reported by the FDIC in its quarterly banking profiles. If I [were] a bank examiner, I would be thinking through and examining for how the next phase of the economic cycle would impact a bank’s operations going forward.

BD: Do you have any advice for boards that seek to improve their bank’s relationship with their examiners?
CY: [The] same thing I would say to an examiner, which is to put yourself in the shoes of the other person. Try to understand that person’s incentives, pressures—both internal and external—and objectives. Always be cordial, and keep discussions civil, even if there is disagreement.

BD: What are some of the biggest mistakes you see banks make when it comes to their relationship with their examiner?
CY: Even if there is disagreement with an examiner, it should never become personal. The examiner is simply there to do a job, which is to review a bank’s policies and practices with the goal of promoting safety and soundness as well as consumer protection. If you disagree with an examiner, simply make your case in a cordial manner, and document the disagreement if it cannot be resolved.

BD: In your presentation at the Bank Audit & Risk Committees Conference, you talked about the importance of projecting a culture of compliance. How should boards ensure their bank is building this type of culture?
CY: Culture of compliance must be a focus of the board and the management, and that focus has to be communicated to the employees throughout the organization. The incentive structure also has to be aligned with this type of culture.

Strong compliance culture starts at the top. The board has to set the tone for the management, and the management has to be the example for all employees to follow. Everyone in the organization has to understand and buy into the principle that we do not sacrifice long-term fundamentals for short-term gain—which in some cases could end up being [a] long-term loss.

(Editor’s note: You can learn more about building a strong culture through Bank Director’s Online Training Series, Unit 16: Building a Strong Compliance Culture.)

BD: You served on the FDIC’s fintech steering committee, which—in a broad sense—examined technology trends and risks, and evaluated the potential impact to the banking system. Banks are working more frequently with technology partners to enhance their products, services and capabilities. What’s important for boards to know about the opportunities and risks here?
CY: Fintech is the next frontier for banking, and banks are rightly focused on incorporating technology into their mix of products and services. One thing to keep in mind as banks increasingly partner with technology service providers is that the regulators will hold the bank responsible for what the technology service provider does or fails to do with regard to banking functions that have been outsourced.

BD: On a final note: In your view, what are the top risks facing the industry today?
CY: I mentioned already the risks facing the industry as we contemplate the downhill side of the current economic cycle. One other issue that I know the regulators are and have been spending quite a lot of time thinking about is cybersecurity. What is often said is that a cyber event is not a question of if, but when. We can devote volumes of literature [to] talking about this issue, but suffice for now to say that it is and will continue to be a focus of the regulators.

Arnold & Porter was a sponsor of Bank Director’s Bank Audit & Risk Committees Conference.

What Does Digital Transformation Mean Today?


transformation-4-17-19.pngFaced with macro-economic pressures, technology adoption decisions and quickly shifting customer expectations, banks are challenged in how to respond. Or if a response is even necessary.

But why?

For hundreds of years banks have existed to facilitate commerce, serving as a gateway to exchange and store value. Customers historically have chosen their bank for a combination of two factors: trust and convenience.

Financial institutions thrived by putting themselves at the heart of communities and centers of commerce. Branch networks expanded to be close to their customers, serving communities with products tailored to their customer footprint.

Then came the internet in the 1990s, and banks began launching online banking. By 2006, 80 percent of banks offered internet banking. Many banks believed they could begin to close bank branches, transitioning from fixed-cost distribution centers to low-cost digital channels.

But when it came to financial advice and large transactions, consumers still prefer branch locations. Instead of replacing costly branches with low-cost digital channels, banks are now faced with the upkeep of ever-changing customer expectations across multiple channels.

Pressure From Fintechs
The problem right now is traditional revenue from interest rate spreads are being strained by specialist digital providers. Instead of offering a breadth of services to customers, fintechs develop one product and continuously refine the single product to the user’s needs.

But how can a bank compete and offer the services customers want with the specialization fintechs can deliver across multiple channels?

The answer is open banking—a collaborative model in which banking data is shared with third-party services across an ecosystem of trusted providers.

As commentator and consultant Chris Skinner states in his book, “Digital Human,” “A bank that is truly into their digital journey would never build anything, but would curate everything.”

A digital transformation begins with extending bank capabilities through APIs (application programming interfaces), which open up an opportunity for banks and their customers to partner with fintechs.

But customers don’t want to vet hundreds of fintech startups. Instead, they’re looking for trust and convenience in their bank, which is the bank’s biggest advantage. While not immediately visible to customers, an important aspect of trust is the bank’s continuing role in ensuring third-party solutions handle their data securely and are in compliance with regulations.

Financial data is the currency of the next generation of banks, and the value of that currency is unlocked when segments are broken down and replaced with a platform. Only at a platform level can you extract the intelligence to deliver actionable, contextualized experiences for your customer.

In many ways, banks are already platforms, with multiple product lines around deposits, lending and insurance. APIs allow these platforms to interconnect, combining data to provide a complete financial picture of their customer. Even with the rise of technology, consumer surveys have shown they trust their banks more than Google and Amazon combined.

Customers want their bank to be at the center of their financial decisions.

The late Walter Wriston, former chairman and CEO of Citicorp said in the 1970s, “Information about money is as valuable as the money itself.”

Measuring Long-Term Success
Long-term success will be measured by the ability to refocus away from transactions in favor of becoming a trusted advisor. Banks that invest in gaining a deeper understanding of their customers’ financial lifestyle through rich data analytics can begin providing personalized, contextual advice to their customers—a valuable service customers will pay for.

Banks don’t have to embark on this journey alone. Institutions should look to technology partners equipped to allow them to think bigger by offering a customizable solution.

The bank of the future looks very similar to the bank of today—focused on core values of trust and convenience.

The Future of Banking: Crypto, Blockchain and Fintech


banking-4-17-19.pngInscribed in the first block of the first blockchain ever created are the words: “The Times 03/Jan/2009 Chancellor on brink of second bailout for banks,” referring to the London newspaper’s lead story of the day.

This edition of the newspaper is now one of the most valuable crypto collectibles to date. It’s hard to deny the symbolism in the covert message encoded into the genesis block of the bitcoin blockchain.

That message signals problems in our modern fiat financial system while introducing a novel system that replaces centralized institutional trust with a system relying on decentralized cryptographic trust.

Today, bitcoin has celebrated its 10th birthday, despite critics predicting its doom since its inception. With bitcoin came another suite of technologies collectively known as blockchain.

Despite the actual word “blockchain” not appearing in the original white paper published under the pseudonym Satoshi Nakamoto in October 2008, it has undoubtedly become one of the most talked about buzzwords in technology and banking, as well as the larger world of finance.

Blockchain is generally considered to be a subcategory of distributed ledger technology (DLT), referring to its distributed architecture in which there is no central point of attack, making it less vulnerable to hacks, fraud and manipulation.

A quick online search of the word “blockchain” will yield a wide array of differing definitions, because there is currently no universally recognized definition—something the International Standards Association is working toward. One way to define blockchain is as a shared ledger designed to produce immutable records through cryptographic techniques that facilitate the processing of transactions and tracking of assets.

Part of what makes blockchain so attractive is that it’s considered a general purpose technology, according to the Massachusetts Institute of Technology, with many potential applications across industry verticals.

The primary application for the technology thus far has been within financial services—specifically, payments.

Banking on Blockchain
A study performed by Accenture found nine out of 10 banking executives saying their bank is exploring the use of blockchain in payments, the most prevalent use being cross-border transfers.

But reaping the promised benefits of blockchain will require “fostering an uncommon coordination among banks,” according to Accenture’s study. The value is in the network—in collaboration. Examples of these interoperable networks between banks and corporations globally are using private enterprise blockchains, or DLT, like R3’s Corda platform and Hyperledger fabric.

Major benefits from blockchain include lower administrative costs and shorter settlement times. One bank that has sought to offer these benefits to its clients by leveraging blockchain technology is Signature Bank. The New York-based commercial bank launched its own blockchain-based platform for real-time, 24/7 payments on Jan. 1, 2019.

Signature’s platform is interesting, considering some alternatives can take several days to clear and can be unavailable on weekends, for instance.

While many of the largest banks in the U.S. may be exploring blockchain and distributed ledger technologies, and filing a litany of patents, cryptocurrency is listed as both a risk and competitive threat in some of their annual reports. Meanwhile, forward-looking community banks have embraced cryptocurrencies and seen their balance sheets improve with it, such as San Diego, California-based Silvergate Bank.

“The Times They Are A-Changin”
Cryptocurrency is only one of many risks cited in the annual reports of major banks.
The rise in the number and nature of fintech firms has brought an explosion of innovation and competition.

Since the financial crisis, younger generations are growing up without the same relationship with banks that their parents and grandparents had, which has helped propel the growth of fintech companies focused on convenience and customized digital experiences.

This has paved the way for many fintech startups to excel in the financial services market. These companies are disrupting the status quo by providing a user experience that quickly adapts to the needs and desires of their customers.

With the genesis of bitcoin and blockchain, and the explosion in fintech, one thing is certain. In the words of Bob Dylan, the times they are a-changin’. And they’re changing in financial services on an unprecedented scale.

Bridging The Gap Between Retail & Business Banking



Speed, ease of use and convenience define the customer experience today for both retail and commercial clients. In this video, First Data’s Christian Ofner and Eric Smith explain what retail and commercial customers expect from banks today—and you might be surprised to find they have similar needs. They also share how banks should enhance the experience.

  • Strengthening the Retail Experience
  • Enhancing Commercial Clients’ Experience
  • Technologies Banks Should Consider
  • Evaluating Your Bank’s Digital Strategy

Strengthening Customer Engagement



Fintech companies are laser-focused on improving consumer engagement—but there is room for traditional banks to gain ground, according to Craig McLaughlin, president and CEO of Extractable. In this video, he shares three ways banks can strategically approach improving the customer experience at their own institutions.

  • The One Trait That Sets Fintechs Apart
  • Improving the Customer Experience
  • Understanding Digital Strategy

The Next Things To Know About Data


data-3-5-19.pngThere’s one thing in today’s banking industry that is critical to remaining competitive, being innovative, and maintaining compliance and risk levels: data.

This is no longer a surprise for most banks. It’s an issue that comes up often among bank boards and management, but there are still a number of challenges that banks must overcome to be successful in all of those areas.

It has a connection to many of the major decisions boards make, from what third-party partners to join forces with to how it integrates the next landmark technology.


	strategy-3-5-19-tb.pngFive Steps to a Data-Driven Competitive Strategy
Maintaining a competitive advantage for banks today lies in one of its most precious assets: data. Banks have the gold standard of consumer data, and leveraging that information can be the trump card in achieving growth goals.

Getting there, though, requires good governance of data and technology, and then using those elements to craft strategic objectives.

compliance-3-5-19-tb.pngFintechs Can Fend Off Compliance Issues With Data
Fintechs are known to be nimbler than banks for a few reasons, including a limited regulatory framework compared to their bank partners and a smaller set of products or services. But with that relative freedom comes added risk if they don’t comply with broader regulatory requirements. One compliance problem can put a fintech out of business.

But those companies can use data to reduce compliance risk. Here’s how.

risk-3-5-19-tb.pngRisk Management at the Forefront in Fintech Partnerships
Bank regulators have generally kept their distance from interfering in bank-fintech partnerships. Agencies have deferred to the bank’s third-party risk management process, but some regulators have indicated the intent to keep a closer eye on third-party fintech firms.

Here is an overview of what banks should keep in mind when considering and managing the risk associated with these third-party partnerships.

innovation-3-5-19-tb.pngFour Ways To Innovate And Manage Risk, Compliance
There is a careful balance that banks must strike in today’s industry. To remain competitive, they have to innovate, but they also have to remain compliant with regulations, many of which have stood for years, and manage risks that can ebb and flow with economic and technological pressure.

Finding a similar balance between thinking strategically for the future while also remembering what has worked and not worked can also be challenging for financial institutions. Building a checklist around these four ideas can help achieve that balance.

partner-3-5-19-tb.pngHow to Pick The Right Data Partner
Banks are grappling with trying to gain the greatest efficiency through a variety of innovative and technological tools, but often are hampered by the quality of the data they maintain. To make correct and sound decisions, accurate and reliable data is essential.

Partnering with third-party data service providers can help with that effort, but even that requires due diligence. To help with that due diligence, banks should have a checklist of capabilities for those partners.

What Are The Real Risks Of Blockchain?


blockchain-2-25-19.pngIn the landscape of innovative disruption, the public’s attention is often focused on bitcoin’s impact on financing and investment options. However, it is important to understand that blockchain, the underlying technology often conflated with bitcoin, carries an even greater potential to disrupt many industries worldwide.

The attraction of blockchain technology is its promise to provide an immutable digital ledger of transactions. As such, it is this underlying technology—an open, distributed ledger—that makes monetary and other transactions work.

These transactions can include bitcoin, but they may also include records of ownership, marriage certificates and other instances where the order and permanence of the transaction is important. A blockchain is a secure, permanent record of each transaction that cannot be reversed.

But with all the positive hype about its potential implications, what are the risks to banks?

The Risk With Fintech
One of the most disruptive effects of blockchain will be in financial services. Between building cryptocurrency exchanges and writing digital assets to a blockchain, the innovation that is occurring today will have a lasting effect on the industry.

One of the principles of blockchain technology is the removal of intermediaries. In fintech, the primary intermediary is a bank or other financially regulated entity. If blockchain becomes used widely, that could pose a risk for banks because the regulatory body that works to protect the consumer with regulatory requirements is taken out of the equation.

This disintermediation has a dramatic effect on how fintech companies build their products, and ultimately requires them to take on a greater regulatory burden.

The Risk With Compliance
The first regulatory burden to consider concerns an often-forgotten practice that banks perform on a daily basis known as KYC, or Know Your Customer. Every bank must follow anti-money laundering (AML) laws and regulations to help limit the risk of being conduits to launder money or fund terrorism.

Remove the bank intermediary, however, and this important process now must occur before allowing customers to use the platform.

While some banks may choose to outsource this to a third party, it is critical to remember that while a third party can perform the process, the institution still owns the risk.

There are a myriad of regulations that should be considered as the technology is designed. The General Data Protection Regulation (GDPR), the European Union’s online privacy law, is a good example of how regulations apply differently on a blockchain.

One of the GDPR rules is the so-called right to be forgotten. Since transactions are immutable and cannot be erased or edited, companies need to ensure that data they write to a blockchain doesn’t violate these regulatory frameworks.

Finally, while blockchains are sometimes considered “self-auditing,” that does not mean the role of an auditor disappears.

For example, revenue recorded on a blockchain can support a financial statement or balance sheet audit. While there is assurance that the number recorded has not been modified, auditors still need to understand and validate how revenue is recognized.

What’s Ahead
The use of blockchain technology has the potential to generate great disruption in the marketplace. Successful implementation will come to those who consider the risks up front while embracing the existing regulatory framework.

There has already been massive innovation, and this is only the beginning of a massive journey of change.

Enhancing Shareholder Value



Bank stocks have taken a dive in late 2018, and bank boards play a key role in the strategic decisions driving shareholder value. Scott Sommer and Steve Williams of Cornerstone Advisors explain the issues impacting shareholder value in 2019, including technology.

  • Bank stock trends
  • Focus on fintech
  • Board decisions