Regulators Should Force Fintechs to Protect Consumers


fintech-3-16-16.pngWhen looking at the new competition arising from fintech companies, many bankers understandably feel that they are at an unfair disadvantage. Banks must deal with a constricting regulatory environment, but regulators don’t always apply the same standards to fintech companies. So bankers have lobbied regulators to take a more aggressive stance towards their new competitors.  [Editor’s note: The Consumer Financial Protection Bureau recently fined payment startup Dwolla $100,000 for “deceiving” customers about its security practices.]

Bankers are right to push regulators on this issue. Regulators must take a closer look at the growing fintech sector, create new standards and coordinate their efforts across multiple enforcement agencies.

The purpose of these oversight efforts should not be leveling the playing field between banks and new entrants. Instead, the purpose should be protecting customer data and keeping customers informed about how their information is used. Regulation that properly incentivizes innovation and benefits consumers needs to focus on security, privacy and transparency.

The Clearing House, which processes payments for banks, correctly pointed this out last year in a white paper that detailed some of the security lapses by alternative payments providers. For example, reports surfaced last spring that Venmo allows changes to important account information without notifying the user. This is a basic security blunder, and banks can be left on the hook for fraudulent transactions when new providers make such mistakes.

Setting Standards Based on Size, Access to Customer Information
To help fix this situation, regulators need to implement security standards for fintech companies based on their size and the type of customer information they touch. That means some fintech companies should be held to the same standards as banks—particularly those that offer account products—but others should not, depending on the sensitivity of the customer data they handle.

It also means that early stage startups shouldn’t be held to the same standards as larger, more mature fintech companies. An early stage startup with a minimum staff is not likely to have a security professional or the funds to hire one. So holding small startups to the same security standards as a large mobile wallet provider that processes billions of transactions per year will only strangle innovation.

Banks can play a key part in helping these early stage startups while also improving their own offerings. Many of these startups hope to partner with or be acquired by banks. As millennials grow up, those banks will increasingly compete with their peers based on their digital offerings. The ability to effectively partner with small, agile startups while ensuring security and compliance will be a competitive advantage for these institutions.

A bank that wants to partner with a promising startup can share some of its knowledge, staff and resources in security and compliance with the startup. Banks are usually cautious in launching new products in conjunction with startups anyway, typically starting with a small trial with a limited number of users before a full launch. That approach helps banks ensure security and compliance with the product and partner before a full launch with customers.

Effective Security Standards
While giving early-stage startups leeway on security makes sense, fintech companies with a threshold of customers using their products should face appropriate scrutiny and regular security audits because of their increased value and attack surface for hackers.

That means regulators will need to be more specific about their security guidance than they’ve been in the past. Regulators often shy away from mandating specific security measures, instead favoring general guidelines and benchmarking against industry peers. As the cyber threat grows bigger, regulators will need to require measures like tokenization and encryption for fintech companies handling sensitive customer information. Those fintech companies that offer account products or a direct connection to users’ existing bank accounts should be required to monitor and analyze user activity to prevent unauthorized logins and transactions.

These measures are likely to become industry standards in time anyway, but regulators shouldn’t hesitate to take a hand in speeding up that process. Regulators might prefer to wait and let the fintech market determine industry standards. Security is already a competitive advantage for fintech companies. Apple set the bar when it introduced Apple Pay and emphasized the security built into it. The fintech companies that don’t meet industry expectations for security won’t succeed in the long run. But regulators shouldn’t wait for fintech winners and losers to shake out to take action that could help protect customers’ information now.

Three Questions to Ask About Your Bank’s DNA


Today, numerous financial technology (fintech) companies are developing new strategies, practices and products that will dramatically influence the future of banking. Within this period of transformation, where considerable market share is up for grabs, ambitious banks can leapfrog both traditional and new rivals. Personally, I find the narrative that relates to banks and fintech companies has changed from the confrontational talk that existed just a year or two ago. As we found at this year’s FinTech Day in New York City on Tuesday, far more fintech players are expressing their enthusiasm to partner and collaborate with banking institutions who count their strengths and advantages as strong adherence to regulations, brand visibility, size, scale, trust and security.

With more than 125 attendees at Nasdaq’s MarketSite on Times Square, we explored the fundamental role financial technology firms will play in changing the dynamics of banking. While we heard about interesting upstarts, here are three questions that underpinned the event that I feel a bank’s CEO needs to sit down with his/her team and discuss right now:

1. Are We Exceeding Our Customer’s Digital Experience Expectations?
Chances are, you’re not. But you can re-set the bar to make clear to your team that while customer expectations have shifted in pronounced ways, this is an area that a bank of any size can compete, especially with the help and support of a fintech company. If you are looking for inspiration, take a look at these examples of successful partnerships that we highlighted at FinTech Day:

  • City National Bank in Los Angeles and MineralTree in Cambridge, Massachusetts, developed an online business-to-business, invoice-to-pay solution that enabled the bank to differentiate itself from its competitors and attract new corporate customers. (In June 2015, City National was acquired by Royal Bank of Canada.)
  • USAA in San Antonio, Texas, and Daon in Reston, Virginia, collaborated to roll out a facial, voice and fingerprint recognition platform for mobile biometric authentication that enhances security while enhancing customer satisfaction.
  • Metro Bank teamed up with Zopa, both in the United Kingdom, on a deal which allows Metro Bank to lend money through the peer-to-peer platform the fintech company developed.

Any good experience starts with great data. Many presenters remarked that fintech companies’ appetite to leverage analytics (which in turn, allows a business to tailor its customer experience) will continue to expand. However, humans, not machines, still play critical roles in relationship management. Having someone on your team that is well versed in using data analytics to uncover what consumer needs are will become a prized part of any team.

2. How Do We Know If We’re Staying Relevant?
How can new players show us whether the end is near? That is, what part of our business could be considered a profit center today but is seriously threatened in the future? As you contemplate where growth isn’t, here are three companies that came up in discussions at FinTech Day that could potentially help grow one’s business:

  • Nymbus, a Miami, Florida-based company which provides a cloud-based core processing system, web site design, marketing and other services to help community banks compete with bigger players.
  • Ripple, a venture-backed startup, whose distributed financial technology allows for banks around the world to directly transact with each other without the need for a central counterparty or correspondent.
  • nCino, based in Wilmington, North Carolina, which developed a cloud-based, end-to-end small business loan origination system that enables banks to compete with alternative lenders with quick processing and approval of loans.

3. Do We Have a “Department of No” Mindset?
Kudos to Michael Tang, a partner at Deloitte Consulting LLP, for surfacing this idea. As he shared at FinTech Day, banks need structure, and when one introduces change or innovation, it creates departments of “no.”

For instance, what would have happened if Amazon’s print book business was able to jettison the idea of selling electronic books? If you refuse to change with your customers, they will find someone else who does. Operationally, banks struggle to make change, but several speakers opined that forward-thinking banks need to hire to a new level to think differently and change.

Throughout FinTech Day, it struck me as important to distinguish between improvements to the status quo and where financial institutions actually try to reimagine their core business. Starting at the customer layer, there appears massive opportunities for collaboration and partnerships between established and emerging companies. The banks that joined us are investing more heavily in innovation; meanwhile, fintechs need to navigate complex regulations, which isn’t easy for anyone. The end result is an equation for fruitful conversations and mutually beneficial relationships.

Innovation Takes Center Stage


Technology has always been integral to banking, bringing both speed and efficiency to a transaction-intensive business. But in recent years, technology has stepped onto center stage as a prime component in every bank’s growth and distribution strategy. Technology has, in effect, gone from being a way to save money (a crucial function that it still fulfills) to a way to make money. Much of this activity is being driven by the continued growth of mobile and online banking.

In an effort to highlight the importance of technology and the evolving partnership between banks and their financial technology providers, Bank Director held its second annual FinTech Day today at the Nasdaq MarketSite in New York. The event brought together senior executives from banks, technology companies and investment firms to create a dialogue between these important groups, encourage cross-fertilization and build a foundation for collaboration.

This year’s event also featured Bank Director’s inaugural Best of FinXTech Awards, which recognizes examples of innovation and collaboration between banks and their financial technology providers. The awards have been given to five banks and their technology partners, chosen by Bank Director from among 10 finalists.

The five winners are:

  • Univest Bank and Trust Co. in Souderton, Pennsylvania, and nCino in Wilmington, North Carolina. The project: Developed a cloud-based, end-to-end small business loan origination system that enabled Univest to meet the challenge of aggressive alternative lenders that are pushing into that important lending market.
  • CNLBank in Orlando, Florida, and CheckAlt in Los Angeles, California. The project: Jointly developed a new solution for remittance processing that greatly reduced the volume of payment exceptions, resulting in reduced costs and improved commercial client retention. In December 2015, CNLBank was acquired by Wayne, New Jersey-based Valley National Bancorp.
  • Somerset Trust Co. in Somerset, Pennsylvania, and Malauzai Software, Inc. in Austin, Texas. The project: Developed a mobile banking solution that allows Somerset retail banking customers to securely check balances, use picture bill pay and remotely deposit checks from any location of device.
  • Metro Bank in Harrisburg, Pennsylvania, and BizEquity in Wayne, Pennsylvania. The project: Developed a private label version of BizEquity’s online business valuation service, available through Metro’s website, that is used as a tool to bring prospective business customers into the bank’s branches. In August 2015, Metro was acquired by Pittsburgh-based F.N.B. Corp.
  • City National Bank in Los Angeles, California, and MineralTree in Cambridge, Massachusetts. The project: Developed an online business-to-business, invoice-to-pay solution that enabled the bank to differentiate itself from its competitors and attract new corporate customers. In June 2015, City National was acquired by Royal Bank of Canada.

The five winners were honored today at FinTech Day in New York. The other five finalists were USAA and Daon Inc., Seattle Metropolitan Credit Union and D+H, First Financial Bank and StrategyCorps, Central Bancompany and Ignite Sales, and Metro Bank and Zopa, both located in the United Kingdom.

The Seven Facets of a Digital Bank


If one were to start a new digital bank today, what would the defining characteristics be? Although there are some similarities to traditional bank counterparts, digital-only banks are in many respects very different. Here are the seven facets of a digital bank that will help drive its success.

Adjacent to each facet are organizations, including digital-only and traditional banks, as well financial technology companies, that Bank Director believes embody each characteristic.

Innovation Takes Center Stage


fintech-day-closing-bell.png

Technology has always been integral to banking, bringing both speed and efficiency to a transaction-intensive business. But in recent years, technology has stepped onto center stage as a prime component in every bank’s growth and distribution strategy. Technology has, in effect, gone from being a way to save money (a crucial function that it still fulfills) to a way to make money. Much of this activity is being driven by the continued growth of mobile and online banking.

In an effort to highlight the importance of technology and the evolving partnership between banks and their financial technology providers, Bank Director held its second annual FinTech Day today at the Nasdaq MarketSite in New York. The event brought together senior executives from banks, technology companies and investment firms to create a dialogue between these important groups, encourage cross-fertilization and build a foundation for collaboration.

This year’s event also featured Bank Director’s inaugural Best of FinXTech Awards, which recognizes examples of innovation and collaboration between banks and their financial technology providers. The awards have been given to five banks and their technology partners, chosen by Bank Director from among 10 finalists.

The five winners are:

  • Univest Bank and Trust Co. in Souderton, Pennsylvania, and nCino in Wilmington, North Carolina. The project: Developed a cloud-based, end-to-end small business loan origination system that enabled Univest to meet the challenge of aggressive alternative lenders that are pushing into that important lending market.
  • CNLBank in Orlando, Florida, and CheckAlt in Los Angeles, California. The project: Jointly developed a new solution for remittance processing that greatly reduced the volume of payment exceptions, resulting in reduced costs and improved commercial client retention. In December 2015, CNLBank was acquired by Wayne, New Jersey-based Valley National Bancorp.
  • Somerset Trust Co. in Somerset, Pennsylvania, and Malauzai Software, Inc. in Austin, Texas. The project: Developed a mobile banking solution that allows Somerset retail banking customers to securely check balances, use picture bill pay and remotely deposit checks from any location of device.
  • Metro Bank in Harrisburg, Pennsylvania, and BizEquity in Wayne, Pennsylvania. The project: Developed a private label version of BizEquity’s online business valuation service, available through Metro’s website, that is used as a tool to bring prospective business customers into the bank’s branches. In August 2015, Metro was acquired by Pittsburgh-based F.N.B. Corp.
  • City National Bank in Los Angeles, California, and MineralTree in Cambridge, Massachusetts. The project: Developed an online business-to-business, invoice-to-pay solution that enabled the bank to differentiate itself from its competitors and attract new corporate customers. In June 2015, City National was acquired by Royal Bank of Canada.

The five winners were honored today at FinTech Day in New York. The other five finalists were USAA and Daon Inc., Seattle Metropolitan Credit Union and D+H, First Financial Bank and StrategyCorps, Central Bancompany and Ignite Sales, and Metro Bank and Zopa, both located in the United Kingdom.

Should Banks Use Facebook to Offer Credit?


data-source-2-26-16.pngIs it time for banks to start using Facebook profiles to offer a loan? Or a person’s Gmail account to verify an identity? A growing number of fintech start-up companies say so.

Banks have traditionally relied on credit bureaus to supply information not only about a person’s FICO score, but also to verify identity with data such as addresses. But sometimes, these data sources come up short. Tommy Nicholas, one of the founders of New York-based startup Alloy, says he has a few banks trying out his company’s platform, which basically allows a la carte access to a variety of traditional and nontraditional data sources to verify a customer’s identity, including credit bureaus as well as services that scan social media profiles or email accounts.

The idea is to make it easier for a bank to verify someone’s identity when traditional sources fall short, for instance, the person moved recently and the new address isn’t showing up on the credit report. “You end up asking half your customers to go find a phone bill and send it to you, not to mention you have all this manual work to do,’’ Nicholas says. “It adds a lot of friction.”

Alloy is trying to get traditional commercial banks interested in the technology for verification purposes, although its use to approve loans may be a ways off. Nonbank lenders already are using a host of online and offline data to make credit decisions, especially micro-finance lenders in developing countries that lack functioning credit bureaus. Some lenders are going so far as to analyze behavioral data to make credit decisions. Smartphone data, for example, can tell a lender that you regularly use a gambling app, which could be a black mark on your alternative credit score. Customers have to agree to provide lenders with the smartphone and social media data before they can be approved for credit. Facebook recently applied for a patent to use data on its users for loan underwriting—if your friends’ average credit score met a minimum, that could be a sign that you were a good credit as well, because you associate with people who have good credit.

Lenddo, which typically works with banks in emerging markets but recently began offering its service to U.S. financial institutions, has an algorithm that assigns a non-traditional credit score based on a variety of data to predict your willingness to pay back your loan. It also verifies identity using non-traditional data, such as Facebook profiles and email accounts. Socure uses what it calls social biometrics, where it pulls data from sources such as email, phone and social media accounts to create a risk score for fraud detection. Customers have to opt in to share their data. Other companies, such as Puddle, allow people to build a trust network online to give small dollar loans to each other. Everyone contributes something to the pool, and the more people you add to your trust network, the more you are able to borrow. Paying back your loan on time increases your trustworthiness.

Advocates of the use of alternative data, like Daniel Castro, the director of the Center for Data Innovation in Washington, D.C., say the plethora of online and offline data on each person is actually making it easier to detect fraud because it’s very difficult to sustain a fake identity online that will pass scrutiny. For example, if you worked somewhere for years, you probably have LinkedIn contacts who worked at that same employer. According to Castro, it’s extremely hard to fake your connections to multiple legitimate people. “More data can be useful,’’ he says. “Long term, every bank will be integrating more data sources. It will just be malpractice on their part not to, because it will reduce risk. It will just take awhile before they figure out the best way to do that.”

John ReVeal, an attorney at Bryan Cave, says the new technologies raise questions about complying with existing banking laws. For example, the Fair Credit Reporting Act applies both to credit and deposit accounts, and consumers have a right to know why they were rejected for either type of account. That could turn some of the new data providers into de-facto credit reporting agencies, he says. Additionally, banks may have to answer questions from their regulators about how they use alternative data to make credit decisions, and ensure such decision-making doesn’t violate anti-discrimination laws.

Will the new technologies provide a better way to analyze credit and approve accounts? That remains to be seen. For now, banks and alternative providers are experimenting with the possibility of augmenting traditional sources, rather than replacing them.

Key Trends & Topics in 2016


Small and midsized banks should continue to outperform the market, but “challenger banks” are positioned to take on even more market share. Tom Michaud, president and CEO of Keefe, Bruyette & Woods, identifies these “challenger banks,” which include innovators such as Silicon Valley Bank and Opus Bank, growing due to a focus on technology and niche expertise, and strong performers such as Bank of the Ozarks and Pinnacle Financial Partners, more traditional models with strong cultures that attract talent. Speaking to the audience at Bank Director’s 2016 Acquire or Be Acquired Conference, Michaud outlines expectations for the industry in 2016, including exposure to commercial real estate, a receptive IPO market and whether we’ll see more partnerships between banks and fintech companies.

Highlights from this video:

  • Current State of the Banking Industry
  • 2016 Banking Outlook & Emerging Trends
  • The Rise of Challenger Banks
  • The IPO Market for U.S. Banks
  • Fintech Partnerships
  • Consolidation Trends

Why Banks Are Buying Design Firms


design-1-22-16.pngWithin the past 18 months, two of the industry’s more innovative banks have made some seemingly odd acquisitions. McLean, Virginia-based Capital One Financial Corp., in October 2014, acquired Adaptive Path. The Spanish-based BBVA (Banco Bilbao Vizcaya Argentaria) acquired Spring Studio in April 2015. The common thread between these acquisitions? Both are San Francisco-based user experience and design firms.

Banks are seeing a critical need to improve customer experience, says Norm DeLuca, managing director of digital banking at Bottomline Technologies, a technology provider for commercial banks. He believes that changing consumer expectations and competition both within the industry and from fintech startups are contributing to a heightened focus on user experience. “One of the biggest differentiators that fintechs and new innovators lead with is a much simpler and [more] attractive user experience,” he says.

Customers increasingly identify their financial institution through their online experiences more than personal interactions, says Simon Mathews, chief strategy officer at San Francisco-based Extractable, a digital design agency. He believes that Capital One and BBVA found a way to more quickly improve the digital experience at their institutions. It’s a relatively new field, and good user experience designers aren’t easy to find. “What’s the quickest way to build a team? Go buy one,” says Mathews.

Design is only one piece of the puzzle. “Great design is important, but it really is only the tip of the iceberg on user experience,” says DeLuca.

A bank can’t expect to place a great design on top of outdated technology and create a good user experience, says Mathews. Data plays a key role. Customers with multiple accounts want to see their total relationship with the bank in one spot. That requires good, clean data, says Mathews.

The products and services offered by a financial institution need to be integrated. Can the customer easily manage and access separate products, such as loans and deposit accounts? Often, the process can be disjointed, and it’s a competitive disadvantage for the bank. “You might as well be buying from separate providers, if the experiences are separate,” says DeLuca.

Data analytics can also help banks personalize products and services for the customer, says Stephen Greer, an analyst with the research firm Celent. The industry is spending a lot on data analytics, “largely to craft that perfect customer experience,” he says.

While technology can be updated, organizational challenges are more difficult to overcome. Banks tend to operate within silos–deposit accounts in one area, wealth management in another and that doesn’t align with the needs of the consumer. “They don’t think, necessarily, about the total experience the user has,” says Mathews. “Users move fluidly between [delivery] channels.”

Great user experience requires “a really deep understanding of customer’s lives, and the environment they’re in, and what they’re trying to do and why,” says Jimmy Stead, executive vice president of e-commerce at Frost Bank, based in San Antonio, Texas, with $28 billion in assets.

Many banks rely on vendors for their technology needs, but “if the user experience relies on the vendors that they’re working with, and those vendors have solutions that are not customizable, then it’s really hard for them to address the customer experience,” says Alex Jimenez, a consultant and formerly senior vice president of digital and payments innovation at $7.1 billion asset Rockland Trust Co., based in Rockland, Massachusetts.

According to a June 2015 poll of banks and credit unions conducted by Celent, more than one-third rely on the user experience supplied by the bank’s vendor for online banking, mobile and tablet applications, with minimal customization. Realizing the increasing importance of the online channel, Frost Bank decided to build its own online banking platform internally in 2000, and continues to manage its user experience in-house. The bank still works with vendors, but is picky when it comes to those relationships. “How can we integrate them seamlessly into our experience?” Stead says he asks of vendors.

Today, expectations are shaped by Apple and Amazon, companies that have done a great job of defining the consumer experience. While more innovative banks like BBVA and Capital One are making user experience a priority, many financial institutions don’t provide a cohesive digital experience, or let their website and mobile app lag behind consumer expectations.

“We can’t fall too much in love with what we have today,” says Stead. “Technology moves so fast.”

Finding Opportunities in the Fintech Boom


The financial technology boom of the past few years will ultimately lead to opportunities for the banks willing to take advantage of them—either through partnership or acquisition. In November, 145 bank senior executives and board members shared their views on the fintech boom. The poll was conducted at Bank Director’s annual Bank Executive & Board Compensation Conference in Chicago. Additional respondents participated online. We’ve tabulated the results, which we share along with insights from leaders in the fintech space.

Questions about our Research? Contact Emily McCormick, director of research, at emccormick@bankdirector.com.

M&A in Fintech: A Sideshow Worth Watching


startup-10-14-15.pngIt’s no secret that what has been happening in the fintech space is attracting more attention from the world of banking. It’s hard to ignore the fact that venture capital invested $10 billion in fintech startups in 2014, compared to just $3 billion in 2013, according to an Accenture analysis of CB Insights data.

But watching M&A in the fintech space shows that these startups are much more likely to pair with others or get acquired by incumbents than they are to go public with an initial public offering, as noted by bank analyst Tai DiMaio in a KBW podcast recently.

“Together, through partnerships, acquisitions or direct investments, you can really have a situation where both parties benefit [the fintech company and the established player],’’ he says.

That may lend credence to my initial suspicions that there are more opportunities in fintech for banks than threats to established players and that these startups really need to pair up to be successful.

Take BlackRock’s announcement in August that it will acquire FutureAdvisor, a leading digital wealth management platform with technology-enabled investment advice capabilities (a so-called “robo advisor.”) With some $4.7 trillion in assets under management, BlackRock offers investment management, risk management and advisory services to institutional and retail clients worldwide—so this deal certainly caught my attention.

According to FT Partners, the investment bank that served as exclusive advisor to BlackRock, the combination of FutureAdvisor’s tech-enabled advice capabilities with Blackrock’s investment and risk management solutions “empowers partners to meet the growing demand among consumers to engage with technology to gain insights on their investment portfolios.” This should be seen as a competitive move to traditional institutions, as demand for such information “is particularly strong among the mass-affluent, who account for ~30 percent of investable assets in the U.S.”

Likewise, I am constantly impressed with Capital One Financial Corp., an institution that has very publicly shared its goal of being more of a technology company than a bank. To leapfrog the competition, Capital One is quite upfront in their desire to to deliver new tech-based features faster then any other bank. As our industry changes, the chief financial officer, Rob Alexander, opines that the winners will be the ones that become technology-focused businesses—and not remain old school banking companies. This attitude explains why Capital One was the top performing bank in Bank Director’s Bank Performance Scorecard this year.

Case-in-point, Capital One acquired money management app Level Money earlier this year to help consumers keep track of their spendable cash and savings. Prior to that, it acquired San Francisco-based design firm Adaptive Path “to further improve its user experience with digital.” Over the past three years, the company has also added e-commerce platform AmeriCommerce, digital marketing agency PushPoint, spending tracker Bundle and mobile startup BankOns. Heck, just last summer, one of Google’s “Wildest Designers” left the tech giant to join the bank.

When they aren’t being bought by banks, some tech companies are combining forces instead. Envestnet, a Chicago-based provider of online investment tools, acquired a provider of personal finance tools to banks, Yodlee, in a cash-and-stock transaction that valued Yodlee at about $590 million. By combining wealth management products with personal financial management tools, you see how non-banks are taking steps to stay competitive and gain scale.

Against this backdrop, Prosper Marketplace’s tie up with BillGuard really struck me as compelling. As a leading online marketplace for consumer credit that connects borrowers with investors, Prosper’s acquisition of BillGuard marked the first time an alternative lender is merging with a personal financial management service provider. While the combination of strong lending and financial management services by a non-bank institution is rare, I suspect we will see more deals like this one struck between non-traditional financial players.

There is a pattern I’m seeing when it comes to M&A in the financial space. Banks may get bought for potential earnings and cost savings, in addition to their contributions to the scale of a business. Fintech companies also are bought for scale, but they are mostly bringing in new and innovative ways to meet customers’ needs, as well as top-notch technology platforms. They often offer a more simple and intuitive approach to customer problems. And that is why it’s important to keep an eye on M&A in the fintech space. There may be more opportunity there than threat.