Are Innovation Labs the Best Way to Innovate?


innovation-1-15-18.pngThese days, companies as diverse as Lowe’s and Blue Cross are touting a shiny new innovation lab—and banks are no different. These special divisions, designed to incubate new ideas and technologies, are on the rise. According to a report from the website Innovation Management, the number of innovation labs jumped 66 percent in a 15-month period from July 2015 through October 2016. But even though some banks like to think of themselves as technology companies, does it really make sense for them to build standalone innovation teams?

Bank innovation labs are unlikely to replicate the secret sauce found in many successful startup companies because they are artificially engineered environments that cannot recreate the parameters that allow the most successful technologies to thrive. As described by Anderee Berengian, CEO of Cie Digital Labs, in-house innovation labs are missing three key ingredients:

  1. A passionate leader: Apple had Steve Jobs, Facebook has Mark Zuckerberg and Amazon has Jeff Bezos. The most successful technology companies in the world have one thing in common: a passionate, obsessive founder. Bank innovation labs miss out on this key ingredient. Even if they’re able to hire a technical wunderkind to run the lab, they simply can’t have that kind of passion. Part of this is because of a lack of ownership. Part of this is that labs are rarely, if ever, founded to pursue a specific idea or product. Bank labs are conjured up to digitize the company, explore new products or pursue any myriad of equally vague directives. These directives do not inspire and, without a visionary founder to lead the way, labs flounder about trying to build something that will meet undefined and unmeasurable objectives.
  2. Room to fail: Banks expect a reasonable ROI when they make a large investment. As Berengian described, “[p]icture Thomas Edison trying 5,000 light bulb filaments before settling on tungsten . . . [t]he reality is, most profit-focused companies would stop after 500 tries. Edison would then go start his own company.” Many of the “innovations” banks expect to come out of labs will not immediately add to the bottom line, or may be difficult to measure in any meaningful capacity for that matter.
  3. Constraints: Bank innovation labs also lack the constraints that force startups to either succeed or burn out. Bank innovation teams have security. So what if they don’t make that iteration deadline? It’s not like they need to ensure another funding round. Without clear objectives and high stakes, it’s hard to push an innovation lab to the lengths necessary to be truly groundbreaking.

Banks are, by nature, the direct opposite of startups; so why are they striving to artificially recreate that environment? That’s not to say that banks are incapable of invention—quite the opposite. To meet the demands of the digital world, banks don’t need innovation labs. They simply need to harness the creativity and ingenuity their teams already possess.

We know that innovation works best when it’s engrained as a corporate cultural value (see the book “Driving Growth Through Innovation,” by Robert Tucker). Too often, responsibility for innovation is limited by organizational silos that relegate the task (typically seen as merely one of many check marks on a CEO’s to-do list) to a small pocket of individuals. Technological advancement shouldn’t be a pet project for an executive team, or a nebulous directive for an innovation lab. It should be a goal that’s shared by every employee—from the retail teller to the CEO—so that ideas can flow freely from those that have a good handle on the way the bank actually works.

Instead of investing in new innovation labs, banks should strive to encourage organic innovation by fostering a culture that prizes critical thinking and new ideas. For example, USAA stays on the cutting edge of technology by utilizing the ideas of its 30,000 employees through events, challenges and its “ideas platform,” which allows any bank employee to post and vote on new ideas. Over 1,000 employee ideas were implemented in 2017. (For more on USAA, read the article “Crowdsourcing Innovation” in the May 2017 issue of Bank Director digital magazine.)

That’s not to say that remaking a bank’s culture is easy. Cultivating culture is hard, especially at a large institution, and can be even more difficult than creating an in-house innovation lab. However, the rewards of culture shift can be more far reaching and long lasting than a lab because new talent—especially tech talent—wants to work in an open, inclusive environment that encourages collaboration.

Innovation is not new; it’s something humans inherently do when faced with a problem. To truly innovate, banks don’t need new office facilities or new branches on their organizational chart (and, really, who needs more of those?) Instead, they need to embrace the natural creativity in their organizations and harness ideas to create specific solutions to real issues.

Using Culture to Drive Innovation at Your Bank


culture-9-1-17.pngHow important is culture when it comes to changing a company’s approach to innovation and technology? Bank Director’s 2017 Technology Survey found that few bank executives and directors believe that their bank’s culture has more in common with a technology company than a traditional bank. But that doesn’t mean that cultural elements don’t play a role in creating a tech-savvy bank.

People generally underestimate the importance of culture and innovating,” says Jimmy Stead, chief consumer banking officer at Frost Bank, headquartered in San Antonio, Texas, with $30 billion in assets.

Most financial institutions wouldn’t be comfortable operating like a technology company. Frost Bank doesn’t think like a technology company, says Stead, but the bank has adopted a cultural mindset along with practices that promote innovation. Other banks are changing their approach too. Here are four elements that financial institutions are embedding in their cultures to encourage innovation and technological change.

Make empathy a core cultural component.
Caring about the customer is a core value at Frost Bank. “If you’re going to truly innovate, you have to start with a problem that’s worth solving,” says Stead. To solve problems for customers, you have to know what problems are important to them. “You don’t do that by caring about innovation. You do it by caring about people,” he says. Improvement is a secondary element of this corporate mindset, and employees are encouraged and empowered to identify and solve customer pain points.

Require bank employees to actively use financial technology.
In his “Advice for New Bank Directors,” Bank Director Editor in Chief Jack Milligan encourages board members to use financial technology, including the bank’s mobile app and competing products such as Venmo, the person-to-person (P2P) payments app owned by PayPal. It’s sound advice that extends to bank staff as well.

When Central National Bank, in Waco, Texas, with $820 million in assets, first introduced mobile banking, Chief Information Officer Rusty Haferkamp says that employees struggled to become familiar with the technology and, by extension, support customers. Later, the bank required that staff use the P2P payments function within the bank’s mobile app, and employees are better equipped to help customers. Training staff on the latest technology is an ongoing process as new solutions continue to evolve.

Encourage collaboration and partnerships.
Teamwork drives innovation at Frost Bank. “We’re fostering an environment of giving people the space to experiment some, and breaking down barriers so that they can work closely and be intensely focused on our customer,” says Stead. An open and collaborative environment helps Frost attract talent that has the technical know-how, he adds.

Relationships with the right technology vendors can drive innovation and also provide another layer of expertise. “I’ve tried through technology to help position the bank, knowing that we can’t develop it internally,” says Chip Register, chief administrative officer and CIO at Fauquier Bankshares, which has $646 million in assets in Warrenton, Virginia. Partnerships can enable this development.

Foster and reward innovative ideas.
San Antonio-based USAA, the diversified financial services parent of $81 billion asset USAA Federal Savings Bank, relies on an array of programs, including competitions, to encourage employees to come up with innovative ideas. Ninety-four percent of USAA employees participated in USAA’s innovation programs in 2016, with USAA implementing more than 1,000 employee ideas, says Lea Sims, assistant vice president of USAA Labs, which she discusses in further detail in Bank Director digital magazine’s May issue.

Frost Bank hosts an annual hackathon, a week-long event where employees collaborate on and develop technology solutions. Experimentation is encouraged—the winning team had two failed ideas before hitting on a winner—and each team has to communicate with customers about their concept. Some of these ideas are put to use at the bank. But that’s not the only goal of the event. “We want to make sure we’re giving smart people a chance to just work on something they’re passionate about,” says Stead.

Department managers at $444 million asset Franklin Savings Bank in Franklin, New Hampshire, are expected to identify efficiencies or areas for improvement in the customer experience, says Cheri Caruso, the bank’s CIO. These goals are part of each manager’s quarterly review, and these managers in turn engage their departments to uncover ideas and implement solutions.

Support for technology comes from the top. “We’re very fortunate that our board is very technology-focused,” says Caruso. She says new employees are often surprised by how much technology is in use at the bank, given its size. “It all comes from the top with the board supporting this,” she says.

Balancing Innovation and Risk Through Disciplined Disruption


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The digital disruption reshaping financial services mirrors the disruption brought about by Netflix, Uber, Lyft and Amazon in other sectors of the economy. What distinguishes financial technology companies is the financial and personal information their consumers entrust them with. The savviest fintech companies are those that employ discipline and structure to manage risk.

Many fintech companies adopt a fast-failure approach: move quickly and accept mistakes as necessary for innovation. Coordinating innovation with risk management might seem cumbersome. But if innovation is not integrated with effective risk management, companies risk running afoul of regulatory or compliance responsibilities.

One challenge fintech companies face is the sheer number of regulators that have rulemaking or supervisory authority over them due to unique business models and state level licensing and regulators. In the absence of a uniform regulatory scheme, there is widespread confusion about rules, expectations, oversight and regulatory risk. Many fintech companies and their banking partners remain uncertain about which laws and regulations apply or, most importantly, how they will be supervised against those rules.

A potential solution to this problem was the announcement in December 2016 by the Office of the Comptroller of the Currency (OCC) that it intended to create a special purpose national bank charter for fintech companies. The OCC aims to promote safety and soundness in the banking system while still encouraging innovation. A special purpose national bank charter would create a straightforward supervisory structure, coordinated by one primary regulator. This has turned out to be a controversial proposal, since the Conference of State Bank Supervisors has sued the OCC in federal court claiming that creation of a fintech charter would be a violation of the agency’s chartering authority.

Common Weaknesses
Executing an effective risk management plan in an innovative culture is challenging. Companies should be alert to the following common areas of weakness that can create vulnerability.

Compliance culture: Fintech companies often have more in common with technology startups than with financial services companies, which becomes particularly notable when maintaining a compliance management system (CMS). Compared with banking peers, many fintech firms generally have less mature compliance cultures that can struggle under increased regulatory scrutiny. The lack of a comprehensive CMS exposes companies to considerable risk, particularly as regulators apply bank-like expectations to fintech companies.

Risk assessments: Many companies fail to move beyond the assessment of inherent risk to the next logical steps: identifying and closing gaps in the control structure. Assessing the control environment and continually aligning an organization’s resources, infrastructure and technology to pockets of unmitigated risk is critical.

Monitoring and testing: Fintech companies can fail to distinguish between monitoring and testing, or understand why both are important. When executed properly, the two processes provide assurance of sound and compliant risk strategy.

Complaint management: Many organizations become mired in addressing individual complaints instead of the deeper issues the complaints reveal. Root cause analysis can help companies understand what is driving the complaints and, if possible, how to mitigate similar complaints through systemic change.

Corrective action: Finally, because of their fast-fail approach, fintech companies do not always follow up to remediate problems. Companies need feedback loops and appropriate accountability structures that allow them to track, monitor and test any issues after corrective action has taken place.

Strategies Across the Organization
Fintech companies should define clear and sustainable governance and risk management practices and integrate them into decision-making and operational activities across the organization. There are a number of actions that can help companies establish or evaluate their risk management strategies.

Assess risks: Because the fast-failure approach can ignite risk issues across the board, companies should evaluate their structure and sustainability of controls, the environment in which they operate, and their leadership team’s discipline level to measure the coordination of risk management and operational progress.

Identify gaps: Often, these gaps (for example non-compliance with certain laws and regulations, ineffective controls or a poor risk culture) represent the gulf between risks and the risk tolerance of the organization. A company’s risk appetite should drive the design of its risk management strategy and execution plan.

Design a road map: Whether a certain risk should be managed through prevention or mitigation will be driven by the potential impact of the risk and the available resources. Defining a plan within these constraints is important in explaining the risk management journey to key stakeholders.

Execute the plan: Finally, companies should deploy the resources necessary to execute the plan. Appropriate governance, including clear lines of accountability, is paramount to disciplined execution.

Successful companies align their core business strategies with effective risk management and efficient compliance. This alignment is especially important in the constantly changing fintech environment. Risk management and innovation can and should coexist. When they do, success is just around the corner.

John Epperson, principal with Crowe Horwath LLP, is theco-author of this piece.

Best of FinXTech Award Winners Announced at Nasdaq


award-winner-4-26-17.pngWhile many bankers still think of them as a source of competition, most fintech companies focus on providing solutions that will ultimately make financial institutions more efficient and profitable. True, some fintech firms do compete head-to-head with banks, but the great majority of them are more interested in partnering with banks in ways that will benefit both sides. In recognition of this growing trend towards cooperation, FinXTech.com recently held its 2nd annual Best of FinXTech Awards, which highlights collaborative efforts between banks and fintech companies working together in a successful partnership. From a pool of 10 finalists, three winners were chosen by this year’s FinXTech Advisory Group. The judging criteria were strength of integration, innovation and growth in revenue, reputation and the customer base that resulted form the project. The three teams, whose stories are detailed below, were honored today at the FinXTech Summit in New York.

USAA and Nuance

Headquartered in San Antonio, Texas, USAA wanted to develop a stronger relationship with current customers while also attracting new customers through the use of technology that would meet their needs and preferences. Since 2013, USAA has utilized Burlington, Massachusetts-based Nuance’s virtual assistant technology—called Nina—on its mobile banking app. Nina leverages natural language understanding and artificial intelligence to provide a proactive and personalized customer experience. In 2016, following Nina’s widespread adoption by USAA members on the mobile channel, the bank deployed Nina on its usaa.com website.

On usaa.com, Nina provides immediate, human-like support and assists USAA members with tasks such as activating cards, changing a PIN, adding travel notifications and reporting lost or stolen cards. Nina goes far beyond a static question-and-answer capability to deliver a more human experience that speaks, listens, understands and helps USAA members get things done efficiently. Nina responds to 1.4 million requests per month and eliminates the need for USAA members to sift through menus, ensuring that every interaction begins and ends with an effortless, natural experience. Through its partnership with Nuance, USAA is able to provide its customers with a compelling, multi-channel, automated customer service experience that keeps it ahead of the pack.

Scotiabank and Sensibill

In October 2016, Scotiabank—Canada’s third largest bank—and Sensibill, both of Toronto, launched eReceipts, a service that allows customers to store, organize and retrieve any receipt (paper or electronic) directly from Scotiabank’s mobile banking app and wallet. Scotiabank is the first of the Canadian Tier 1 banks to rollout the solution, and Scotiabank CEO Brian Porter has referred to it as a “game-changing application.”

Sensibill’s receipt processing engines uses deep learning and machine-learning to extract and structure information about each item, including product names and SKU codes. This adds clarity to otherwise vague transactions and reduces the friction associated with searching for a specific purchase. The service is also the first to offer consumers automatic matching of receipts to card transaction histories, which supports customers’ need for convenience and accessibility and enables Scotiabank to provide a seamless end-to-end payment experience.

Scotiabank customers use the service to track both personal and business expenses, with approximately 38 interactions with the service per month per customer. In the same way that online and mobile bill pay serves as a “sticky” product that retains customers who do not want to move their information to another bank, eReceipts has the propensity to reduce attrition. Forty-eight percent of eReceipts users use the app’s folders and notes to keep themselves organized, with captured receipts often being revisited. Not only does the app improve the customer experience, it also has the potential to lower the bank’s costs. For example, Scotiabank believes that 20 percent of credit and debit card queries could have been resolved through the Sensibill app, which ultimately should lead to a reduction in call center activity.

Green Dot Corp. and Uber Technologies Inc.

One of the biggest challenges workers in the gig economy face is gaining speedy access to their earnings. In March 2016, Uber, the transportation network company headquartered in San Francisco, and Green Dot, a prepaid card issuer located in Pasadena, California, launched a customized business version of Green Dot’s GoBank mobile checking account. Initially piloted in San Francisco and a few other cities, the solution provides Uber drivers with immediate access to their funds through a feature called Instant Pay. All drivers do is open a free Uber debit card from a mobile GoBank checking account and use this account to access their earnings instantly, for free, up to five times per day. Drivers are also able to use their Uber debit card for free at any of GoBank’s 42,000 ATMs spread across the country, and can also use it for transactions wherever Visa cards are accepted.

The pilot was so successful that in June 2016, Uber offered the solution to all of its drivers nationally, resulting in over 100,000 drivers signing up since August. That same month, in response to driver feedback and increasing demand, Uber and Green Dot announced it was expanding Instant Pay to work with not only a GoBank account, but almost any U.S. MasterCard, Visa or Discover debit card that is attached to a traditional checking and savings account. The expanded debit card program has scaled quickly, with millions of transactions having occurred between the August launch date and September 30, 2016.

The other seven finalists in this year’s Best of FinXTech Awards were IDFC Bank and TATA Consultancy Services, Franklin Synergy Bank and Built Technologies, National Bank of Kansas City and Roostify, Somerset Trust Co. and BOLTS Technologies, Toronto-Dominion Bank and Moven, Woodforest National Bank and PrecisionLender, and WSFS Bank and LendKey.

A Roadblock That Ruins Futures


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Culture is one of the best things a bank has going for it. It’s also one of the worst.

While I am bullish on the future of banking as a concept, I am admittedly concerned about what’s to come for many banks who struggle with cultural mindsets resistant to change. Specifically, the same mindsets that helped weather the last few years’ regulatory challenges and anemic economic growth may now prevent adoption of strategically important, but operationally risky, relationships with financial technology companies.

Most banks don’t have business models designed to adapt and respond to rapid change. So how should they think about innovation? I will raise that question and others at our upcomingFinTech Weekin New York City startingtoday, a look at how technology continues to change the nature of banking. Those in attendance include banks both large and small, as well as numerous financial technology companies.

More so than any regulatory cost or compliance burden, I sense that the organizational design and cultural expectations at many banks present a major obstacle to future growth through technology.While I am buoyed by the idea that smaller, nimble banks can compete with the largest institutions, that concept of agility is inherently foreign to most legacy players. It doesn’t have to be. Indeed, Richard Davis, the chairman and CEO of the fifth largest bank in the country, U.S. Bancorp, shared at our Acquire or Be Acquired Conference in Phoenix last January that banks can and should partner with fintech companies on opportunities outside of traditional banking while working together to create better products, better customer service and better recognition of customer needs.

The urgency to adapt and evolve should be evident by now.The very nature of financial services has undergone a major change in recent years, driven in part by digital transformation taking place outside banking.Most banks—big and small—boast legacy investments.They have people doing things on multi-year plans, where the DNA of the bank and culture does not empower change in truly meaningful ways.For some, it may prove far better to avoid major change and build a career on the status quo then to explore the what-if scenarios.Here, I suggest paying attention to stories like those shared by our Editor-in-Chief Jack Milligan, who just wrote about PNC Financial Services Group in our current issue of Bank Director magazine. As his profile of Bill Demchak reveals, it is possible to be a conservative banker who wants to revolutionize how a company does business.But morphing from a low-risk bank during a time of profound change requires more than just executive courage. It takes enormous smarts to figure out how to move a large, complex organization that has always done everything one way, to one that evolves quickly.

Of course, it’s not just technological innovation where culture can be a roadblock.Indeed, culture is a long-standing impediment to a successful bank M&A deal, as any experienced banker knows. So, just as in M&A deals, I’d suggest setting a tone at the top for digital transformation.

Here are three seemingly simple questions I suggest asking in an executive team meeting:

  • Do you know what problems you’re trying to solve?
  • What areas are most important to profit and near-term growth?
  • Which customer segments are critical for your bank?

From here, it might be easy to create a strategic direction to improve efficiency and bolster growth in the years ahead.But be prepared for false starts, fruitless detours and yes, stretches of inactivity.As Fifth Third Bank CEO Greg Carmichael recently shared in an issue of Bank Director magazine, “Not every problem needs to be solved with technology… But when technology is a solution, what technology do you select? Is it cost efficient? How do you get it in as quickly as possible?You have to maintain it going forward, and hold management accountable for the business outcomes that result if the technology is deployed correctly.”

Be aware that technology companies move at a different speed, and it’s imperative that you are nimble enough to change, and change again, as marketplace demands may be different in the future. Let your team know that you are comfortable taking on certain kinds of risk and will handle them correctly. Some aspects of your business may be harmed by new technology, and you will have to make difficult trade-offs. Just as in M&A, I see this is an opportunity to engage with regulators.Seek out your primary regulator and share what you’re looking for and help regulators craft an appropriate standard for dealing with fintech companies.

Culture should not be mistaken for a destination.If you know that change is here, digital is the expectation and you’re not where you want to be, don’t ignore the cultural roadblocks. Address them.

Buying Bank Technology: If Not Now, When?


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FoMO, or the Fear of Missing Out, isn’t just a pop culture buzzword created to describe our obsession with social media. It’s an actual, scientifically proven phenomenon described in scientific literature as “the uneasy and sometimes all-consuming feeling that you’re missing out—that your peers are doing, in the know about, or in possession of more or something better than you.”

That feeling probably sounds very familiar to bankers these days. In the press, in blogs, on podcasts, and at every industry conference, bankers are hearing that the time is now to make big technology changes in their organizations. Everyone seems to be busy innovating, and many bankers are left wondering if they’re the ones being left behind.

In this case, the answer may be “Yes.”

We are facing a set of once-in-a-generation circumstances that will determine the winners and losers in banking for the coming decades. And this separation of the “haves” from the “didn’t act fast enough to be among the haves” is already in motion.

Here are the four big trends that have converged to create the opportunity—or threat—of a lifetime for banks.

1) Tech Spending Neglected
A great deal has been written about how antiquated much of the banking infrastructure has become. Some concerns about legacy systems are overblown, but there is undoubtedly a marked difference between the digital experience customers have with their banks and what they encounter in most other parts of their lives. Banks still handle debits and credits as well as ever, but when compared to the Amazon, Netflix or Gmail experience, the gap is widening. Banks cut all spending following the financial crisis, and have been slow to replace those vacated technology budgets in the face of new regulations and shrinking margins. The result is wide swaths of banking technology that haven’t been upgraded in 10-plus years.

2) Expected “windfalls” from regulatory and tax reform
In our interactions with banks, there has been a sudden change in mood. Bankers have shifted quickly from the glass being half empty to half full, in large part because of the outcome of the November elections. Banks now see the potential for big windfalls, in the form of tax relief and regulatory reform, with a recent Goldman Sachs piece suggesting that industry earnings in 2018 could increase by 28 percent over current estimates if the chips fall just right.

3) Interest rates (and margins) are rising
In addition to those windfalls, banks are also getting a long-awaited earnings boost from rising interest rates. The Federal Reserve has increased overnight rates by 0.75 percent, and long-term rates have followed suit, with 10-year Treasury yields up more than 1 percent from their 2016 lows. Deposits rates have been slow to follow along, resulting in margins that are finally improving after years of painful compression.

4) Game changing technology is plentiful and accessible
Finally, in the decade since most banks have been actively in the market, the number and quality of technology solutions has exploded. Computing power, high quality data sets and cheap storage are contributing to a renaissance in enterprise software, and banks now have multiple possible solutions for just about any conceivable business need. You are no longer beholden to your core provider to sell you everything, as the new generation of tools are better at integrating, easier to deploy and easier to use. On top of all that, most of them are also incredibly cheap for the value they are providing, making them accessible to banks of all sizes and shapes.

When you combine these four factors, you see why there is so much hoopla around innovation and fintech. Many bankers are viewing the next few years as their one big chance to completely revamp the critical pillars of their business. Due to the long gap in meaningful technology investment, they are starting with a blank slate, and because of the recent improvement in profitability trends, they have sufficient budgets to make substantial changes. They are approaching the market and finding plentiful options and are excited by the opportunity.

Some will choose wisely and win big. Others will choose poorly and will not fare as well. But FoMO is real: If you simply stand on the sidelines and do nothing, that is also a choice. Your competitors will leave you behind, and soon your customers might just do the same.

If you’re not willing to make some changes in this environment, when will you be?

CFPB Assumes ’Catalyst’ Role in Fintech Innovation


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In 2012, the Consumer Financial Protection Bureau (CFPB) recognized that the industry we now call fintech was starting to accelerate the delivery of cutting edge technology products to the financial services marketplace. The CFPB was aware that many of these offerings would make banking faster and easier for consumers and might also allow banks to perform their operations far more efficiently. At first blush, that seems like a win-win situation for consumers and the industry alike. However, the bureau was also aware that rapid growth of the largely unregulated fintech sector created the potential for abuse and fraud. The result was Project Catalyst, a program in which the bureau works with fintech firms to encourage the development of new consumer-friendly products while making sure these companies color inside the regulatory lines.

The CFPB released it first look at the achievements of the program in October. In “Project Catalyst report: Promoting consumer-friendly innovation,”the bureau outlined it efforts to work with fintech companies to develop consumer-friendly programs while avoiding potential regulatory pitfalls. In his preamble to the report, Director Richard Cordray noted that “As these efforts reflect, the Bureau believes innovation has enormous potential to improve the financial lives of consumers. At the same time, however, the Bureau recognizes that innovation cannot skirt the need for sufficient oversight and consumer protection.” While the CFPB wants to encourage financial innovation, it has endeavored to do so in a manner that keeps consumers and their money safe. So far the bureau would seem to be succeeding.

The report also outlines areas where the bureau has high interest and concerns. For example, payday lending products has been a concern for the CFPB from day one. These high-cost, short-term loans exploit lower-income and underbanked consumers who have cash flow issues. To reduce the need for these products the bureau has been encouraging the development of alternatives that help consumers better manage their finances to avoid the cash crunch that creates the need for a payday loan in the first place.

Underbanked and “credit invisible” consumers are a particular concern of the bureau. These individuals tend to be less sophisticated and are often easy prey for less scrupulous fintech companies. While they may not have a bank account, they do have smartphones and are targeted for payday loans, car title loans and other high-cost consumer loan products. Project catalyst has been actively working with fintech companies to find ways to deliver reasonably priced loans to the underbanked market on terms that are also favorable for the lender.

Building savings is also a key focus for the bureau. Project Catalyst is interested in working with companies that develop products that encourage savings and make it easier for customers to get and keep money in a savings account. Building tools that help consumers understand and utilize the budgeting and savings process is a key goal of the project and has been since the beginning. One of Project Catalyst’s first collaborations was with the personal finance website Simple to develop a program that helped consumers understand their spending habits and patterns.

Project Catalyst also highlights the need for improvements in mortgage servicing platforms. The bureau notes that many banks have just loaded new mortgage servicing platforms on the back of their current legacy system and that is not the optimum solution. The report comments that “These workarounds can be costly and are sometimes plagued by programming errors, failures in system integration or instances of data corruption. These failures cause consumer harm and increase the risk of data inaccuracies during loan transfers.” The CFPB is working with fintech companies to build new, more efficient technology platforms that will make the process easier and more consumer friendly.

Credit reporting and clarity are also a focus of the CFPB. Many credit users have no idea what is on their credit report and any technology that makes it easier to check credit scores and profiles is of interest to the bureau. It is also working with companies to develop products that help understand what types of behavior might improve or worsen their score.

Project Catalyst is also looking to improve the peer-to-peer payments process. The bureau is working with fintech providers to help people send money overseas, pay their bills or make purchases on a cost effective basis. It has also met with firms that are working on providing easily accessed price comparisons when sending money overseas so that people can find the cheapest and most convenient way to transfer cash to relatives back home.

While the CFPB’s mission is to help and protect all consumers, it is evident from the report that the bureau is very sensitive to the needs of the underbanked and less affluent consumers. This segment of the market has always been the target of fraud and predatory practices, and the introduction of mobile technology has made them more so than ever before. Fintech companies that develop programs to serve and protect this market will find the CFPB more than willing to help get their products to market.

Creating Regulatory ’Sandboxes’ to Protect Innovation


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Fintech regulation has presented a confusing picture here in the United Sates for several years now. Various federal agencies have at least some measure of control over fintech companies, and it can be challenging for innovative new startups to figure out which regulatory authority they are supposed to be talking to at any stage of the game.

Because of this confusion, there is a risk that we could fall behind the rest of the world as nations including Singapore and the United Kingdom have taken steps to provide their fintech companies with the benefits of a looser regulatory environment. Both nations have developed what they are calling fintech “sandboxes” to encourage and accelerate the development of new ideas and products for the financial services industry. Emerging countries like Thailand and Abu Dhabi are also promoting their version of the fintech sandbox to attract new companies and investment dollars into their economy.

There are some signs that the U.S. is also moving to relax regulation and encourage fintech innovation. I talked recently with William Stern, a partner at alaw firm whose practice focuses on both banking and financial technology. Stern says he is seeing some positive movement among U.S. regulators on the fintech front.

Stern referenced the Financial Services Innovation Act of 2016, introduced by Rep. Patrick McHenry, R-N.C., in September of this year. The bill creates a program similar to that used in the U.K. and would allow innovative new companies to apply to one or more of the agencies that currently oversee the financial services industry for a waiver of certain regulations and requirements. It would also prevent other agencies from introducing enforcement actions against the companies while the agreement was in place.

Stern noted that for a smaller company facing the full brunt of all the rules and regulations from a multitude of agencies including the Federal Deposit Insurance Corp., the Consumer Financial Protection Bureau, the Securities and Exchange Commission and the Office of the Comptroller of the Currency, it can be incredibly discouraging for a young entrepreneurial company, particularly one with limited funding. Entering into a compliance agreement would allow the firm to move forward, test and introduce new products without falling under the full weight of the combined rules and regulations at various levels of government.

Stern believes there is support on both sides of the aisle in Congress for encouraging financial innovation, but he also points out that the banking industry isn’t necessarily a big fan of relaxed regulation for fintech companies. Allowing smaller fintech concerns to operate without complying with the same rules as banks would place the latter at a disadvantage. Concerns about maintaining a high level of consumer protection have also been expressed.

For his part, Rep. McHenry thinks the legislation is needed to keep companies from leaving the U.S. and taking their innovation to countries with a less onerous regulatory environment. “Innovation in financial services has created more convenient and secure ways to meet the demands of American consumers,” McHenry said in a statement when he introduced his bill. “For these to succeed, however, Washington must rethink its own laws and regulations to keep up with the growth and creativity in the private sector. This bill represents a mindset shift in the way we address financial regulation. Rather than the command-and-control structure of the past, my bill establishes an evolved regulatory framework that encourages financial innovation, all while maintaining our regulators’ commitment to the safety of consumers and our financial markets.”

The bill is still in the early stages of the legislative process and is highly unlikely to be passed this year. McHenry has acknowledged this but hopes it will spark discussions that will carry over into the next congressional session, which will begin in January. The bill will likely face substantial opposition from those who favor greater rather than reduced regulation of financial services—a position generally associated with the Democratic Party—so the outcome of the congressional races on Nov. 8 could have a huge impact on the prospects for passage.

Both the OCC and the CFPB have been encouraging innovators to work closer with them so the agencies can help them navigate the compliance waters. Back in March, the OCC released a paper titled “Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective.” When the report was introduced, Comptroller of the Currency Thomas J. Curry said that “At the OCC, we are making certain that institutions with federal charters have a regulatory framework that is receptive to responsible innovation and supervision that supports it.” The paper outlined eight principles the agency thinks should guide financial innovation and was viewed by many as the first step towards making it easier for innovators to deal with regulators.

As other nations around the world develop and embrace the sandbox concept, there is some legitimate concern that the U.S. will see companies and jobs leave for a more relaxed environment elsewhere.

How Government Disruption Impacts Fintech Innovation


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It is a given that markets are constantly being disrupted by innovation. I would argue that the financial services marketplace is also being disrupted by legislation and regulation. Let’s face it, the payments sector is hot right now. Issues that were once solely the province of industry publications are now widely covered by mainstream media. This fact is not lost on the legislative and regulatory community.

Last year we saw the creation of the Congressional Payments Technology Caucus, a bipartisan group of lawmakers designed to keep the U.S. Congress informed of the rapid changes in the financial services industry. Over the last year, the caucus has held briefings on issues ranging from EMV Migration to mobile payments. This year, the House Financial Services Committee and Senate Banking Committee have held numerous hearings on payments-related matters as well.

One of the more contentious topics addressed is Operation Chokepoint, a controversial campaign spearheaded by the Department of Justice in conjunction with several federal consumer protection and banking regulatory agencies (including the Federal Trade Commission and the Federal Deposit Insurance Corp.) to hold acquirer financial institutions and their payment processor partners responsible for allegedly illegal acts committed by merchants and other third-party payees.

This perhaps well intentioned program has moved beyond illegal acts to targeting legal activities that are perceived by some prosecutors and regulators as undesirable, which in turn has led to the denial of banking services to businesses that operate lawfully. Legislative attempts to rein in this initiative, led by Rep. Blaine Luetkemeyer, R-MO, have passed the House but face a future that is likely dependent on the outcome of the November elections.

Given this election season and the relatively limited number of working days remaining on the congressional calendar, it is unlikely that any significant financial services or fintech legislation will pass this year. Still, there is considerable opportunity for additional market disruption by federal regulators, particularly the Consumer Federal Protection Bureau (CFPB).

Those involved in the prepaid space await the CFPB’s long delayed final rule on prepaid products that have the potential to adversely impact long established business models-thereby driving some companies out of business.

Despite its popularity and the fact that consumers must opt-in to the program, overdraft services are viewed with skepticism, if not antipathy by the CFPB. The CFPB’s goal is to issue proposed rules on this in the near future. These rules have the potential to drive up cost and reduce access to consumers who have found these services to be beneficial.

Unlike other federal agencies, the CFPB will not be affected by the November elections. Created as part of the Dodd-Frank Act, the bureau was structured as an independent entity funded by the Federal Reserve, which insulates it from the effects of a change in the administration. The term of its current director, Richard Cordray, does not expire until 2018. And though this is currently being challenged in court, the director can only be fired for cause or malfeasance.

It is difficult if not impossible for legislation or regulation to keep up with technology advances and the dramatic changes they are creating in the payments marketplace. Such efforts should be flexible enough to accommodate these changes and not create their own disruption.

BNY Mellon Is Betting on Blockchain


blockchain-6-24-16.pngSometimes people ask BNY Chief Information Officer Suresh Kumar if blockchain is a friend or foe. “Why would I think of that as a foe?” Kumar told the magazine Fast Company in June. “It’s another piece of technology that could help us and our clients and remove friction from the system.”

Blockchain is the technology underlying bitcoin, the most popular form of cryptocurrency, a digital, encrypted currency that isn’t tied to a central bank. Blockchain is the public ledger for all bitcoin transactions, and each block on the blockchain represents a transaction. These transactions are irreversible.

Organizations, including banks, see potential for blockchain technology to revolutionize many areas of the financial industry and beyond, including securities trading, payments, fraud prevention and regulatory compliance. “We think blockchain can be transformative,” said BNY Mellon CEO Gerald Hassell, in the company’s first quarter 2016 earnings call. “We’re spending a lot of time and energy on it, but I think it’s going to take some time to see it play out in a full, meaningful way. We actually see ourselves as one of the major participants in using the technology to improve the efficiency of our operations and the resiliency of our operations.”

Saket Sharma, BNY Mellon’s chief information officer of treasury services, chairs a virtual team at the bank that includes all lines of the bank’s business. The team meets monthly, with the goal to foster understanding regarding how blockchain could impact each area of the organization. Meanwhile, BNY Mellon’s innovation center actively works with the technology. “We need to constantly be in touch with it, because technology’s evolving so rapidly,” he says.

BNY Mellon created an internal currency, called “BKoins,” to understand how blockchain technology could impact the bank. “We thought it would be good to do something purely internally, and learn about the technology,” says Sharma.

BKoin doesn’t have real value, but by working with it, the technology team now understands how the blockchain is generated, and from there is learning how it could transform different business lines, as well as the organization as a whole. It was widely reported last year that the cryptocurrency would be used as an internal rewards program, where employees could exchange BKoins for gift cards and perks. While the bank doesn’t rule out those possibilities for the future, Sharma says that this isn’t how BKoin is currently used and, aside from that, was never the goal. The goal is to educate BNY Mellon’s technology team and business lines about blockchain’s possibilities, and create a conversation about the technology’s potential for the organization. The approach has resulted in a significant increase in knowledge about blockchain at BNY Mellon in the span of just a few months, he says.

BNY Mellon isn’t the only bank using its own internal cryptocurrency to test blockchain’s potential. Citigroup and Japan’s Bank of Tokyo-Mitsubishi UFJ are also experimenting with proprietary digital currencies.

In addition to internal trials, BNY Mellon is also a member of a consortium of more than 40 global banks, including JPMorgan Chase & Co., Wells Fargo & Co. and Bank of America Corp., which is led by the financial innovation firm R3 in New York. Following a smaller test in January, 40 banks, including BNY Mellon, successfully traded fixed income assets in March using blockchains built by IBM, Intel and startup firms Chain, Eris Industries and Ethereum.

How blockchain will impact the banking industry is unclear for now. But the potential benefits are promising: Efficiency gains created through the technology could save the industry $20 billion annually by 2022, according to a joint paper released by Santander Innoventures, the consulting firm Oliver Wyman and London-based advisory firm Anthemis Group.

But the blockchain probably isn’t ready for primetime yet. In June, a hack resulted in the theft of almost 4 million “ether,” a cryptocurrency housed on the Ethereum blockchain, from the Decentralized Autonomous Organization (DAO), a crowdfunded venture capital firm. At the time, the stolen “ether” was valued at $79.6 million. After the discovery, the value of the cryptocurrency plunged precipitously. Bitcoin’s value stumbled as well.

Two days after the DAO incident, Ethereum creator Vitalik Buterin wrote: “There will be further bugs, and we will learn further lessons; there will not be a single magic technology that solves everything.”

Banks are less comfortable with the inevitable failures that come along with experimentation, but BNY Mellon and other global banks will continue to cautiously experiment, combining internal experiments with peer collaboration. “We’re going to have to work together with our industry peers to really drive [blockchain innovation],” says Sharma.