OPEN FINANCE CONFERENCE - tisa.uk.com · 16 Pre-2000 –before the emergence of online platforms...

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OPEN FINANCE CONFERENCEA Digital Revolution reshaping UK Financial Services

Monday 18th November 2019

Lead sponsor

Kindly hosted by

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Opening remarks from TISA

David Dalton-Brown, Chief Executive Officer, TISA

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Open Finance

• The ability for consumers to have full access to their financial data so as to take greater

control of their Financial Well-Being.

• Covers all aspects of Financial Well-Being : Health and Wealth

• Made possible through the introduction of:

• Open standards and APIs.

• Supporting Trust Framework - Consumer Consent, liability management, standards & regulatory

permissions for trusted parties.

• Required regulatory and legal developments

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Open Finance – FDATA Definition

“Open Finance” describes the process whereby a financial services customer can choose to enable Third Party Providers (TPPs) to offer products and services by compelling current providers of financial services to share access to the customer’s financial data. Some of

the services provided by TPPs may be competitive to existing financial service providers.

The Genesis Of Open Finance

Eduardo Martinez Barrios - Head of Open Banking Product

London, 18th November 2019

1967

First world ATM in

London.

2

1980s

Introduction of online

banking services.

1999

Beginning of mobile

banking.

2018

Open Banking APIs

8

C u s t o m e r

a d o p t i o n

T P P

f u n n e l

B a n k s

p r e s e n c e

O p e n B a n k i n g s t a t e o f p l a y | S e p t e m b e r 2 0 1 9

1.45%

+49M

61 | 50

290

Open Banking adoption rate TPPs with an App offering

TPPs with a prototype

Digitally active customers across the CMA9 Banks

TPPs applied for Open Banking

26

79

Banks active in Production

Total non-CMA9 Banks in Open Banking

9

Estimated UK’s Open Banking-

enabled services opportunities annual

value*

£18 billion

Global eWallet payments

estimated in 2018

Forecasted to grow up to

47% by 2022 **

36%UK smart phone penetration

rate by 2016 †

81%

Third party providers currently

in the process of registration

290

(**) Source Worldpay: Global Payments Report Digital 2018 (†) https://www.deloitte.co.uk/mobileuk/assets/pdf/Deloitte-Mobile-Consumer-2016-There-is-no-place-like-phone.pdf

(*) Consumer Priorities for Open Banking: Faith Reynolds & Mark Chidley

K e e p i n g m o m e n t u m

10

Open Finance

Open

Savings &

Investments

Funds

Trading &

Settlement

Electronic transfer

of Assets

Pensions

Dashboard

Digital ID Open

Banking

££

▪ Technology leverage

▪ Security framework

▪ Trusted ecosystem

▪ Collaboration spirit

Change

Management

Foundations

Scope maturity

Costs

▪ Technology pace is faster than public’s

appetite to adopt new features

▪ Consolidated use cases available

through TPPs

▪ As-Is Ecosystem implications and

transition to new dynamics

▪ Coexistence with parallel regulation

▪ Functionality and specifications

definition aligned with attractive use

cases for the ecosystem

▪ Realistic roadmap: fit for purpose

delivery

▪ High investment commitment

▪ Challenging financial/resource

requirements for smaller

participants

▪ Sustainable investment

Open

Finance

11

U K ’s O p e n B a n k i n g i m p l e m e n t a t i o n l e s s o n s l e a r n e d

Our purpose is to help people

and business prosper.

Our culture is based on believing

that everything we do should be:

Thank You.

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Impact of Open FinanceAdvisers, Providers and Business Models David Dalton-Brown, Chief Executive Officer, TISA

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Content

• Industry Models – past evolution of consumer engagement

• Industry Models – future evolution of consumer engagement

• Some case studies of future consumer engagement models

• Winners and losers

• Next steps for your business

Past evolution of consumer engagement

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Pre-2000 – before the emergence of online platforms

Consumer✓ Consumer has direct relationship with product providers✓ Providers manage the consumer relationship✓ Consumer makes phone / postal request for data✓ Data provided in company specific, paper report✓ Consumer has to prepare own consolidation of data✓ Transactions by paper and cheques taking weeks to complete

Product Provider - ISA


Product Provider - Pension


Product Provider - GIA

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Pre-2000 – before the emergence of online platforms

Consumer

✓ Consumers with an adviser (only 8% of consumers) instruct an adviser to collect their product data – letter of authority

✓ Data provided to adviser in company specific, paper report

✓ Adviser has to prepare own consolidation of data (some limited back office support)

✓ Transactions by paper and cheques taking weeks to complete


Adviser

Product Provider -

Investments




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Post-2000 – The emergence of online platforms

Consumer

✓ Platforms consolidate consumers product holdings

✓ Data provided to consumers and adviser in common digital format

✓ Platforms provide product wrappers, open architecture fund solutions, modelling tools etc.

✓ Transactions are online and asset transfers (in wrapper) in-specie by paper and cheques taking weeks to complete


Online Platform

Product Provider -

Investments




Adviser

…

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Post-2005 – Online platforms become the norm

Consumer

• Platform consolidates assets into its own ISA, GIA and Pension Wrappers

• Traditional non-platform, product providers are removed from market through consolidation by platform

• Fund managers are disintermediated from the consumer (Via Platform D2C or Adviser Relationship)


Online Platform

Product Provider -

Investments

Product Provider -Pension



Adviser

X X X X X…

Platform Wrappers – ISA, GIA, Pensions, Bonds,

Open Architecture Funds, Equities, Cash

Adviser Back-Office Providers

Future evolution of consumer engagement

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Open Finance – Stage 1 – Evolving central consolidation model

Consumer• Platforms provide full picture

of consumers on and off platform assets and debt

• Consumer gets full picture of their financial position

• Advisers are able to provide improved / complete services at lower cost

• Off platform providers are further disintermediated by platforms – further loss of consumer contact

• Platforms extend the services and product offeringsBanks – for

cash holdings

Online Platform

Off Platform Pensions

Off Platform Investments

Lenders –Secured /

Unsecured Debt

Adviser

…

Platform Wrappers – ISA, GIA, Pensions, Bonds

Open Architecture funds, Equities, Cash

Open Finance Standards / APIs

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Open Finance – Stage 2 – Emerging / potential models

Some potential examples:

• Existing Fintech personal finance providers (Moneybox, Money Dashboard…) and online banks (Monzo..) embrace Open Finance to provide personalized financial consolidation services coupled with simple guides to managing personal finances.

• Leading advisers embrace Open Finance to build personalised consolidation services for their client base and then partner with wrapper providers and institutional trading services to provide an adviser own platform service.

• Back office providers (Intelliflo…) embrace Open Finance and provide complete consolidation platform service to advisers and consumers.

• Next generation Fintech emerges that offers complete consumer and adviser consolidation services replacing existing centralized platform providers.

• Existing traditional product and investment providers adopt Open Finance to develop new retail consumer services – they push back against disintermediation.

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Stage 2 - Fintech provider – virtual platform/aggregated holdings

Web SiteVirtual platform –

aggregating all assets together and

transacting via Central client bank account

Asset Provider 1

Existing Platform Providers

Pension Provider

Term Deposit

With Profits Fund

Asset 1

Asset 2Consumer

Gives consent to trusted partner to collect all their financial holdings

• Aggregated holdings• Transactional information• Performance• Transact via Open Finance

APIs

Bank Account

ISA Provider

Asset X

Asset Y

Open Banking

API

Standard OSI API to Asset

Providers

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Open Finance Stage 3 – The emergence of the consumer led market UBERisation of Retail Financial Services

Trusted Open Finance Partner

Consolidated view of existingAssets & Debts

Risk profile

Consumer Health & Wealth Goals

ExistingProvider

Existing Provider

Existing Provider

Consumer

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Open Finance Provider 1



Open Finance Provider ?

✓ These are my Goals✓ These are my Assets✓ These are my Debts• Meet my Goals?



Risk profile


ExistingProvider

Existing Provider

Existing Provider

Consumer

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Open Finance Provider ?

✓ These are my Goals✓ These are my Assets✓ These are my Debts• Meet my Goals?



Risk profile


ExistingProvider

Existing Provider

Existing Provider

Consumer

Potential Impact of Open Finance on Advisers, Provider and Current Business Models

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Open Finance – arrival of new personalised consolidation servicesHow could business models of centralised platform consolidators evolve?

Consumer

Banks – for cash holdings

Online Platform

Off Platform Pensions

Off Platform Investments

Lenders –Secured /

Unsecured Debt

Adviser

…

Platform Wrappers – ISA, GIA, Pensions, Bonds,

Open Architecture funds, Equities, Cash

Open Finance Standards / API

?

• Platforms further focus on improved services to advisers –retain the advice relationship

• Platforms develop white label solutions for advisers

• Platforms launch next generation retail personalised consolidation service and provide introductions to advisers / introduce their own advice and guidance services

• Platforms embrace full range of Open Standard and APIs and become service providers for all traditional providers….

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Open Finance - Some options for current product & investment providers

• Embrace Open Finance – partner with platforms who have adopted Open Finance

• Leverage platforms investment in Open Finance

• Consolidate all legacy holdings with platform partner

• Accept that business in now an institutional / disintermediated provider

• Embrace Open Finance - bypass the platforms

• Establish new consumer / adviser engagement model

• Design products to support Open Finance

• Evolve Distribution and Administration Systems to include use of Standards / APIs

• Maintain current model and acknowledge potential impact – further disintermediation

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Open Finance - Some potential options for advisers

• Embrace Open Finance – partner with platforms who have adopted Open Finance

• Leverage platforms investment in Open Finance

• Consolidate all holdings of existing clients with platform partner

• Develop advice model to cover all consumers life goals

• Embrace Open Finance - bypass the platforms

• Partner with Open Finance Fintech developer

• Partner with back-office provider who has embraced Open Finance

• Adopt a white label Open Finance solution

• Develop advice model to cover all consumers life goals

• Maintain current model and acknowledge potential impact

Winners and losers

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Open Finance – Potential winners and losers

• Winners:

1. Those closest to the consumer have the best range of proposition options and ability to optimise ROI

2. Having consumer financial well-being at the centre of your proposition planning will keep your business relevant

3. Embracing Open Finance provides the foundations for staying close to the consumer and for understanding consumers financial well being needs

4. Those prepared to disrupt their business models – Open Finance is a disruptive development

• Losers:

1. Those not above

Next steps for your business

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Next Steps

• Remember Open Finance could be mandated by government / regulators – Open Banking and Pension Dashboard are already mandated

• Consider / assess strategic options – be in a leadership position through knowledge

• Speak to your customers – understand their views on digital engagement – how does Open Finance support your customers needs

• Engage with industry projects (Open Banking, Open Savings & Investment and Pension Dashboard ) to help shape industry development of Open Finance

• Consider partnership opportunities that support your digital consumer engagement model

• Consider the digital customer propositions that support your engagement model

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TISA’s Open Savings and Investment Project includes participants from all areas of the Financial Services Community

TISA are extending the current steering committee – to a maximum of 20 member firms

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THANK YOU

www.tisa.uk.com

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Opportunities for consumer – the consumer perspectiveHarry Weber-Brown, Digital Innovation Director, TISA

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What is it?

Open Finance refers to the potential for financial services providers to enable consumers to better manage their money and access the right products and services at the right time.

It enables consumers to own and control their data, in an environment that provides for safe and ethical re- use by other financial services providers and with informed consent.

Background

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Background

The UK population is not saving enough:

14.4 million working age adults in Britain are not saving at all and 26.5 million working age adults in Britain do not hold adequate asset balances in either rainy day or pension savings.

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Background



One in seven UK pensioners currently living in poverty.

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Background



One in seven UK pensioners currently living in poverty.

Low levels of liquid assets is also associated with poor psychological wellbeing

(The Social Market Foundation, August 2017)

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The current situation

When households do save, they are not making the most of their money:

70% people in Britain hold no medium to long-term assets

6.8 million people hold more money in cash assets than they require to cover their rainy day needs

£200billion held in held in cash accounts in excess to rainy day

(Source: The Social Market Foundation, August 2017)

Opportunities for consumer

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Opportunity

• It is not just the amount of saving that households undertake, there is a a critical issue with the behaviour of those who save, which is a bias for “riskless”.

• Some 85% of savers say that rates of return (interest rates) is an important factor in making savings and investment decisions

• Providing an aggregated view of assets and liabilities allows savers to view and plan their financial position across their immediate needs, rainy day funds and longer term saving for retirement.

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Case Study – Quicken Loans Application

1) Quicken Loans turned the US mortgage industry on its head with the introduction of Rocket Mortgage, an online mortgage application that takes less than 10 minutes to complete, in November 2015

a) The goal was to allow a person to get a mortgage or re-mortgage their home while standing in line for a cup of coffee.

b) Its product simplified the mortgage process by offering a clean and quick online application form, allowing online information verification, and providing conditional preapproval within minutes.

c) In 2017, Quicken became the largest US residential mortgage provider by volume, surpassing Wells Fargo

2) The company leverages technology to retrieve information real time through secure API’s from:

a) Financial institutions (banks, platforms etc) to confirm assets

b) Credit agencies to confirm status

c) Employers to confirm both employment status and income

d) Real estate data on the intended purchase/remortgage

3) This allows the application to provide an instant mortgage if the consumer pass the eligibility criteria as traditional mortgage providers, but without the need for the consumer to provide all the physical evidence

Apply Declaration Check Approved Choose

Consumer Vision + Proposition

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TISA project: Open Savings & Investments

Open Savings and Investments will provide a common set of open standards and APIs to allow customers to share their data between firms.

It will be the fundamental building block to achieve the future digital marketplace for financial services.

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What is the user need (Pension Dashboard)

High level user need

“I need to know how much money I’ll have to live on when I retire so that I can plan for my future”.

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What is the user need (Pension Dashboard)

Additional user needs

“I need to know that the information will be displayed in a clear and easy to understand way, as I am already confused by current pension information and this may put me off from logging on”.

“I need to know that the service is secure and that my information is safe and protected so that I am reassured other people cannot see and access my financial information”.

“I need to know that I am accessing the correct service provided by one impartial and reliable source so that I’m reassured I can trust the guidance and information I am given”.

Benefits

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What value can Open Finance deliver to the consumer

Remove the perceived and/or actual difficulty in managing multiple financial products across different providers that results in low levels of customer engagement.

Opportunity for consumers to reduce the time and effort required to manage their finance

Opportunity to enable consumers to make better informed decisions based on having a single view of their full financial position in a single place.

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What value can Open Finance deliver to the consumer

Remove the perceived and/or actual difficulty in managing multiple financial products across different providers that results in low levels of customer engagement.

Opportunity for consumers to reduce the time and effort required to manage their finance

Opportunity to enable consumers to make better informed decisions based on having a single view of their full financial position in a single place.

Ability to easily compare the returns on money and make decisions - move money at the appropriate time

Assist consumers and advisors with the completion of various forms or returns (e.g. tax return, mortgage application).

Enable improved access to advice and guidance and to help consumers to make better financial decisions

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Consumer Benefits

• At the consumer level benefits come in many forms; however the key benefit is in allowing them to have complete pictures of their overall wealth .

Category Benefit

Consumer Engagement Simplification of experience

Consumer Engagement Ownership of personal data.

Consumer Engagement Facilitates more effective financial planning - both self-directed and

advised

Improved customer

decisions

Auto prompts to clients. E.g. would you like to invest your bonus

payment?

Costs & Efficiency Reduction in costs due to competitive pressure in the market

Consumer Education Better education personalised on total asset holdings

Service Propositions

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Possible services built on Open APIs (Savings and Investments)

• Wealth Dashboard – virtual platform

• Tax Optimisation

• Portfolio risk review

• Support for Life events (planned and unplanned)

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What a Dashboard Could look like

John SmithOverview

John SmithSavings and Investments

John SmithDebt

Cash ISA

GIA Pension

Mortgage Fixed Loans

Variable loan

Net Position£134,000

Total £297,000 Total £163,000

Fidelity ISA Multi Asset

£24,000

Fixed rate Mortgage

£150,000

Cash

£18,000

Cirilium Multi Asset Fund

£5,000

Vantage Growth SIPP

£250,000

Fixed Loan

£10,000

Partnership Card

£3,000

Consumer obstacles and how to mitigate

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Obstacles

• Consumers cautious about sharing data unless services are credible and trustworthy

• Consumer apathy and lack of awareness of the value of services delivered using Open Finance

• Regulation is still designed for old world and not data rich, so relying on technology driven solutions.

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EY Open Banking Opportunity Index

Source: EY Open Banking Opportunity Index, 2018

Trust Models TRUST CONCEPT QUESTION KEY FACTORS TO HELP BUILD TRUST

Security Is there protection to ensure the security of any information being shared?

• Standards• Oversight and enforcement

Integrity Is there a set of values or behaviours, will all parties stick to them, and do the right thing even if costs them

• Legal contracts• Dispute resolution services• Codes of Conduct• Trustmarks and registers

Credibility Does the other party have the necessary ability, competence, technical knowledge?

• Licensing, certification and accreditation• Trustmarks• Oversight and enforcement

Clarity Is what is being provided and what is expected clear and transparent?

• Education and awareness raising• Trustmarks and registers

Reliability Is it consistent? Will it do what they say it will do?

• Standards• Legal contracts and SLAs agreed between participating

firms• Licensing, certification and accreditation

Privacy Is there a suitable level of protection to ensure that data privacy rights will not be compromised?

• Legal• Codes of conduct• Oversight and enforcement

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Trust Marks

The shield is a common theme and conveys security and trust

The finger print is a modern and recognizable way to convey accessing your digital identity

A single trustmark across sectors and products is probablydesirable

Users do need some way to understand where they can use gather and aggregate their personal data using the Open Finance scheme: trustmark may convey this.

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Digital Identity

Federated Identity

Finance sector

Health

Government

Travel

Entertainment

Education A variety of access points and proliferation of Open Finance services requiring ID authentication to synthesise the services and experience.

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Adoption

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Rising Speed of Technological Adoption

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Day 1 - Scope Management• For day 1 we have defined a scope that is a Minimum Viable Proposition but also

establishes and tests the legal and governance model

Day 1Delivery

Valuations(basic, withdrawal, …)

Transaction Info(Income, dividends, equalisation, buys , sells , switches, transfers,…)

Transactional Instructions(Buy, Sell, Switch, move, …)

Funds, ETFsITs, Equities, ISA, GIA

Insurance plans, Investment Bonds, Pensions

Cash Deposits

Structured products, Loans

API Complexity

Assets /Wrappers covered

The way ahead

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Vision for the future

Develop a range of Digital tools and services to help consumers understand their financial situation and make better better financial decisions.

Shape public policy to ensure Open Finance creates positive disruption and the appropriate flows of capital allocation in markets that optimise financial outcomes for the consumer.

Promote this through direct to consumer communications such as value propositions, weaved into education, guidance and advice to provide better financial wellbeing for all.

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THANK YOU

www.tisa.uk.com

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Adam Byford, Distribution Director, Anorak Technologies

The new standard in protection sales

A software platform enabling any financial services company

to offer life insurance advice and products to their customers -

at scale

HELLO, WE ARE ANORAK

anorakBritish, informal: A person who is extremely

enthusiastic about and interested in

something that other people find boring.

Like life insurance.

HELLO, WE ARE ANORAK

An award-winning protectiontech company backed by AXA

Top 5 hottest fintech company in the world

Business Insider 2019

Most Innovative Life Insurance Firm

Life Insurance International Innovation Awards 2018

# 1 UK Insurtech

By Insurance Post and Tallt Ventures

£9M invested

As seen in: Cover Magazine – FT Adviser – Life Insurance International – Techworld – TechCrunch

Why do we exist

⅓ of families have no savings14 homes repossessed every day235 Landlord possession orders issued per day9m have no Life Insurance50% of mortgages aren’t protected97% of Self Employed have no income protection

WHY WE ARE HERE5

As an industry we are not providing the protection that people need

OUR FOCUS IS ON THE CUSTOMER6

We feel that the industry has lost sight of the customer wants and

needs

THERE IS TOO MUCH FOCUS ON PRODUCTS7

How many times do you hear people saying that they wish there

were more features on a product or that the definition of Devic’s

Disease is amended?

The way people expect to buy protection has changed – for good

CUSTOMER BEHAVIOUR HAS CHANGED FASTER THAN THE MARKET HAS8

Omnichannel access Instant solutions Expert help Data transparency

An online-first service, easy to

access on mobile, desktop,

chat or phone

A personalised experience,

plus an instant and situation-

specific outcome

Both automated expertise and

human help to support

informed decision-making

Fair value exchange, plus

transparent and minimal use

of personal user data

UNINTENDED CONSEQUENCES19

THE REASON WHY PEOPLE NEED PROTECTION HASN’T CHANGED10

New home New baby Death or illness

New job Marriage Divorce

What are we doing about it?

THE FUTURE OF PROTECTION

End customersGet needs-based advice and the right protection for them

Advisers Drive more sales and efficiency, with compliance and due care

This is not about Robo Vs Human It’s about building a scalable new

business channel that delivers better customer outcomes

12

100% proprietary technology stack

Data from partner integration

MACHINE LEARNING

DELIVERYOUTPUTCOMPUTATION (ANORAK ENGINE) INPUT

APIs

Customer platform

User profiling

Insurance

modelling

Risk analysis

User input

Open data

Quote APIs

Behavioral data

platform & APIs

Financialplanning

Protection recommendations

Personalised

Compliant

Instant

Adviser platform

13

OUR TECHNOLOGY14

Anorak advice engine

Customer platform Adviser platform APIs

● Lifetime risk exposure and needs analysis

● Coverage gap analysis

● Multi-scenario computation

● Optimal coverage computation

● Market-available product outcomes

● ML-trained predictive quoting

● Deep semantic data modelling

● Dynamic product suitability analysis

● Reverse engineering of whole-of-market

protection products

● ML-trained predictive quoting

Insurance modelling

● Multiple data sources – e.g. bank

transactions, risk data and open data

● Open-banking used to profile and monitor

users

● Actuarial and risk data integration – e.g.

mortality, morbidity and incidence rates

● CRM system integration for automated

protection fact-find

AI-based user profiling Financial planning & risk analysis

Who do we work with?

PROTECTION DISTRIBUTION

With technology, it’s anyone’s game

Create the opportunity

● Employee Benefit Consultants

● Online money services

● Affinity brands

● Anyone good at helping people online

Seize the opportunity

● Insurers

● Banks and Lenders

● Price comparison websites

● Mortgage advisers

● Financial advisers

16

EARLY ADOPTER PARTNERSHIPS

● Mortgage data creates report

● Anorak email client

● Client view

● Call trigger from client action

● L&C use adviser view

● Adviser support provided on

telephone (L&C)

● Anorak provide Nutmeg with content

for emails and blogs

● Nutmeg have incorporated a Life

Insurance section into their financial

report

● Clients are passed to Anorak without

data


telephone (Albany Park)

● Digital marketplace

● Exchange of bank data

● 2-way trust model

● Opportunity to review on ongoing

basis


telephone (Albany Park)

17

Reinventing Bancassurance 3.0 for life insurance● In App Marketplace - personal and sole trader

● 2 Way data trust model established

● 1 time sign on process

● Customer profile created based on bank data and customer input

18 Bancassurance 3.0

19 IP PROMOTED THROUGH THE NEW SME MARKETPLACE

20 STARLING CUSTOMER ARRIVES AT THE SAME LANDING PAGE BUT WITH SOME QUESTIONS ANSWERED BY THE BANK DATA

21 BANK DATA POPULATED JOURNEY

Bank Data Mortgage Data

Name 👍 👍

DOB 👍 👍

Sex 👎 👎

Partner Name 👍 👍

Partner DOB 👍 👍

Partner Sex 👎 👎

How many children 👎 👍

Age of children 👎 👍

Childcare Costs 👍 👍

School Fees 👍 👍

University Fees 👍 👍

Bank Data Mortgage Data

Smoker Status 👎 👎

Employment Status 👎 👍

Occupation 👎 👍

Benefits from Employer 👎 👍

Other Personal Cover 👎 👍

Savings 👎 👎

Expenses 👍 👍

Property Ownership 👎 👍

Mortgage Amount 👍 👍

Rent Amount 👍 👍

22 Expenses Analysis

● Bills and Subscriptions

● Communications

● Energy

Electricity

Gas

Household

● Groceries

Alcohol, tobacco & Narcotics

Food and non-alcoholic drinks

● Insurance

● Other

Essential

Non-Essential

● Recreation and Culture

● Holiday

● Other holiday expenses

Other recreational activities

● Eating and drinking out

● Clothing

● Transport

Any questions?

July 2019

THANK YOU

Adam Byford

Distribution Director

+44 7539 167874

[email protected]

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John Salmon, Partner, Hogan Lovells

John Salmon

The legal issues

Open Finance

| 96Hogan Lovells

• Compulsion vs non-compulsion

– Pros & cons

– Key legal issues

• Comparison between mandatory and voluntary contractual framework by reference to examples

• Secure access and communication

• Privacy

• Liability

• Authorisation and due diligence

Overview

Hogan Lovells

• Compulsion

– Mandatory framework

– Using mandatory open banking regimes in the UK and EU, namely Open Banking and PSD2, as a reference point

• Non-compulsion

– Contractual framework

– Such as the Open Savings & Investments (OS&I)

• What can we learn from:

– Open Banking

– Voluntary frameworks like TeX

Compulsion vs non-compulsion

Hogan Lovells

Pros & cons

Compulsion Non-compulsion

Pros • Clear uniform framework• Regulatory compulsion and

consequences

• Industry has control• Much more flexible to change

Cons • May not be so clear• Difficult to alter

• May not have uniformimplementation

• Voluntary nature

Hogan Lovells

Different approaches to Open Banking

Ismail Chaib (November 2018), 'Regulating Open Banking - How regulators around the world are shaping the future of financial services', Open Bank Project.

Hogan Lovells

Key legal issues

Compulsion Non-compulsion

• Coherent standard framework• Ensuring technology neutrality vs

certainty• Privacy issues can be subsumed• Liability model can be provided• Authorisation/regulatory models for

access – mandatory access?• Withdrawal of access set out clearly • Dispute resolution and customer redress

mechanism

• Possibly different contractual models• Standard technology approaches that

can be adapted as necessary• Privacy concerns• Difficulties of agreeing liability model• Difficulties of managing access issues for

third parties – authorisation?• Difficulties of management withdrawal

of access• Agreed dispute resolution process

PSD2/Open Banking Model

Compulsion

Hogan Lovells

Where does responsibility

begin and end?

Intellectual Property

Governance Issues

Regulation

PSD2 vs Open Banking

Open BankingCMA

• 9 mandated banks• PCA/BCA accounts only• Open API interface• Implementation Entity

with an Independent Trustee

CMA & PSD2• GBP payments• Payment Initiation

services• Transaction History

services• Explicit consent

PSD2• All payment service providers

(PSPs)• Non-prescriptive dedicated

interface• Multi-currency• Strong Customer

Authentication• All payment accounts

Open Banking PSD2 Scope

PSD2 Scope

Hogan Lovells

Compulsion – PSD2/Open Banking Model

PISP AISP

Payment initiation service

Account information service

ASPSP (Bank)

PSU(Customer)

Hogan Lovells

Consent and privacy (1/2)

PISP AISP

ASPSP (Bank)

PSU(Customer)

Grounds for processing




Explicit consent

Fair collection notice


Hogan Lovells

• Key Issues

– Explicit consent under PSD2 is “contractual consent”

– Under GDPR means any freely given, specific, informed, unambiguous – clear affirmative action

– Grounds for processing

– necessary for the performance of a contact

– Legitimate interests – silent party data

Consent and privacy (2/2)

Hogan Lovells

Secure communications (1/2)

PISP AISP

ASPSP (Bank)

PSU(Customer)

Strong customer authentication

Identification of PISP and AISPSecure

communications Secure

communications

Hogan Lovells

• Key Issues

– Use of EiDAS Certificates

– Secure communications between the parties

– Strong customer authentication – demands 2 factor

Secure communications (2/2)

Hogan Lovells

Liability (1/2)

PISP AISP

ASPSP (Bank)

PSU(Customer)

Refund to customer for unauthorised

transactions

Liability for unauthorised transactions

Liability for fraudand gross negligence

Liability for unauthorised transactions

Hogan Lovells

• Key Issues

– Liability model is limited

– Unauthorised transactions only

– Difficult to see relevance to AISP model

– Interaction with GDPR

Liability (2/2)

Hogan Lovells

Authorisation, due diligence and access (1/2)

PISP AISP

ASPSP (Bank)

PSU(Customer)

Must allow access to payment accountsMust be

authorisedMust be registered

Hogan Lovells

• Key Issues

– Mandatory access for regulated TPPs

– No due diligence permitted

– No contracts permitted

– Cannot refuse access unless justified reasons

Authorisation, due diligence and access (2/2)

Contractual Model

Non-compulsion

Hogan Lovells

Savings and Investment – Current Situation

Data provider Data consumer

Customer

Financial service product providers

hold the data

Individual unique contract for every

relationship

App provider/firm requests the data

Hogan Lovells

New contractual framework (Open Savings & Investment)


Customer

OS&I

Data sharing agreement

Sign up to OS&I Sign up to OS&I

Standard documentation provided by OS&I issued by Data Consumer to Customer

Hogan Lovells

Consent and privacy


Customer

OS&I




Hogan Lovells

Secure communications


Customer

OS&I

Customer authentication

Secure communications

Hogan Lovells

Liability

Agreed liability model


Customer

OS&I

Hogan Lovells

Authorisation and due diligence

Regulatory status of data consumer


Customer

OS&I

Hogan Lovells

• Key legal issues to be resolved

– Privacy

– Secure access

– Liability model

• Key advantages of industry led approach

Conclusions

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as partners, but who are not members of Hogan Lovells International LLP, do not hold qualifications equivalent to members.

For more information about Hogan Lovells, the partners and their qualifications, see www.hoganlovells.com.

Where case studies are included, results achieved do not guarantee similar outcomes for other clients. Attorney advertising. Images of people may feature current or former lawyers and employees at Hogan Lovells or models not

connected with the firm.

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