Consultation outcome

Consultation paper on draft innovation plan for financial services

Published 22 April 2016

This was published under the 2015 to 2016 Cameron Conservative government

1. Background

The government announced in its Productivity Plan 2015 that departments will be required to work with regulators to publish innovation plans by spring 2016. This announcement reflects the key government aim to ensure the UK is supporting the development of new business models and disruptive technologies, breaking down barriers to entry and boosting productivity. To do this the UK’s regulation and enforcement frameworks must be agile enough to respond flexibly to continuing developments in new technologies and disruptive business models.

The purpose of this consultation is to set out ongoing and proposed work to foster a supportive regulatory framework for financial services that allows innovation to flourish.

The innovation plan covers the work of the financial services regulators: Financial Conduct Authority (FCA), Payment Systems Regulator (PSR), Prudential Regulation Authority (PRA) and the wider Bank of England.

The innovation plan covers three key issues:

• How new technology is shaping financial services
• How financial services regulators are adapting to new technologies and disruptive business models to encourage growth
• How financial services regulators are better utilising new technologies to generate efficiency savings and reduce burdens on business

This consultation invites comment on the work of financial services regulators to support innovative technology and disruptive business models. We would also like to understand where there might be gaps in regulatory approach when it comes to supporting innovation.

2. Draft innovation plan for financial services

2.1 Innovation and regulation

The government’s vision is for UK financial services to be the most competitive and innovative in the world, delivering greater choice and value for consumers.

The government has already taken significant action to reach this vision. This includes:

• Working with regulators to substantially lower barriers to entry by making it quicker and easier for new, innovative firms to enter the market
• Committing to develop an open banking standard for application programming interfaces (APIs). An open banking standard will create an ecosystem that allows financial technology (fintech) firms to use customers’ financial data in innovative ways to provide a range of value-added services to consumers. This will allow consumers to make better use of their financial data, and more easily compare and assess financial products and services
• Legislating to require the big banks to share SME credit data so alternative finance providers, including fintechs, are more able to compete and make effective lending decisions
• Delivering and driving improvements in the Current Account Switch Service (CASS) and midata, so customers can compare personal current accounts and switch where they see a better deal – simply, quickly and reliably. Consumers have switched over 2.8 million times since CASS was launched in 2013

Creating the right regulatory environment is particularly important to ensure that innovative firms can compete and grow. To this end, HM Treasury has firmly embedded competition and innovation objectives in the regulatory landscape for financial services through the main regulators’ objectives and remits.

The FCA has a duty to promote effective competition, so far as that is compatible with its consumer protection or market integrity objectives. It also has an operational objective to promote effective competition in the interests of consumers in the markets it regulates.

The PSR is an independent subsidiary of the FCA, and has a specific objective to promote innovation in the UK payments sector. This complements its two other objectives to promote effective competition in the markets for payment systems and associated services, and to promote the interests of actual or likely users of services provided by payment systems. The PSR has strong powers over the main interbank and international card schemes to promote these objectives.

The PRA is a subsidiary of the Bank of England and has a secondary competition objective to act, as far as is reasonably possible, to facilitate effective competition in the markets it regulates when discharging its functions in a way that advances safety and soundness and insurance policyholder protection.

The FCA, PRA and PSR will produce annual reports on how they are delivering against their respective competition objectives.

2.2 How new technology is shaping financial services

A key focus of innovation in financial services in recent years is the growth of fintech – technology solutions which deliver financial services, often in a more efficient and customer-focused way. For example, technology has enabled:

• consumers to make payments via their smartphones
• the matching of consumers and businesses with money to save and invest with those who need to borrow
• personal insurance pricing based on the characteristics and behaviours of individual consumers
• the development of new digital currencies

The financial services sector is characterised by both new disruptive players and fintechs working with incumbents to deliver more innovative products and services through existing networks and infrastructure.

The fintech sector is diverse: from small dynamic start-ups to more established players. Fintechs operate in many areas of financial services – for example, payments, peer-to-peer lending, big data analytics and robo-advice – and the potential for technology to transform financial services is substantial. 25% of all fintechs globally are in the retail payments industry^{[footnote 1]}.

The UK is the world-leader in fintech. An independent report from Ernst and Young (EY) published in February ranked the UK as the leading fintech centre in the world – ahead of other leading hubs like Silicon Valley, New York and Hong Kong.

The UK’s fintech sector has been growing rapidly. In 2015, fintech investment in the UK and Ireland grew 28% to £524 million. In 2014, investment in UK fintech accounted for almost half of all European fintech investment and we expect this trend to continue. The UK fintech sector also contributed £20 billion to GDP in 2015 and employed 61,000 people^{[footnote 2]}.

2.3 How financial services regulators are adapting to new technologies and disruptive business models to encourage growth

This section outlines how each financial services regulator plans to support and promote innovation, facilitating the development of new technologies and disruptive business models in financial services.

The government’s priority is to ensure that regulation is proportionate and promotes innovation, rather than constrains or inhibits it. Indeed there are likely to be some areas of existing regulation, developed long before digital and technological advances, which may now be acting as a barrier to innovation.

2.4 Financial Conduct Authority (FCA)

Project Innovate

The FCA launched Project Innovate in October 2014 to help encourage and support innovation in financial services. This work is central to delivering against the FCA’s competition objective – it aims to encourage innovation in the interests of consumers, and promote competition through disruptive innovation that offers new services to customers and challenges existing business models.

The FCA is working to engage more constructively with innovative firms – from smaller start-ups to mass market new models – and seeks to remove unnecessary barriers to innovation.

It helps innovative firms gain access to fast and frank feedback on the regulatory implications of their concepts, plans and choices. It also seeks to tackle the structural issues that impede the progress of innovators entering the market.

Part of Project Innovate is the Innovation Hub which helps new and established businesses (both regulated and non-regulated) introduce innovative financial products and services to the market. The Innovation Hub also identifies areas where the regulatory framework needs to adapt to enable further innovation in the interests of consumers.

To date, Project Innovate has helped over 250 firms, 18 of which have been authorised to undertake regulated activities. It provides an end-to-end experience for new entrants. Firms that receive initial support from the Innovation Hub have their applications for authorisation handled via a specialised Project Innovate authorisation process.

The FCA provides firms with dedicated supervisory support, usually for one year post-authorisation, which gives firms a seamless regulatory experience and minimises the risk of unnecessary delay.

As well as directly supporting firms, the FCA has introduced broader changes to help innovators. This includes:

• working with government on its plans to introduce anti-money laundering regulation for digital currency exchanges, to provide a supportive environment for legitimate digital currency users and businesses, and create a hostile environment for illicit users
• making a statement looking at the extent of the issue of disproportionate de-risking, which denies businesses access to banking facilities, and how the FCA might influence firms to take a more proportionate approach
• using informal steers on proposed innovations to enable more direct communication with firms

Going forward the FCA plans to broaden and strengthen the scope of Project Innovate, to continue to deliver against its competition objective and further support innovative firms. This includes enhancing international engagement.

The UK attracts fintech innovators from around the world – many choose to base themselves in the UK, not only to be part of a vibrant local ecosystem, but also because they see the UK as a springboard to launch their businesses or products internationally and bolster their competitiveness.

As part of this work the FCA:

• Helps put UK-based innovators in touch with the right regulators when they look to start doing business in other regulatory jurisdictions
• Stand ready to help non-UK innovators interested in entering the UK market
• Seeks co-operation agreements with key regulators. For example, the FCA recently signed a world-first Co-operation Agreement with the Australian regulator, ASIC, to facilitate the referral of innovative firms between their respective innovation hubs
• Promotes pro-innovation regulatory solutions to international standard-setters

The FCA also intends to broaden engagement with large incumbent institutions. To facilitate increased dialogue the FCA plans to proactively engage with large incumbents to ensure their potential for consumer-friendly innovation is not being held back by regulatory considerations. In particular, it will seek out opportunities to pilot research on new initiatives.

Following the Financial Advice Market Review (FAMR), the FCA is taking forward the recommendation to build on the success of Project Innovate by setting up an advice unit to support firms developing automated advice models that aim to deliver low-cost, high-quality advice to consumers who do not have significant wealth or income. The advice unit will focus on advice models in the investment advice, protection and retirement income sectors.

Other initiatives to support competition and innovation

More broadly, the FCA has a number of other initiatives that aim to support competition and innovation.

In November 2015 the FCA published its plans to open a regulatory sandbox: a safe space where both regulated and unregulated firms can experiment with innovative products, services, business models and delivery mechanisms without immediately incurring all the normal regulatory consequences of engaging in such activity.

Firms can start applying to the sandbox on 9 May 2015. The FCA also recommended that industry looks into establishing a virtual sandbox, which allows firms to experiment in a virtual environment using their own or publicly available data, and a sandbox umbrella company. Innovate Finance is leading a working group to explore these recommendations further.

Conventional consultation and engagement methods often do not work with innovative firms. Since September 2015 the FCA has facilitated a series of themed weeks, designed to stimulate intense engagement with stakeholders interested in a particular area of innovation.

The first of these events was on robo-advice (i.e. automated advice), which provided a valuable source of intelligence for the government’s FAMR. Themed weeks are an effective way of reaching a large number of firms simultaneously – to learn about their problems with the regulatory system, and dispel regulatory uncertainties and myths. The FCA is planning to hold a themed week on innovation in the payments sector, details of which will be released in the coming months.

Following engagement with cloud service providers and regulated firms, the FCA published draft guidance in November 2015 to clarify the requirements on firms when outsourcing to the cloud and other third-party IT services.

The guidance aims to dispel misconceptions about regulators’ opposition to the cloud and encourage innovation in this area.

The FCA published a Call for Input in June 2015 to understand the barriers to digital and mobile solutions for financial services, and specific rules and policies that should be introduced to facilitate innovation in this area. In March 2016 the FCA published a feedback statement which set out its roadmap to address the issues raised by market participants.

The FCA is working with firms to improve how they communicate with consumers and drive improvements in the effectiveness of the information consumers receive. The Smarter Consumer Communications initiative focuses on how information is presented to consumers.

It aims to encourage greater use of technology and behavioural insights to deliver communications that help people make effective decisions about products and services. The FCA is committed to working with industry where an idea has strong potential to improve consumer outcomes; the FCA may consider waiving or modifying disclosure rules where appropriate to facilitate this testing.

It is also looking at amending its Handbook to remove a number of disclosure requirements that have not been as effective as initially envisaged in terms of providing appropriate information to consumers.

HM Treasury is working with the FCA to implement the revised Payment Services Directive (PSD2). PSD2 will introduce two new regulated payment services, allowing aggregators and payment initiators to access consumers’ account information. This has the potential to facilitate a step-change in the way consumers engage with financial services to view statements, budget and make payments.

Related to this, the FCA is also engaged with the Open Banking Working Group looking at the development of the open banking standard, which will help drive competition and innovation by creating an ecosystem to allow fintechs and other innovators to use banking data to provide a range of value-added services.

2.5 Payment Systems Regulator (PSR)

The government set up the PSR, which became operational in April 2015, ensuring that it had strong objectives to promote innovation and competition in the UK payments sector. In particular, the PSR seeks to ensure that all firms can access payment systems on fair and transparent terms, that governance arrangements are more inclusive and it is clear how, and by whom, decisions are being made.

Access to payment systems is an important driver of competition and innovation in the provision of payment services. Limited access has long been considered a barrier to entry for new banks, e-money issuers and other payments institutions, with the concern that the pace of innovation in this area is too slow.

The PSR’s Innovation and Horizon Scanning project is dedicated to understanding emerging innovative payment firms and technologies. This includes working with other regulators to ensure the regulatory landscape accommodates innovative business models and new technologies.

A main objective is to work proactively with small payments institutions and fintech firms to identify where the barriers to innovation exist, which feeds into the PSR’s policy development and implementation.

Innovation in payment systems can be driven either competitively, collaboratively, or a combination of the two. The PSR therefore aims to both remove barriers to competitive innovation and ensure that collaborative innovation delivers timely and efficient results for service users.

Competitive innovation

The PSR’s work in this area mostly focuses on lowering barriers to entry and ensuring that the market responds effectively to new technologies and business models. The PSR aims to give quicker and easier access to payment systems to a wider range of payment service providers, to increase competition and innovation which delivers better outcomes for consumers.

In particular, the PSR is working to improve the terms and availability of direct and indirect access to payment systems, which can involve issuing legally binding directions. Improving the ability of small and innovative firms to access payment systems means that these firms are able to compete more effectively with large incumbents.

As part of the work on improving direct and indirect access to payment systems, the PSR also issued general directions to improve the governance and transparency of payment systems in the interests of all users and participants.

Transparency ensures that payment systems are flexible to the requirements of innovative players. The PSR monitors compliance with these directions to ensure that payment systems’ access requirements and governance structures work well for innovative firms.

This includes publishing annual reports to assess each scheme’s compliance, which includes areas where the PSR expects to see improvements. The PSR will consider further regulatory action if improvements are not made.

To ensure that the market is operating in a way that supports competitive innovation, the PSR is conducting two market reviews:

• A market review into the supply of indirect access to payment systems is looking at the limited choice of sponsor banks, lack of information and whether competition is working well for service-users. The PSR may propose remedies to improve indirect access for payment service providers – thus supporting competition and innovation in these firms
• A market review into the ownership and competitiveness of infrastructure provision is considering whether competition is effective in the provision of infrastructure services in UK interbank payment systems and whether current provision delivers a good outcome for service-users. The PSR may propose remedies to improve the pace or quality of innovation in the infrastructure underpinning payment systems

The interim findings for both reviews were published in February and March before the final reports later this year. Depending on its findings, the PSR may implement remedies or undertake further policy work to support competitive innovation.

As well as the direct actions taken in the course of its regulatory duties, the launch of the PSR has prompted other industry players to innovate and take action to boost their own competitiveness. In particular, the Faster Payments Scheme (FPS) has started to develop new terms of access to its payment system which will enable a range of challenger banks and non-bank service providers to plug in directly to FPS through a number of fintech platforms.

Collaborative innovation

Innovation should be driven by competition, where possible. However, as payment systems rely on networks built across multiple parties, the PSR recognises that it is often necessary for those parties to collaborate to achieve the best outcomes. There are a number of examples of successful collaborative innovation in payments – for example, Faster Payments, Paym and the Current Account Switch Service (CASS).

Collaborative innovation, however, can be difficult to coordinate and sometimes individual firms have no strong incentive to work collaboratively to improve customer outcomes. To address this, the PSR established the Payments Strategy Forum to develop collaborative solutions for improving payment systems. Forum membership includes industry (banks, fintechs and other providers) and service-user representatives (consumers, retailers, SMEs, corporates and government).

Following engagement with the wider payments community, the Forum developed its initial set of priority areas. This includes:

• Greater control and assurance for end users
• Simplifying access to market for payment services providers
• An assessment of how industry can work to detect and reduce financial crime
• An assessment of the costs and benefits of account number portability

The Forum is due to publish its user-led, industry supported strategy in October 2016, with an expectation of further work in 2016 and 2017. The PSR holds industry to account for the success of the Forum and for the successful implementation of the strategy.

The PSR will review the effectiveness of the Forum after its first 12 months, taking into account industry and regulatory developments. The review will include an assessment of the extent to which the Forum has been able to achieve its objectives.

2.6 Prudential Regulation Authority (PRA)

Lowering barriers to entry and expansion

The PRA supports innovation primarily by ensuring that new banks are able to enter the market, many of which will have innovative and disruptive business models. It also seeks to address the proportionality of regulation for small banks, challenger banks and building societies.

Together with the FCA, the PRA has reduced barriers to entry that might arise from capital requirements for new banks. These now scale up more gradually as the bank becomes established. This means that the minimum amount of capital required by a new entrant bank is substantially lower than before.

The PRA and FCA also introduced a new mobilisation option, where a firm that has met the essential requirements is granted authorisation, but with restrictions on its activity while other requirements are met. This helps give prospective new banks some certainty while raising capital or investing in infrastructure.

Fourteen new banks have been authorised since the PRA’s creation in April 2013, several of these have highly innovative business models. For example, Atom Bank (authorised in June 2015) is an app-only bank where customers can only access services via their smartphones, and not through internet or telephone banking.

Tandem Bank (authorised in November 2015) is a digital-only retail bank that will operate a personal finance guide which compares financial products offered by both Tandem and its competitors. Other innovative banks are in the pipeline for authorisation.

To further help innovative firms come to market, the PRA and FCA established a New Bank Start-up Unit (NBSU) in January 2016 to help prospective new banks enter the market and through the early days of authorisation.

Comprising staff from both the PRA and FCA, the NBSU provides new banks with the information and materials they need to navigate the process to become a new bank, as well as a focused supervisory resource during the early years of authorisation.

Other initiatives to support new and innovative firms

More broadly, the PRA and the wider Bank of England are also engaging in a number of workstreams to support new and innovative firms:

• This year the PRA will introduce new prudential rules for credit unions that modernise the prudential framework
• The Bank of England and PRA are exploring potential opportunities to take a more proportionate approach to the application of pan-European rules, in particular for smaller firms. This includes discussing these issues with EU policy makers, including the European Commission, and considering the transition process for smaller banks and building societies to begin to use a model-based internal ratings based approach to credit risk

2.7 Bank of England

The Bank of England supports innovation in financial services through its work to promote innovative research and data analytics in central banking, and improving the ability of innovative firms to access Bank of England facilities. The Bank has also embraced new technology in the provision of UK banknotes.

Research and analytics

The Bank launched its One Bank Research Agenda initiative in February 2015 to try to understand and develop innovative best practice in central banking, taking into account technological, institutional, social and environmental change.

It aims to facilitate open dialogue between the Bank and the research community to support innovation and inform the Bank’s work. The Bank has set up a Research Hub division to help drive this forward and developed a new online blog, Bank Underground.

The initiative covers research questions on five broad themes: policy frameworks and interactions; evaluating regulation, resolution and market structures; policy operationalisation and implementation; new data, methodologies and approaches; and response to fundamental change.

In particular the fundamental change workstream takes a longer term look at how technological (and other) innovations might affect central banking over a longer horizon. This includes, for example, exploring the impact of digital currencies or alternative finance providers, and any associated economic, technological and regulatory challenges.

As part of its broader research agenda, the Bank publishes new datasets to facilitate external research. This includes long run historical data, the Bank of England’s balance sheet and data recorded by the Bank’s regional agents. The long-term plan is to open up even more of the Bank’s data to the public.

The Bank has also set up an advanced analytics division and data lab to exploit new and innovative analytical tools and techniques, analyse new data sources such as social media, and help spread best practice in the analysis of new big datasets both inside and outside the Bank.

The division is also developing relationships with external partners in this area, and recently ran a data visualisation competition to engage with data scientists and students across the UK.

In the payments space, the Bank is conducting research into innovations in payments technology, with a particular focus on digital currencies and the distributed ledger systems that underpin them.

This builds on the Quarterly Bulletin articles published by the Bank in 2014, which considered the technical architecture of digital currencies, and the economic theories that govern how they work.

Polymer banknotes

Following extensive public consultation, the Bank announced in December 2013 that new Bank of England banknotes will now be printed on polymer. Polymer is a thin and flexible plastic material which has benefits over and above current paper banknotes.

Polymer notes are cleaner and more durable – they are more resistant to dirt and moisture, more environmentally friendly and last at least 2.5 times longer than paper banknotes. Polymer notes are also more secure, with advanced security features that provide a step-change in counterfeit resilience. The full design of the £5 note will be unveiled on 2 June and the banknote introduced in September 2016, with the £10 note issued in 2017, and £20 note by 2020.

Access to Bank of England facilities

The Bank’s reform of its Sterling Monetary Framework (SMF) has made it easier for small banks, challenger banks and building societies to access the Bank of England’s balance sheet at a lower cost and with greater predictability. Forty-one banks and building societies have been given access since the changes were introduced.

The Bank has broadened the range of collateral accepted in its market operations to now include residential mortgages, asset finance, personal loans, auto loans, corporate loans, SME loans and revolving credit facilities.

This allows access for a wider range of counterparties – over 80 banks and building societies now have assets placed at the Bank, ready for use in initiatives such as the Funding for Lending Scheme. Work is underway to ensure that there are no technical obstacles to the Bank’s ability to accept equities as collateral should the need arise.

As part of its strategy to broaden liquidity provision in the market, the Bank commenced work in 2015 to assess the feasibility of establishing a Shari’ah compliant facility.

The Bank recognises the challenges Islamic banks face in meeting liquidity requirements with the current limited range of options – existing facilities are not Shari’ah compliant as they involve interest-bearing activity. The Bank has also become an associate member of the Islamic Financial Services Board (IFSB).

In its provision of payment services, the Bank has introduced prefunding for Bacs and Faster Payments, which lowers barriers to entry for banks and building societies looking to become members of these payment schemes.

Previously, a member of these schemes had to hold securities as collateral and commit to a mutual loss-sharing framework. Prefunding allows each institution to manage their exposure limit using reserves at the Bank.

In January 2016 the Bank announced its plan to design a blueprint for the future of the UK’s high value sterling settlement system – the Real Time Gross Settlement System (RTGS). The Bank will look to redesign RTGS in such a way that its resilience is further enhanced, while at the same time enabling innovation.

2.8 How financial services regulators are better utilising new technologies to generate efficiency savings and reduce burdens on business – RegTech

Regulators not only have a role to play in promoting competition and innovation, but also in using technological advances to reduce regulatory burdens on firms and drive efficiency savings. The FCA and PRA have been particularly focused on this issue.

Firms have to meet higher regulatory standards and greater reporting requirements following the financial crisis. New technologies that help firms better manage these regulatory requirements and reduce compliance costs (so-called RegTech) are good for effective competition and innovation.

The government announced at Budget 2015 that the FCA, working with the PRA, will identify ways to support the adoption of RegTech. The FCA launched a Call for Input on supporting the development and adoption of RegTech in November 2015.

In Q1 2016 the FCA held a number of roundtables to seek broader stakeholder views on how to progress this work.

The focus of these were to understand:

• where RegTech may deliver outcomes that improve efficiency and transparency
• where the FCA should focus its efforts to ensure it best supports collaboration
• the challenges and risks faced by fintech firms in providing RegTech to financial services firms, and those faced by financial services firms adopting RegTech
• whether there are existing regulatory rules, policies and guidance which restrict innovation and the adoption of RegTech solutions
• building a RegTech community to facilitate dialogue and the development of creative solutions to the challenges being identified

The FCA will use the results from the Call for Input and roundtables to shape its strategy to reduce the regulatory burden on firms in both RegTech and fintech, while delivering greater compliance. The results will also be used to define the FCA’s and industry’s risk tolerances in this area.

The FCA held a two day TechSprint event in April 2016 to promote a collaborative approach with traditional financial services and the fintech and RegTech communities. The event was an opportunity for participants to generate innovative technology-based ideas to help address the issue of access to financial services.

3. Consultation questions and how to respond

The purpose of this consultation is to seek views on the work of financial services regulators to support innovative technology and disruptive business models, and understand where there might be gaps in regulatory approach when it comes to supporting innovation.

3.1 Consultation questions

The government invites responses from all interested parties, in particular both regulated and unregulated firms and innovators in the financial services sector, on the following specific questions.

1. Does the UK’s regulatory environment for financial services effectively support innovation?
2. Do financial services regulators understand innovation in financial services and potential areas where new technologies and disruptive business models might emerge in the sector?
3. Are there any gaps in approach or areas where financial services regulators should be doing more to support innovative technology and disruptive business models in financial services?
4. Is there more that financial services regulators could do to better utilise new technologies to deliver their own work more effectively?

3.2 How to respond

This consultation will run from 22 April to 6 May 2016.

Responses should be sent by email to Innovation plan consultation.

Alternatively please send responses by post to:

Innovation Plan consultation
Banking and Credit team
HM Treasury
1 Horse Guards Road
London SW1A 2HQ

When responding, please say if you are making a representation on behalf of a business, individual or representative body. In the case of representative bodies, please provide information on the number and nature of people you represent.

3.3 Confidentiality

Information provided in response to this consultation, including personal information, may be published on disclosed in accordance with the access to information regimes. These are primarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 1988 (DPA) and the Environmental Information Regulations 2004.

If you want the information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals with, amongst other things, obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential.

If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on HM Treasury.

HM Treasury will process your personal data in accordance with the DPA and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

1. McKinsey & Co (2015), Cutting Through the Fintech Noise: Markers of success, imperatives for banks ↩

2. EY (2016), UK Fintech on the Cutting Edge: An evaluation of the international fintech sector ↩