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How FinTech is changing the Regulatory Environment: Compliance Keynote at Next

Regulators around the world are recognizing the massive impact that fintech is having on the financial services industry and many are taking new approaches for both traditional institutions and new technology-based players.

Learn more and view the Compliance Keynote presentation given at Next Money Chicago, Sept. 27, 2017.

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How FinTech is changing the Regulatory Environment: Compliance Keynote at Next

  1. 1. COMPLIANCE KEYNOTE SEPTEMBER 26, 2017 HOW FINTECH IS CHANGING THE REGULATORY ENVIRONMENT
  2. 2. AGENDA Copyright © 2017 Accenture. All rights reserved. 1 1. STATE OF FINTECH & REGTECH 2. THE PLAYERS 3. WAYS TO COLLABORATE 4. WHAT YOU CAN DO NOW
  3. 3. INTRODUCTION BASIS OF OUR PERSPECTIVE… Copyright © 2017 Accenture. All rights reserved. 2 The perspectives in this presentation are based on experiences and insights gained through direct engagement in the Financial Services industry. ACCENTURE RESEARCH ACCENTURE VENTURES ACCENTURE STUDIOS ACCENTURE INNOVATION CENTERS ACCENTURE FINTECH ACCELERATORS ACCENTURE LABS Identify and anticipate game-changing business, market and technology trends through provocative thought leadership. Trends Incubate and prototype new concepts through applied R&D projects that are expected to have a significant near-term impact on clients businesses. Research & Development Partner with and invest in growth-stage companies that create innovative enterprise technologies, using an open innovation approach. Investment & Open Innovation Build innovative solutions with speed and agility. Solution Innovation Bring solutions to scale and demonstrate their impact for clients. Use Cases & Assets Mentorship program to bring together FinTech start-ups and leading financial institutions across New York, London, Hong Kong and Dublin. Over 110 companies have graduated since 2011. Platform to grow innovative technology PROJECT WORK Assisting clients identify, select, implement and integrate technology to solve business challenges, improve operational efficiency and reduce cost. Client Engagement
  4. 4. THE GROWING IMPACT OF FINTECH STRONG INVESTMENT TREND Copyright © 2017 Accenture. All rights reserved. 3 Global financing for Venture Capital (VC)-backed FinTech companies has topped $10 billion annually since 2015, a trend expected to continue this year according to CB Insights. $589 $744 $577 $593 $1170 $898 $1072 $1648 $1822 $1392 $3177 $2587 $4326 $5187 $1989 $4992 $3754 $2580 $2158 $2842 $5193 Amount ($M) VC-BACKED FINTECH COMPANIES RAISE $5.2B ACROSS 251 DEALS IN Q2’17 • Investment dollars to VC-backed FinTech companies in 2017 are on pace to rise 19% from 2016, at the current run rate • Global FinTech deal activity could surpass 2016’s all-time high if the rest of the year sustains H1’17’s deal pace 115 104 133 121 136 165 167 171 183 195 218 210 243 240 217 268 247 213 216 245 251 Deals Source: The Global Fintech Report Q2 2017, CB Insights, Research Report: https://www.cbinsights.com/research/report/fintech-trends-q2-2017/
  5. 5. THE GROWING IMPACT OF FINTECH STRONG MOMENTUM BEHIND REGTECH Copyright © 2017 Accenture. All rights reserved. 4 For RegTech alone, there has been nearly $5 billion in equity funding since 2013, across almost 600 deals. 1290 558 1088 1294 1128 894 2013 2014 2015 2016 2017 R Full-Year Projection Disclosed Funding ($M) 83 126 126 147 103 148 Deals Projected 2017 ON PACE TO SET RECORD OF 148 DEALS WORTH NEARLY $1.29B • Year to date, RegTech startups seen 103 deals worth $894M in funding • At the current run rate, deals and dollars in 2017 will reach a deal high of 148 deals worth $1.3B, bringing investment over the last 5 years to more than $5B Source: The State of RegTech, CB Insights, September 20, 2017
  6. 6. COUNTRIES HAVE DEVELOPED REGULATORY SANDBOXES TO FOSTER DEVELOPMENT OF FINTECHS AND REGTECHS (UK, CANADA, AUSTRALIA, SINGAPORE, MALAYSIA, RUSSIA, SWITZERLAND, BAHRAIN, HONG KONG, AND THAILAND).1 REGULATORY ENVIRONMENT WITH RESPECT TO FINTECH & REGTECH Copyright © 2017 Accenture. All rights reserved. 5 Regulators are increasingly embracing FinTechs and RegTechs, with many of them actively supporting their development through regulatory sandboxes, inter-country bridges, and special charters. 10 HAS ESTABLISHED A SPECIAL PURPOSE NATIONAL BANK CHARTER FOR FINTECH COMPANIES TO FACILITATE NATION-WIDE ADOPTION.3 OCC COUNTRIES HAVE ESTABLISHED FINTECH BRIDGES TO COORDINATE INTERNATIONAL DEVELOPMENT AND ADOPTION OF FINTECHS (AUSTRALIA, SINGAPORE, SOUTH KOREA, AND UK).2 4 Sources: 1. Regulatory Sandboxes: A Practice For Innovation That Is Trending Worldwide, ETH News: https://risk.thomsonreuters.com/content/dam/openweb/documents/pdf/risk/report/cost-of-compliance-2017df 2. Cost of Compliance 2017, Thomson Reuters: https://risk.thomsonreuters.com/content/dam/openweb/documents/pdf/risk/report/cost-of-compliance-2017.pdf1 3. OCC’s Noreika endorses fintech charter, slams state regulators, American Banker: https://www.americanbanker.com/news/occs-noreika-endorses-fintech-charter-slams-state-regulators
  7. 7. NEW CHARTER TYPES ARE DRAWING ATTENTION OCC’S CHARTER PROPOSAL Copyright © 2017 Accenture. All rights reserved. The Office of the Comptroller of the Currency’s (OCC) proposal to issue National Bank charters to FinTech companies has faced many challenges with no applications to date. December 2, 2016 OCC proposes a special purpose national bank charter for FinTechs April 26, 2017 State regulators sue the OCC, arguing it lacks the legal authority June 19, 2017 OCC opens Innovation Office January 27, 2017 Over 100 public comments on OCC proposal Today Progress awaits appointment of new OCC director OCC’s approach differs from other nations’ sandbox idea, in which regulators select FinTechs to pursue defined activities for a set time period, while waiving certain laws REACTION TO THE OCC PROPOSAL State regulators: “… unlawful expansion of the chartering authority …”1 NYDFS: “reckless folly”4 FinTech CEO: “…a safe and positive impact on financial service innovation …”3 State Bank Association: “… supportive of efforts to bring fintech firms into the mainstream regulatory system …”2 Bank Trade Association: fosters “…innovation, competition and improved products for customers.5 Acting Comptroller of the Currency Keith Noreika:“Federal regulators aren’t ready to take concrete steps to offer fintech firms a special charter…”6 Sources: See Reference slide
  8. 8. THE PLAYING FIELD SANDBOXES AND ACCELERATORS Copyright © 2017 Accenture. All rights reserved. 7 FinTech firms: their global reach continues to expand with the multiplication of sandboxes and accelerator programs. Regulatory Sandboxes Accelerators & Incubator Programs Australian Securities and Investments Commission (ASIC) The Monetary Authority of Singapore (MAS) Hong Kong Monetary Authority (HKMA) FinTech Innovation Labs NOT EXHAUSTIVE 1864 Accelerator – Flat6Labs 3D FinTech Challenge Anthemis Foundry ATDC FinTech Program Axel Springer Plug and Play Accelerator Bank of England FinTech Accelerator Barclays Accelerator Program Capital One Growth Labs in the UK Citibank Accelerator Program Coin Apex Commerce Innovated FinTech Innovation Lab by Intel and The Floor FUSION iAccelerate JPMorgan In- Residence Program LAUNCHub Main Incubator Mambu FinTech Startup Program Ryerson Futures Plug and Play QC FinTech Lab Six Thirty Startupbootcamp The Watson Centre by IBM ValueStream Wayra Y Combinator Ynext Scivantage FinTech Incubator Program FCA – Innovate Sources: FinTech, RegTech and the role of compliance, Thomson Reuters, December 5, 2017: https://blogs.thomsonreuters.com/answerson/fintech-regtech-compliance/ Accenture Primary and Secondary Research 41 International Accelerators & Incubators Nurturing the Future of the Financial Services Industry, Let’s Talk Payment: https://www.google.com/amp/s/letstalkpayments.com/41-international-fintech-accelerators-incubators-nurturing-the-future-of-the-financial-services-industry/amp/
  9. 9. DIFFERENT PATHS TO ADOPTING REGTECH COLLABORATION AND PARTNERING MODELS Copyright © 2017 Accenture. All rights reserved. 8 Joint activities, investment and acquisition have all been attempted. 8 1. JOINT ACTIVITIES JOINT RESEARCH AND PRODUCT PLACEMENT/ DEVELOPMENT, WORKING WITH OPEN/ APPLICATION PROGRAM INTERFACE (API) PLATFORMS. + Time to market + Flexibility + Building expertise ‒ No exclusivity ‒ Reputational risk ‒ Strategic misalignment 2. INVEST SETTING UP A VENTURE CAPITAL ARM TO INVEST IN STARTUPS & FOCUS MANAGERIAL ATTENTION ON A CERTAIN AREA. + Organic capability growth + Lower investment stake ‒ No autonomy/control ‒ Overpricing ‒ Required knowledge & capabilities 3. ACQUIRE ACQUIRE FINTECH STARTUPS OUTRIGHT, INTEGRATING THEM OR RUNNING THEM AS STANDALONE ENTITIES. + Reduced speed-to- market + Inorganic capability growth ‒ Risk of culture bleeding ‒ Overpricing ‒ Acqui-hire 4. BUILD BUILD NEW INNOVATIONS IN-HOUSE TO CREATE PRODUCTS. + Independence + Personalization & Customization ‒ Slower speed-to-market ‒ Potentially not aligned with best of breed ‒ Legal ramifications
  10. 10. HOW FIRMS ARE ENGAGING FINTECH / REGTECH FIRMS ARE ADOPTING FINTECH / REGTECH SOLUTIONS AT A FASTER PACE Copyright © 2017 Accenture. All rights reserved. 9 This is replacing investments in traditional Compliance areas. 9 52% 33% 35% ~$5BN OF FIRMS BELIEVE THAT REGTECH SOLUTIONS ARE IMPACTING HOW THEY MANAGE COMPLIANCE, WHILE 17% HAVE ALREADY IMPLEMENTED A REGTECH SOLUTION.1 OF FIRMS HAVE INCREASED FOCUS ON ASSESSING FINTECH / REGTECH SOLUTIONS AS COMPARED TO LAST YEAR.2 OF FIRMS EXPECT THEIR BUDGETS FOR REGTECH TO INCREASE IN THE COMING YEAR.3 ACROSS 585 DEALS IN REGTECH EQUITY FUNDING SINCE 2013.4 Sources: 1. Cost of Compliance 2017, Thomson Reuters: https://risk.thomsonreuters.com/content/dam/openweb/documents/pdf/risk/report/cost-of-compliance-2017.pdf 2. Ibid 3. Ibid 4. RegTech Europe: 60+ Startups Helping Financial Services Companies Navigate Regulations, CB Insights Research Briefs: https://www.cbinsights.com/research/RegTech-europe-market-map/
  11. 11. COMPLIANCE MODERNIZATION REQUIREMENTS THE MODERN DAY COMPLIANCE FUNCTION IS MARKED BY SEVERAL KEY CHARACTERISTICS Copyright © 2017 Accenture. All rights reserved. 10 These are driven or facilitated by emerging technology trends and capabilities. People • Elastic Workforce - Trained resources that support subject matter advisors (SMA) and business as usual (BAU) staff as needed • Cost efficiencies with center of excellence (COE) or business process outsourcing (BPO) Technology Architecture / Platform • New Open / API-based architectures that allow “plug-in” of new technical capabilities to add, upgrade or swap components much easier, thereby facilitating faster integration of RegTech solutions • Rapid adoption of state-of-the-art RegTech solutions as they reach maturity • Robust, secure and scalable Data / Information • Data quality is high quality and data sets are fit for purpose • New Data sources can be quickly onboarded into evolving analytical library End-to-End Process • Machine Learning and Intelligent Automation embedded in process where available (e.g., surveillance) • Integrated Case Management to handle Regulatory and Compliance issues across the enterprise Analytics, MI and Reporting • High Quality Management Information (MI) Dashboards and Business Intelligence (BI) • Standalone and integrated analytics across Compliance functions
  12. 12. Analytics Domain Expertise RegTech Mkt Knowledge NEW SKILLS ARE REQUIRED IN COMPLIANCE TO EFFECTIVELY LEVERAGE FINTECH Copyright © 2017 Accenture. All rights reserved. 11 The profile of talent and skills required in organizations will continue to evolve as technology becomes increasingly integrated into daily activities, meaning that even traditional business-focused roles will require understanding of things like data, analytics and applications of Compliance technology. Focus and Proficiency Communications Business Acumen Data Scientist Analytics Ethical Monitor Performance Monitoring Control Oversight Compliance Organization IT Architecture Experts Surveillance and Monitoring Risk and Controls MI / Reporting Experts Leadership Data Science Experts Focus and Proficiency Data Architecture Business Acumen Analytics Domain Expertise Technology Architecture Systems Design Data Science RegTech Market Knowledge …and Compliance Officers, in particular, will need a deeper understanding of tech to effectively perform their jobs and enable better collaboration.Source: Accenture 2017 Compliance Survey Tech Arch Systems Design Data Science Business Acumen Data Arch
  13. 13. • Quarule, Inc. 12 • Silverfinch (CSS Company) • AssetLogic SARL • TheMarketsTrust (Gust, Inc.) • IdentityMind™ • Trunomi Ltd. • Trulioo Inc. • Detectica Inc. • Digital Reasoning Systems, Inc. • Fund Recs™ • Fiserv, Inc. COMPLIANCE/REGTECH COLLABORATION BARRIERS AND REWARDS Copyright © 2017 Accenture. All rights reserved. There are some significant barriers to increasing collaboration between Compliance and RegTech, but there are many potential rewards as well. RegTech collaboration brings increased scrutiny, and Regulators are bringing big data and analytics to their Surveillance toolkit. RegTech collaboration requires significant investment. Compliance budgets cannot fund the innovation needed to modernize capabilities. Scrutiny is magnified Compliance budgets are built for BAU – not innovation Leadership in Risk & Compliance tends to take a conservative approach, which limits willingness to invest and leverage newer and unproven technology solutions. Limited willingness to take risks when investing in newer capabilities BARRIERS BENEFITS / REWARDS Risk Data Aggregation Data utilities to allow efficient distribution and storage of data in secure and controlled environments Forecasting & Scenario Analysis Risk-management solutions that include portfolio simulation and regulatory compliance reporting Trade Surveillance Software to help reconcile positions (e.g., cash, Forex) and reconstruct trades KYC / Client Identification Solutions to manage client onboarding processes and conduct due diligence reviews Transaction Monitoring Applications to scan transactions to help determine potentially suspcious or fraudulent activity Employee Monitoring Automated solutions that monitor and interpret voice and eCommunications Semantic technologies that assist with reg interpretation and managing of jurisdictional requirements Reg Interpretation & Management
  14. 14. Copyright © 2017 Accenture. All rights reserved. 13 BANKS & FIRMS • Efficiency • Happy customers • Cost reduction / Lower cost of Compliance • Reduced cost of compliance • Faster deployment of services • Better, more reliable technology REGTECHS & FINTECHS • Access to market and other resources needed • Reinforcement of trust • Reduced cost of customer acquisition REGULATORS • Customer protection • Reduced systemic risk • Better competition in the market • Increased market competition • Increased efficiency in the market INDUSTRY • Increased level of “safety and soundness” • Protected customers • Higher level of Compliance at a lower cost BENEFITS OF COLLABORATION
  15. 15. SMOOTHER PATH TO COLLABORATION NEW PERSPECTIVES ARE EMERGING, MAKING IT EASIER TO COLLABORATE AND PARTNER SUCCESSFULLY Copyright © 2017 Accenture. All rights reserved. 14 BANKS & FIRMS ORIGINAL PERSPECTIVE ON COLLABORATING • Mistrust of regulators (viewed as police) • Mistrust of vendors and capabilities • Conservative approach to adopting new technology • Reserved approach towards collaboration • Not open to sharing data and info externally (“closed loop system”) NEW PERSPECTIVE ON COLLABORATING • Open to collaboration and joint activities • Increased appetite for innovation BARRIERS • Lack of leadership support • Silo’d organizational structures • Inflexible architectures • Legacy systems • Lack of needed (technical) talent and skills • Lack of resources • Conflicting priorities • Lack of vision and/or innovation strategy
  16. 16. SMOOTHER PATH TO COLLABORATION NEW PERSPECTIVES ARE EMERGING, MAKING IT EASIER TO COLLABORATE AND PARTNER SUCCESSFULLY Copyright © 2017 Accenture. All rights reserved. 15 FINTECHS & REGTECHS ORIGINAL PERSPECTIVE ON COLLABORATING • Unwilling to accept criticism and feedback (hubris) • Limited scope of offering (specific use cases) • Selective “partnering and collaboration” only to improve their offering NEW PERSPECTIVE ON COLLABORATING • Open to partnering in mutually beneficial way (willingness to adapt product) • Increased appetite for innovation BARRIERS • Lack of industry / regulatory knowledge • Limited resources • Cultural fit with prospective partners • Immature offering • Evolving value proposition (“solution without a problem syndrome”)
  17. 17. SMOOTHER PATH TO COLLABORATION NEW PERSPECTIVES ARE EMERGING, MAKING IT EASIER TO COLLABORATE AND PARTNER SUCCESSFULLY Copyright © 2017 Accenture. All rights reserved. 16 REGULATORS ORIGINAL PERSPECTIVE ON COLLABORATING • Limited awareness of specific innovations and capabilities provided by RegTechs • Conservative mindset towards adopting new technology • Limited support of innovation • Lack of clarity on their specific mandate to foster innovation (i.e., who is responsible) • Limited coordination across other regulators NEW PERSPECTIVE ON COLLABORATING • Increased level of support towards innovation • Increased promotion and facilitating industry discussion on technology adoption • Participation in industry forums & sandboxes • Willingness to mentor (“office hours”) • Increased focus on new entrants • Increased fostering of innovation and competition (e.g., OCC FinTech charters) BARRIERS • Taking a firm position invariably results in debate and stakeholder reaction • It is not clear what kind of new or evolving regulation are required that focus on FinTech • Long standing mistrust of regulators (i.e. viewed as “the police”) • Despite increase use of technology, shortage of technology expertise within regulators themselves
  18. 18. CULTURAL FIT AND STEREOTYPES THERE HAS TRADITIONALLY BEEN A GAP BETWEEN PERCEPTION AND REALITY THAT HAS INHIBITED COLLABORATION Copyright © 2017 Accenture. All rights reserved. 17 BANKS & FIRMS FINTECHS & REGTECHS REGULATORS How they view themselves… How others see them… • Leading edge • Flexible • Technically advanced • Noble & changing the world for the better • Technically advanced • Cool • Protectors • Noble & changing the world for the better • Important • Difficult to work with • Too large and inflexible • Not innovative • Uneducated on the ways of the industry • Arrogant • Inexperienced • Confusing from a technical point of view • Enforcers • Indecisive • Unfair / Biased in their regulation • Unapproachable
  19. 19. FI AND FINTECH COLLABORATION FINTECH INNOVATION LAB SURVEY Finding #1: There’s a disconnect between FIs and FinTechs on the scope and purpose of Proof of Concepts (POCs ), which commonly end up dragging for months with no clear success criteria or exit strategy. Finding #2: FIs and FinTech companies highlight different areas as problematic when moving from prospecting to procurement. Finding #3: FI processes are too complex and onerous for small FinTechs. Finding #4: FIs and FinTechs disagree on the rate of live implementations achieved with FinTechs believing the success rate is higher than FIs (<25% convert to implementations according to FIs surveyed). Finding #5 FIs are working more actively with regulators than FinTechs, with 60% of FIs surveyed claiming they are actively working with regulators but only 17% of FinTechs are doing the same. Copyright © 2017 Accenture. All rights reserved. 18 Several key findings were uncovered in our recent survey of 35 financial institutions (FIs) and 52 FinTechs from the FinTech Innovation Lab accelerator program: Source: Accenture 2017 FinTech Survey (35 Financial Institutions, 52 FinTechs)
  20. 20. FI AND FINTECH COLLABORATION BARRIERS TO ACHIEVING SUCCESS BARRIERS TO COLLABORATION mostly originate in the cultural clash between highly regulated, control-driven FIs and nimble and innovation-driven FinTech companies. Copyright © 2017 Accenture. All rights reserved. 19 FIs & FinTechs operate very differently and have sharply different views of their experiences working together: FINTECH OPPORTUNITIES get bogged down in lengthy and diffuse approval processes within FIs - FinTechs advocate for POCs that are 1 month or shorter but commonly end up in approval processes of 3+ months with no clear success criteria or exit strategy and spending time that could be productive on administrative activities. FIS AND FINTECH COMPANIES have different perceptions of collaboration barriers - FIs see regulation, compliance and security as the biggest hurdles to advancement. FinTechs cite issues related to lack of cooperation from FIs. Source: Accenture 2017 FinTech Survey (35 Financial Institutions, 52 FinTechs)
  21. 21. FI AND FINTECH COLLABORATION FI ACTIONS TO IMPROVE SUCCESS RATE BE TRANSPARENT with the FinTech companies you’re collaborating with and agree on the scope, timeframe and exit strategy for the POC. Copyright © 2017 Accenture. All rights reserved. 20 There are ways that FI can make themselves more FinTech-friendly: SPEED UP AND SIMPLIFY your processes – consider how a small company will find dealing with you - consider streamlining the POC approval process and creating a “fast track” procurement process for FinTechs. COLLABORATION WITH FINTECHS has a higher probability of yielding benefits if targeted to solve a specific business issue or problem. CREATE SANDBOXES that FinTech companies and FIs can use effectively for the POC. Source: Accenture 2017 FinTech Survey (35 Financial Institutions, 52 FinTechs)
  22. 22. FI AND FINTECH COLLABORATION FINTECH ACTIONS TO IMPROVE SUCCESS RATE LEARN TO SPEAK the same language as FIs and recognize and understand the stumbling blocks that are holding back progress. Copyright © 2017 Accenture. All rights reserved. 21 Similarly, there are steps FinTechs can take to make themselves FI-friendly: REGULATION, COMPLIANCE AND SECURITY concerns are the top reasons for not proceeding with a POC, according to 60 percent of the FIs surveyed - FinTechs would greatly benefit from a better understanding of these concerns and should work alongside FIs to find solutions. UNDERSTAND THE SPECIFIC business or industry need first, then build or tailor the solution around it – many new FinTechs have solutions in search of a problem or are exploring the re-purposing of a solution intended for a different problem. Source: Accenture 2017 FinTech Survey (35 Financial Institutions, 52 FinTechs)
  23. 23. WHAT YOU CAN DO NOW STEPS TO FOSTER COLLABORATION AND INNOVATION IN COMPLIANCE Copyright © 2017 Accenture. All rights reserved. 22 BANKS & FIRMS FINTECHS & REGTECHS REGULATORS • Create and migrate towards Open Banking (API-based) architectures that lend themselves to plugging in new technology capabilities • Hold internal discussions to obtain buy- in and ease constraints to achieving collaboration and adoption of technology • Define a FinTech & RegTech strategy and the desired outcomes to help drive actions and decisions on prospective partners and solutions • Continue to study & learn about regulatory obligations • Meet with regulators early and often to obtain their guidance and point of view • Refine value-proposition and capabilities to focus on relevant compliance use cases (define the problem you are solving before building the solution) • Embrace technology as a way to lower the overall cost of compliance in the industry • Define new standards / protocols to facilitate collaboration (e.g., data sharing, APIs, etc.) with an eye on eliminating unnecessary barriers and fostering innovation • Actively promote and participate in regulatory sandboxes to gain early understanding of evolving technology and potential risks that may need to be addressed
  24. 24. REFERENCE Sources – timeline: • OCC to Consider Fintech Charter Applications, Seeks Comment, OCC, December 2, 2016: https://www.occ.gov/news-issuances/news- releases/2016/nr-occ-2016-152.html • Public Comments on Exploring Special Purpose National Bank Charters for Fintech Companies, OCC, January 27, 2017: https://www.occ.gov/topics/responsible-innovation/fintech-charter-comments.html • State regulators sue OCC over fintech charter, American Banker, April 26, 2017: https://www.americanbanker.com/news/ • OCC to Hold Innovation Office Hours in New York, OCC, June 19, 2017: https://www.occ.treas.gov/news-issuances/news-releases/2017/nr-occ-2017- 68.html • OCC Fintech Plan Faces Uncertainty as Comptroller Term Expires, Credit Union Times, April 18, 2017: http://www.cutimes.com/2017/04/18/occ- fintech-plan-faces-uncertainty-as-comptroller?slreturn=1506375193 Sources – quotations: 1. CSBS Files Complaint Against Comptroller of the Currency, Conference of State Bank Supervisors, April 25, 2017: https://www.csbs.org/news/press releases/pr2017/Pages/042617.aspx 2. Comments on Exploring Special Purpose National Bank Charters for fintech Companies, Massachusetts Bankers Association letter, January 15, 2017: https://www.occ.gov/topics/responsible-innovation/comments/comment-mass-bankers.pdf 3. Response to Request for Comments to Consider Fintech Charters, OCC, January 27, 2017:https://www.occ.gov/topics/responsible- innovation/comments/comment-wing-cash-parity-pay.pdf 4. NY regulator sues U.S. OCC over national charters for online lenders, Reuters, May 12, 2017: http://www.reuters.com/article/us-new-york-occ- fintech/ny-regulator-sues-u-s-occ-over-national-charters-for-online-lenders-idUSKBN1882QO 5. Exploring Special Purpose National Bank Charters for Fintech Companies, BAFT, January 17, 2017: https://www.occ.gov/topics/responsible- innovation/comments/comment-baft.pdf 6. OCC Not Yet Ready to Offer Special Charters to Fintechs, Bloomberg BNA, September 13, 2017: https://www.bna.com/occ-not-yet-n57982087846/ Copyright © 2017 Accenture. All rights reserved. 23
  25. 25. ABOUT ACCENTURE Accenture is a leading global professional services company, providing a broad range of services and solutions in strategy, consulting, digital, technology and operations. Combining unmatched experience and specialized skills across more than 40 industries and all business functions— underpinned by the world’s largest delivery network —Accenture works at the intersection of business and technology to help clients improve their performance and create sustainable value for their stakeholders. With more than 411,000 people serving clients in more than 120 countries, Accenture drives innovation to improve the way the world works and lives. Visit us at www.accenture.com DISCLAIMER This presentation is intended for general informational purposes only and does not take into account the reader’s specific circumstances, and may not reflect the most current developments. Accenture disclaims, to the fullest extent permitted by applicable law, any and all liability for the accuracy and completeness of the information in this presentation and for any acts or omissions made based on such information. Accenture does not provide legal, regulatory, audit, or tax advice. Readers are responsible for obtaining such advice from their own legal counsel or other licensed professionals. Accenture, its logo, and High Performance Delivered are trademarks of Accenture.

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