Report of the

Working Group on FinTech

and Digital Banking

November 2017

Reserve Bank of India

Central Office
Mumbai
 Acknowledgements

The Working Group gratefully acknowledges the support and guidance received from
Deputy Governor, Shri. N.S. Vishwanathan. The Chairman is grateful for the
contributions made by the individual members of the Working Group for completing the
task entrusted to it. In particular, he wishes to place on record the excellent work done by
the Member-Secretary, Shri Prasant K. Seth, General Manager, RBI in compiling the
Group's Report.

The Group wishes to specially acknowledge the contribution of Shri S.S. Barik, CGM-In-
Charge, DBR in providing necessary support to the Working Group. The Group also
wishes to acknowledge the contribution by Shri Talakona Jagadeesh Kumar, Assistant
General Manager, DBR, in providing assistance to the Working Group for drafting the
Report.

The Group also wishes to thank Shri Rajat Gandhi, M/s Faircent Technologies, Mr.
Lishoy Bhaskaran and Mr. Mohamed Galib, M/s Backwaters Technology and Ms.
Theresa Karunakaran, Deutsche Bank, for sharing their valuable experience and market
perspective on working of various FinTech products.
 Contents
Background, Terms of Reference, Methodology & Members of the Group

Executive Summary……………………………………………………………………….. 1

1. Introduction……………………………………………………………………………... 5
1.1. FinTech and Financial Market disruptions………………………………………. 5
1.2. FinTech: Definitions and scope…………………………………………………... 5
2. FinTech and its impact on Global Financial Services…………………………… 7
2.1. FinTech innovations, products and technology…………………………………. 7
2.2. FinTech innovations and their impact on global financial services……………15
3. FinTech and its impact on Indian Financial Services…………………………….17
3.1. FinTech innovations, products and technology………………………………….17
3.2. Innovations in Digital Banking and investment services in India………………22
3.3. Scope for Growth of FinTech and digital banking in India………….…………..26
4. Recent global regulatory Initiatives on FinTech…………………………………..27
4.1. Global experiences on regulatory actions………………………………………..27
4.2. Regulatory Sandboxes/Innovation Hub…………………………………………..29
4.3. Regulatory response in other jurisdictions………………………………….…….45
5. Emerging Regulatory and Supervisory issues in India…………………….…….47
5.1. Regulatory and Supervisory response in India……………………………….….47
5.2. Impact on Financial inclusion………………………………………………….…...49
5.3. Initiatives taken by other financial market regulators in India…………….…….49
5.4. Cyber security and FinTech…………………………………………………….….51
6. Way Forward – for stakeholders………………………………………….…….….…57
6.1. Regulation……………………………………………………………………..…..…57
6.2. Supervision……………………………………………………………………..…....64
6.3. Banks / NBFCs/Securities Markets/Insurance Companies……………..…..….65
6.4. Data Security, Privacy and Fraud prevention………….………………….……..66
6.5. Government……………………………………………………………….……....…66
6.6. Consumers………………………………………………………………….………..67
7. List of Recommendations……………………………………………………………...68
Annexes………………………………………………………………………………….…….71
References / Bibliography, Abbreviations………………………………………………73
Background, Terms of Reference, Methodology and Members of the Group
Background

In view of the growing significance of FinTech innovations and their interactions with the
financial sector as well as the financial sector entities, the Financial Stability and
Development Council - Sub Committee (FSDC-SC) in its meeting held on April 26, 2016
decided to set up a Working Group to look into and report on the granular aspects of
FinTech and its implications so as to review and reorient appropriately the regulatory
framework and respond to the dynamics of the rapidly evolving FinTech scenario.

Given the wide ranging issues involved, Reserve Bank of India set up an inter-regulatory
Working Group (WG) to look into and report on the granular aspects of FinTech and its
implications for the financial sector so as to review and reorient appropriately the
regulatory framework and respond to the dynamics of the rapidly evolving FinTech
scenario. The Group included representatives from RBI, SEBI, IRDA, and PFRDA, from
select financial entities regulated by these agencies, rating agencies such as CRISIL and
FinTech consultants / companies.

Terms of Reference of the Working Group

i. To undertake a scoping exercise to gain a general understanding of the major

FinTech innovations / developments, counterparties / entities, technology
platforms involved and how markets, and the financial sector in particular, are
adopting new delivery channels, products and technologies
ii. To assess opportunities and risks arising for the financial system from digitisation
and use of financial technology, and how these can be utilised for optimising
financial product innovation and delivery to the benefit of users / customers and
other stakeholders.
iii. To assess the implications and challenges for the various financial sector
functions such as intermediation, clearing, payments being taken up by non-
financial entities.
iv. To examine cross country practices in the matter, to study models of successful
regulatory responses to disruption across the globe.
v. To chalk out appropriate regulatory response with a view to re-aligning / re-
orienting regulatory guidelines and statutory provisions for enhancing FinTech /
 digital banking associated opportunities while simultaneously managing the
evolving challenges and risk dimensions.
vi. Any other matter relevant to the above issues.

Methodology/Approach

The WG reviewed globally published material on the subject, the FinTech developments
worldwide, the approaches adopted by various regulators, evolving views of international
standard-setting bodies, and interacted with some FinTech entities/start-ups/sponsors
operating in India as payment system provider, platform lender, block chain/digital ledger
provider, etc. and took on board their views and concerns, including impact on the
broader financial market 1. These helped inform some of the views of the WG on aspects
to be kept in mind while conceptualizing, designing and implementing the regulatory
framework / structure for FinTech in the near future.

Members of the Working Group

The WG comprised:
i. Shri Sudarshan Sen, Executive Director, RBI Chairman
ii. Dr. Sarat Kumar Malik, CGM, SEBI Member
iii. Shri R.K. Sharma, Joint Director, IRDAI Member
iv. Shri Rakesh Sharma, GM, PFRDA Member
v. Shri A. P. Hota, MD & CEO, NPCI Member
vi. Dr. A. S. Ramasastri, Director, IDRBT Member
vii. Smt. Nanda S. Dave, CGM, DPSS, RBI Member
viii. Shri R Ravikumar, CGM, DBS, RBI Member
ix. Shri Mrutyunjay Mahapatra, DMD, & CIO, SBI Member
x. Shri Nitin Chugh, Head, Dig. Bkg. HDFC Bank Member
xi. Shri Amish Mehta, CFO, CRISIL Member
xii. Shri A. Joseph, JLA, LD, RBI Member
xiii. Shri Prasant K. Seth, GM, DBR, RBI Member-Secretary

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M/s Backwaters Tech Pvt. Ltd., Faircent Technologies India and Deutsche Bank and Bill & Melinda Gates Foundation
Executive Summary
a. Financial services, including banking services, are at the cusp of a revolutionary
change driven by technological and digital innovations. A rapidly growing number of
financial entities and technology firms are experimenting with related technological and
financial solutions as well as new products in the financial services field which either
modifies the way financial intermediation takes place or leads to disintermediation.

b. FinTech is broadly an omnibus term used to describe emerging technological

innovations in the financial services sector, with ever increasing reliance on information
technology. Commencing as a term referring to the back end technology used by large
financial institutions, it has expanded to include technological innovation in the financial
sector, including innovations in financial literacy and education, retail banking,
investments, etc.
Technological innovation is considered to be one of the most influential developments
affecting the global financial sector in the near future. Innovations related to payments,
lending, asset management and insurance pose a challenge to business models and
strategies of financial institutions; yet, these also bring opportunities for both the
incumbent market participants and newcomers. At the same time, innovation can create
new risks for individual financial institutions, consumers of financial services, as well as
the financial system as a whole.
c. FinTech or digital innovations have emerged as a potentially transformative force in
the financial markets. A recent FSB study highlighted some of the potential benefits of
FinTech, including efficiency improvements, risk reduction and greater financial
inclusion. It also identified some of the key challenges associated with FinTech, such as
difficulty of regulating an evolving technology with different use cases, monitoring activity
outside the regulated sector, identifying and monitoring new risks arising from the
technology.

d. Financial innovation has become a focal point for a lot of attention, and some
jurisdictions have decided to take a more active approach in facilitating this innovation.
To do this, they have taken a variety of regulatory and supervisory initiatives such as
regulatory sandboxes, innovation hubs, innovation incubators or accelerators, etc.
e. The regulatory uncertainty surrounding FinTech could potentially hamper
development. As a result, international standard setting bodies (BCBS, FSB, CPMI,
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WBG, etc.) including regulatory authorities of different jurisdictions are taking steps to
actively monitor FinTech developments both domestically and in cooperation with
international organizations.

f. Key Recommendations

 There is a need to have a deeper understanding of various FinTech products and

their interaction with the financial sector and, thereby, the implications on the financial
system, before regulating this space.
 The regulatory actions may vary from “Disclosure” to “Light-Touch Regulation &
Supervision” to a “Tight Regulation and Full-Fledged Supervision”, depending on the
risk implications.
 There is a need to develop a more detailed understanding of risks inherent in
platform based FinTech.
 Various financial sector regulators to identify sector specific FinTech products and
regulatory approaches.
 The adoption of digital channels to replace manual time-consuming processes to
empower customers and / or workforce in insurance sector.
 Innovation labs may be established, including within insurance companies, to
combine brand and product managers with technological and analytical resources.
 As and when any securities market Fin-Tech products are introduced or emerge in
the market, regulators may assess the product and see whether it can be monitored
by way of registering them as an intermediary or through the activity regulations.
 Insurance companies may collaborate with “Insurtech” entities or start-ups to provide
better customer experience in a cost effective manner.
 Financial sector regulators need to engage with FinTech entities in order to chalk out
appropriate regulatory response and with a view to re-align regulation and
supervision in response to the changing environment.
 In order to identify and monitor the challenges associated with the development of
major FinTech innovations and to assess respond to opportunities and risks arising
for the financial system from these innovations, a ‘dedicated organizational structure’
within each regulator needs to be created.

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 To provide an environment for developing FinTech innovations and testing of
applications/APIs developed by banks and FinTech companies.
 An appropriate framework may be introduced for “Regulatory Sandbox/innovation
hub” within a well-defined space and duration where financial sector regulators will
provide the requisite regulatory support, so as to increase efficiency, manage risks
and create new opportunities for consumers in Indian context similar to other
regulatory jurisdictions.
 In view of IDRBT’s unique positioning as a research and development institute, and
as indicated by some of its activities, it is felt that IDRBT is well placed to create and
maintain a regulatory sandbox in collaboration with RBI for enabling innovators to
experiment with their banking/payments solutions for eventual adoption. The Institute
may continue to interact with RBI, banks, solution providers regarding testing of new
products and services and over a period of time upgrade its infrastructure and skill
sets to provide full-fledged regulatory sandbox environment. The Reserve Bank of
India may actively engage with the Institute in this regard.
 Regulatory and legal reforms are essential to enable the sustained development of a
digital financial industry for the future.
 Partnerships / engagements among regulators, existing industry players, clients and
FinTech firms will enable the development of a more dynamic and robust financial
services industry.
 Regulators may explore the use of Reg Tech that may facilitate the delivery of
regulatory requirements more efficiently and effectively than existing capabilities.
 The organizational structure and human resources (HR) practices of regulators have
to be reoriented to meet the challenges of innovation, in terms of adapted HR hiring
profiles, learning and educational programmes.
 There is a need for a stand-alone data protection and privacy law in the country.
 Banks / Regulated entities may be encouraged to collaborate with FinTech/start-ups
to improve their customer experience and operational excellence. They may also
consider undertaking FinTech activity in areas such as payments, data analytics and
risk management.
 Models of engagement and checklist to be developed by each regulator for each of
the activities.

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 Given that FinTech companies are in their infancy but are growing at a rapid pace,
the Government may consider introducing tax subsidies for merchants that accept a
certain proportion of their business revenues from the use of digital payments.
 The requirement of increasing the levels of education/ awareness of customers
should be highlighted by all market regulators.
 A self-regulatory body for FinTech companies may be encouraged.

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1. Introduction
1.1 FinTech and Financial Market disruptions

The term “FinTech” is a contraction of the words “finance” and “technology”. It refers to
the technological start-ups that are emerging to challenge traditional banking and
financial players and covers an array of services, from crowd funding platforms and
mobile payment solutions to online portfolio management tools and international money
transfers.

Some of the major FinTech products and services currently used in the market place are
Peer to Peer (P2P) lending platforms, crowd funding, block chain technology, distributed
ledgers technology, Big Data, smart contracts, Robo advisors, E-aggregators, etc. These
FinTech products are currently used in international finance, which bring together the
lenders and borrowers, seekers and providers of information, with or without a nodal
intermediation agency.

FinTechs are attracting interest both from users of banking services and investment
funds, which see them as the future of the financial sector. Even retail groups and
telecom operators are looking for ways to offer financial services via their existing
networks. This flurry of activities raises questions over what kind of financial landscape
will emerge in the wake of the digital transformation.

Financial institutions are seeking to increase their knowledge in relation to technological

innovation, both through partnerships with tech companies and by investing in or
acquiring such companies. Despite this, there are wide differences in the preparedness
of market participants for these changes in practice.

1.2 FinTech: Definitions and scope

1.2.1 What is FinTech?

FinTech is an umbrella term coined in the recent past to denote technological innovation
having a bearing on financial services. FinTech is a broad term that requires definition
and currently regulators are working on bringing out a common definition.

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According to Financial Stability Board (FSB), of the BIS, “FinTech is technologically
enabled financial innovation that could result in new business models, applications,
processes, or products with an associated material effect on financial markets and
institutions and the provision of financial services”. This definition aims at encompassing
the wide variety of innovations in financial services enabled by technologies, regardless
the type, size and regulatory status of the innovative firm. The broadness of the FSB
definition is useful when assessing and anticipating the rapid development of the
financial system and financial institutions, and the associated risks and opportunities.

FinTech innovations have the potential to deliver a range of benefits, in particular

efficiency improvements and cost reductions. Technological developments are also
fundamentally changing the way people access financial services and increasing
financial inclusion.

There is large investment in FinTech sector by venture capital Funds. During 2014
around USD 12 billion was invested in FinTech companies, and in 2015 the same is
estimated around USD 20 billion 2.

2
KPMG-The pulse of FinTech- https://home.kpmg.com/xx/en/home/media/press-releases/2016/03/kpmg-and-cb-insights.html

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 2. FinTech and its impact on global Financial Services

2.1 FinTech innovations, products and technology

2.1.1 There is no commonly accepted taxonomy for FinTech innovations. In order to get
a sense of the broad nature of the ongoing developments in this area, the WG
categorized some of the most prominent FinTech innovations into five main groups
through its scoping exercise. Though this does not represent a comprehensive review of
all FinTech innovations, it highlights those regarded as potentially having the greatest
effects on financial markets 3.

2.1.2 A simple categorization of some of the most prominent FinTech innovations into
groups according to the areas of financial market activities where they are most likely to
be applied is as under:

Categorization of major FinTech Innovations

Payments, Deposits, Lending Market Investment Data Analytics
Clearing & & capital raising provisioning management & Risk
Settlement Management

Mobile and web- Crowd-funding Smart contracts Robo advice Big data
based payments Peer to peer lending Cloud computing Smart contracts Artificial
Digital currencies Digital currencies e-Aggregators e-Trading Intelligence
Distributed ledger Distributed Ledger & Robotics

2.1.3 Payments, clearing and settlement services

Innovations in this category are targeted at improving the speed and efficiency of
payments, clearing, and settlement, reducing cost and changing the ways people access
financial services and conduct financial transactions. Some of the innovations in areas of
payments, clearing and settlements in the financial markets are as follows:

3
Drawing on a categorization from WEF, The Future of Financial Services, Final Report, June 2015
7
2.1.3.1 Mobile and web-based payment applications
The majority of developments in the areas of payments are based on mobile technology
by providing wrappers over existing payments infrastructure. Examples include Apple
Pay, Samsung Pay, and Android Pay, which sit on top of existing card payment
infrastructure enabling the user’s mobile devices to act as their credit/debit cards. There
are also mobile payments built on new payment infrastructure, for example mobile phone
money services, such as M-Pesa in Kenya and IMPS in India, which provide payment
services. While such innovation facilitates the entrance of new users to the financial
system, it may also move the provision of some payment services to non-banking
companies that are not regulated as financial entities. There are a number of web-based
and mobile-based payment applications that primarily focus on the customer experience
and often aim to better integrate payment transactions within the commerce value chain.
These service providers usually do not offer banking services other than payments, and
they normally do not apply for banking licenses. The services can be offered by the
payer’s own payment service provider (PSP) or by third party services (TPS), where an
innovative service provider links payers and merchants by using the payer’s online
banking credentials but without necessarily involving the payer’s PSP in the scheme or
solution or by using the card payment infrastructure (Alipay, PayPal).
2.1.3.2 Digital currencies (DCs)
Digital currencies (DCs) are digital representations of value, currently issued by private
developers and denominated in their own unit of account. They are obtained, stored,
accessed, and transacted electronically and neither denominated in any sovereign
currency nor issued or backed by any government or central bank 4.
Digital currencies are not necessarily attached to a fiat currency, but are accepted by
natural or legal persons as a means of exchange and can be transferred, stored or
traded electronically. DC schemes comprise two key elements: (i) the digital
representation of value or ‘currency’ that can be transferred between parties; and (ii) the
way in which value is transferred from a payer to a payee.
Privately issued DCs, such as Bitcoin, facilitate peer-to-peer exchange, possibly at lower
cost for end-users and with faster transaction times, especially across borders. DC
schemes are also known as ‘crypto currencies’ due to their use of cryptographic

4
Committee on Payments and Market Infrastructures, “Digital Currencies,” November 2015.
8
 techniques. It is reported that there are hundreds of crypto currencies currently in use
with an aggregate market capitalization of around USD 6.5bn 5. However, only a very
small fraction of these currencies are traded on a daily basis.
Crypto currencies derive their value solely from the expectation that others will be willing
to exchange it for sovereign currency or goods and services. DC schemes may allow for
the issuance of a limited or unlimited number of units. In most digital currency schemes,
distributed ledger technology allows for remote peer-to-peer exchanges of electronic
value. The various DC schemes differ from each other in a number of ways; they have
different rules for supplying the currency; they differ in the way in which transactions are
verified.
The implications of DCs for financial firms, markets and system will depend on the extent
of their acceptability among users. If use of DCs were to become widespread, it would
likely have material implications for the business models of financial institutions. DCs
could potentially lead to a disintermediation of some existing payment services
infrastructure.
At the moment, DCs schemes are not widely used or accepted, and they face a series of
challenges that could limit their future growth. As a result, their influence on financial
services and the wider economy is negligible today, and it is possible that in the long
term they may remain a product for a limited user base on the fringes of mainstream
financial services.
The regulatory perimeter around DCs is a complicated issue and regulation may depend
on the definition of DCs in particular jurisdictions. The cross-border reach of DC
schemes may make it difficult for national authorities to enforce laws.
2.1.3.3 Distributed ledgers Technology
Distributed ledger technologies (DLT) provide complete and secure transaction records,
updated and verified by users, removing the need for a central authority. These
technologies allow for direct peer-to-peer transactions, which might offer benefits, in
terms of efficiency and security, over existing technological solutions.
The impetus behind the development and adoption of distributed ledger technology are
the potential benefits. The major benefits are reduced cost; faster settlement time;
reduction in counterparty risk; reduced need for third party intermediation; reduced

5
FinTech: Describing the Landscape and a Framework or Analysis by SCAV, FSB-March 2016

9
collateral demand and latency; better fraud prevention; greater resiliency; simplification
of reporting, data collection, and systemic risk monitoring; increased interconnectedness;
and privacy.
Distributed ledger technology is an innovation with potentially broad applications in
financial market infrastructures (FMIs) and in the economy as a whole. Its most common
use at present is for digital currencies, but firms are stepping up their R&D activities for
other uses including securities trading, smart contracts, and land and credit registries. If
widely adopted, distributed ledger technology can pose new challenges for regulation.
Though there are no imminent concerns, constant monitoring of developments in the
application of the distributed ledger technology to financial services and systems is
prudent given the significant potential of the technology.

2.1.3.4 Block chain Technology

Block chain is a distributed ledger in which transactions (e.g. involving digital currencies
or securities) are stored as blocks (groups of transactions that are performed around the
same point in time) on computers that are connected to the network. The ledger grows
as the chain of blocks increases in size. Each new block of transactions has to be
verified by the network before it can be added to the chain. This means that each
computer connected to the network has full information about the transactions in the
network. Block chain potentially has far-reaching implications for the financial sector, and
this is prompting more and more banks, insurers and other financial institutions to invest
in research into potential applications of this technology.
Frequently cited benefits of Block chain are its transparency, security and the fact that
transactions are logged in the network. Some of the disadvantages currently include the
lack of coordination and the scalability of this technology. One of the best-known
applications of Block chain technology at the present time is bitcoin. Transactions in this
virtual currency are largely anonymous. This creates ethical risks for financial institutions
dealing with users of this currency, because they are unable to (fully) verify their identity.
It has also been observed that market participants in other securities markets are
exploring the usage of Block chain or Distributed Database technology to provide various
services such as clearing and settlement, trading, etc. Indian securities market may also
see such developments in near future and, therefore, there is a need to understand the
benefits, risks and challenges such developments may pose.

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2.1.4 Deposits, lending and capital raising services
Alternative models of lending and capital raising are gaining prominence, potentially
changing the market dynamics of traditional lenders and affecting the role of traditional
intermediaries. A few examples of the products offered by FinTechs are as under:

2.1.4.1 Peer-to-peer (P2P) lending

Peer-to-peer (P2P) lenders connect lenders and borrowers, using advanced
technologies to speed up loan acceptance. These technologies are designed to increase
the efficiency and reduce the time involved in access to credit.
While P2P lending originally involved direct matching of individual lenders and borrowers
on a one-to-one basis, it has evolved into a form of marketplace lending where
institutional and high net worth individual investors lend into a pool that borrowers can
access.
P2P lending has grown rapidly over the past decade but remains small outside of the
United States, the United Kingdom, and China. P2P lending is estimated to have
recorded 123% compound annual growth (CAGR) globally from 2010-2014. Further,
global market for P2P lending is expected to grow at a CAGR of 60 per cent to USD 1
trillion by 2025 from USD 9 billion in 2014 6.

Depending on the structure, P2P may involve simple matching, deposit taking, or
management of a collective investment scheme. Since P2P lending companies operate
entirely online, they can run with lower overhead and provide services more cheaply than
traditional financial institutions. As a result, lenders often earn higher returns compared
to savings and investment products offered by banks, while borrowers can borrow

6
In the US, new P2P lending was USD 12 billion in 2014, (USD 7 billion in unsecured consumer loans and USD 5 billion in small
business loans). In the UK, P2P platforms originated about EUR 2.7 billion in 2015. Source: Morgan Stanley (2015) “Global
Marketplace Lending: Disruptive Innovation in Financials”. Source-Bloomberg
11
money at lower interest rates. The most common form of P2P loan is an unsecured
personal loan, but start-up and small-business loans are also becoming important.
The principal benefit of P2P lending for borrowers is the fast and convenient access to
funding, while for investors it is the potential for high returns.
In their current form, P2P platforms are different from banks, because they do not take
positions in loans and do not generally perform maturity and liquidity transformation like
banks. P2P platforms more directly match the risk appetite of lenders with the risk profile
of borrowers. These factors are likely to make P2P platforms less systemically important
than banks of comparable size.
The default of a bank can have systemic effects because of the many credit inter
linkages that a bank builds during its business of intermediating credit markets. This
creates the possibility of contagion should a single bank fail. The risk of such a contagion
is likely to be much less with the failure of a P2P platform because they do not have the
same network of credit inter-linkages. This would be true even if a P2P platform was very
large. In sum, P2P lending does not currently pose a systemic risk, and it is not clear
whether it would if the sector grew significantly larger.

2.1.4.2 Crowd funding

Crowd funding is a way of raising debt or equity from multiple investors via an internet-
based platform. Securities and Exchange Board of India (SEBI) has released a paper
and defined crowd funding as “solicitation of funds (small amount) from multiple investors
through a web-based platform or social networking site for a specific project, business
venture or social cause.” Some jurisdictions have chosen to enact special legislative
regimes to determine the conditions under which this service can be made available to
retail investors. The platform matches borrowers / issuers with savers/investors. Platform
providers offer a range of information about the potential borrowers/issuers, ranging from
credit ratings (for most peer-to-peer loan arrangements) to business model to verification
of information and AML checks of firms that want to raise equity capital. Though SEBI
had come out with a draft regulation on the subject, it has not issued the final guidelines.

2.1.5 Market provisioning services

Advances in computing power are facilitating faster and cheaper provision of information
and services to the market. A few of these innovations are discussed below:

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2.1.5.1 Smart contracts
Smart contracts are computer protocols that can self-execute, self-enforce, self-verify,
and self-constrain the performance of a contract. Development of smart contracts in
relation to financial services could have a large impact on the structure of trade finance
or derivatives trading, especially more bespoke contracts, and could also be integrated
into Robo-advice wealth management services. The widespread adoption of smart
contracts in financial services could be facilitated by the establishment of distributed
ledger technology.
2.1.5.2 E-Aggregators

E-Aggregators provide internet-based venues for retail customers to compare the prices
and features of a range of financial (and non-financial) products such as standardised
insurance, mortgages, and deposit account products. They can also be firms that provide
services that allow users to aggregate and analyse their data on their payment patterns,
across separate accounts and products (example-Yodlee). E-Aggregators also provide
an easy way to switch between providers and may become a major distributor for a
variety of financial products. Reserve Bank of India has issued directions regarding
Account Aggregators which requires that no entity other than a company can undertake
the business of an Account Aggregator, no company shall commence or carry on the
business as an Account Aggregator without obtaining a certificate of registration from the
RBI and every company seeking registration with the RBI as Non-Banking Financial
Company - Account Aggregator shall have a net owned fund of not less than ₹ two crore
or such higher amount, as the RBI may specify. Provided that, entities being regulated
by other financial sector regulators and aggregating only those accounts relating to the
financial assets of that particular sector will be excluded from the registration
requirement.

2.1.5.3 Cloud computing

Cloud-based IT services can deliver internet-based access to a shared pool of
computing resources that can be quickly and easily deployed. Infrastructure, Platform,
Service and Mobile backend as a service are offered under cloud based services. The
use of these services is an important enabler for new entrants to the financial services
arena to set up quickly and with low start-up cost, with easy options to expand their
capability as the firm grows. Depending on the type of services of the cloud service

13
availed, it can potentially pose several challenges including the ability of jurisdictional
enforcement authorities to effectively ensure security of data.

2.1.5.4 Big data

As more business activity is digitised, new sources of information are becoming
available. Combining these data sources with the availability of increased computing
power is delivering faster, cheaper, and more comprehensive analysis for better
informed decision-making. For example, wider use of increasingly large datasets could
deliver material improvements in credit risk assessments. Financial institutions may
desire to monetize aggregated data by selling them or bundling them with other products
and services offered.
2.1.5.5 Artificial Intelligence (AI) & Robotics
Companies looking to achieve a competitive edge through AI need to work through the
implications of machines that can learn, conduct human interactions, and engage in
other high-level functions at an unmatched scale and speed. They need to identify what
machines do better than humans and vice versa, develop complementary roles and
responsibilities for each, and redesign processes accordingly. AI often requires, for
example, a new structure, of both centralized and decentralized activities, that can be
challenging to implement. Finally, companies need to embrace the adaptive and agile
ways of working and setting strategy that are common at startups and AI pioneers. All
companies might benefit from this approach, but it is mandatory for AI-enabled
processes, which undergo constant learning and adaptation for both man and machine.

2.1.6 Investment management services

Automated systems have the potential to transform the business of investment
management. Few commonly used applications in investment management services are
discussed as under:

2.1.6.1 Robo advice

“Robo-advice” is the provision of financial advice by automated, money management
providers, thereby disintermediating human financial advisors and reducing costs. It can
offer more investor choice, especially for low and middle income investors who do not
have access to the wealth management divisions of the banks. Robo Advisors are said

14
to be currently handling assets under management estimated at $20bn 7 and such
business is growing rapidly. They use client information and algorithms to develop
automated portfolio allocation and investment recommendations that are meant to be
tailored (to a greater or lesser degree) to the individual client.
Robo advisors are regulated just like independent advisors who set up offices and meet
clients on a regular basis in USA. They typically register with the U.S. Securities and
Exchange Commission and are deemed "fiduciaries" who must put their clients' interests
above their own.

2.1.6.2 E-Trading
Electronic trading has become an increasingly important part of the market landscape,
notably in fixed income markets. It has enabled a pickup of automated trading in the
most liquid market segments. Innovative trading venues and protocols, reinforced by
changes in the nature of intermediation, have proliferated, and new market participants
have emerged. This, in turn, has had implications for the process of price discovery and
for market liquidity. It could also lead market structures to evolve from over-the-counter
to a structure where all-to-all transactions can take place. The development of e-trading
platforms contributes to improving the efficiency of market orders and to reducing
average trading costs 8.

2.2. FinTech and its impact on global financial services

2.2.1 Innovation and technology have brought about a radical change in traditional
financial services. The world has seen the emergence of more than 12,000 start-ups and
massive global investment of USD 19 billion in 2015 9 in the FinTech space. The global
FinTech software and services sector is expected to boom as a USD 45 billion 10
opportunity by 2020, growing at a compounded annual growth rate of 7.1% as per
NASSCOM.
2.2.2 Technological innovations compel banks to modify their way of doing business and
earnings models. Banks currently perform activities in several market segments, viz.,
payments services, raising deposits, lending, and investments, etc. These are segments

7
Fintech: Describing the Landscape and a Framework or Analysis by STANDING COMMITTEE ON ASSESSMENT OF
VULNERABILITIES of FSB-March 2016
8
CGFS, Fixed Income Market Liquidity, January 2016
9
The Pulse of Fintech, KPMG, 2016
10
India emerging a hub for Fintech start-ups, Business Standard, http://www.business-
standard.com/article/companies/india-emerging-a-hub-forFintech-start-ups-116051700397_1.html, 17 May 2016
15
where technological innovations will result in more high-grade products at lower prices. If
banks do not adopt them quick enough, innovation by rivals may put their business
models under pressure. Loss of consumer contact and fragmentation of the value chain
could then diminish banks’ ability to profit from the cross-selling market.
2.2.3 Global Technology players, viz., Apple, Google and Facebook that adopt
innovations effectively and carry technological innovation and new services across the
financial value chains. These companies displace existing financial institutions by
exploiting their scale and innovative capacity.
2.2.4 Technological innovation brings opportunities and risks. FinTech can increase
efficiency and diversity by boosting competition within the financial sector. This effect will
reduce market concentration and may lead to better services for consumers, in particular
as new technological processes often result in greater user-friendliness. This is in
particular relevant for the Indian banking sector. Moreover, innovative new entrants
provide an incentive for established financial institutions to become more competitive
and focus more on their customers.
2.2.5 A more diverse financial sector also reduces systemic risk by increasing the
heterogeneity between the risk profiles of market participants. In addition to creating new
opportunities, FinTech also carries potential risks for the financial sector. These include
risks to the profitability of incumbent market players as well as risks related to cyber-
attacks.
2.2.6 As the rise of FinTech leads to more and more IT interdependencies between
market players (banks, FinTech, and others) and market infrastructures, IT risk events
could escalate into a full-blown systemic crisis.
2.2.7 The entrance of new FinTech players has not only increased the complexity of the
system but has also introduced heightened IT risks for these players who typically have
limited expertise and experience in managing IT risks.

16
3. FinTech and its impact on Indian Financial Services

3.1 FinTech innovations, products and technology

India’s FinTech sector may be young but is growing rapidly, fueled by a large market
base, an innovation-driven startup landscape and friendly government policies and
regulations. Several startups populate this emerging and dynamic sector, while both
traditional banking institutions and non-banking financial companies (NBFCs) are
catching up. This new disruption in the banking and financial services sector has had a
wide-ranging impact.
In India, FinTech has the potential to provide workable solutions to the problems faced
by the traditional financial institutions such as low penetration, scarce credit history and
cash driven transaction economy. If a collaborative participation from all the
stakeholders, viz., regulators, market players and investors can be harnessed, Indian
banking and financial services sector could be changed dramatically. FinTech service
firms are currently redefining the way companies and consumers conduct transactions
on a daily basis.

The Indian FinTech industry grew 282% between 2013 and 2014, and reached USD 450
million in 2015. At present around 400 FinTech companies are operating in India and
their investments are expected to grow by 170% by 2020. The Indian FinTech software
market is forecasted to touch USD 2.4 billion by 2020 from a current USD 1.2 billion 11, as
per NASSCOM. The transaction value for the Indian FinTech sector is estimated to be
approximately USD 33 billion in 2016 and is forecasted to reach USD 73 billion 12 in
2020. The broad FinTech products/services offered in Indian financial markets are as
under Indian FinTech Industry

Payments Online Financial products

Payment Mobile Payment Payment Lending Insurance e-NPS

banks wallets gateway infrastructure
MF /
Broking

m POS
ATM
11
India emerging a hub for FinTech start-ups, Business Standard website, http://www.businessstandard.com/article/companies/india-
emerging-a-hub-for-FinTech-start-ups-116051700397_1.html, accessed on 25 May 2016.
12
Statista website, https://www.statista.com/outlook/295/119/FinTech/india, accessed on 25 May 2016, 17 May 2016
17
3.1.1 Peer-to-Peer (P2P) Lending Services

These companies use alternative credit models and data sources to provide consumers
and businesses with faster and easier access to capital, providing online services to
directly match lenders with borrowers who may be individuals or businesses. Examples
are Lendbox, Faircent, i2iFunding, Chillr, Shiksha Financial, Gyan Dhan, and Market
Finance.

3.1.2 Personal Finance or Retail Investment Services

Fintech companies are also growing around the need to provide customized financial
information and services to individuals, that is, how to save, manage, and invest one’s
personal finances based on one’s specific needs. Examples are FundsIndia.com,
Scripbox, Policy Bazaar, and Bank Bazaar.

3.1.3 Miscellaneous Software Services

Companies are offering a range of cloud computing and technology solutions, which
improve access to financial products and in turn increase efficiency in day to day
business operations. The scope of FinTech is rapidly diversifying at both macro and
micro levels, from providing online accounting software to creating specialized digital
platforms connecting buyers and sellers in specific industries. Examples include Catalyst
Labs in the agriculture sector, AirtimeUp which provides village retailers the ability to
perform mobile top ups, ftcash that enables SMEs to offer payments and promotions to
customers through a mobile based platform, Profitbooks (online accounting software
designed for non-accountants), StoreKey, and HummingBill.

3.1.4 Equity Funding Services

This includes crowdfunding platforms that are gaining popularity as access to venture
capital is often difficult to secure. These services are particularly targeted at early stage
business operations. Examples include Ketto, Wishberry, and Start51.

3.1.5 Crypto currency

India being a more conservative market where cash transactions still dominate, usage of
digital financial currency such as ‘bitcoin’ has not seen much traction when compared to

18
international markets. There are, however, a few bitcoin exchange startups present in
India – Unocoin, Coinsecure, and Zebpay.

3.1.6 Developments in Block chain Technology in India

Block chain, a seemingly unassuming data structure, and a suite of related protocols,
has recently caught the attention and spurred efforts of a number of domestic firms.
IDRBT has taken the initiative of exploring the applicability of BCT to the Indian Banking
and Financial Industry by publishing a White Paper detailing the technology, concerns,
global experiences and possible areas of adoption in the financial sector in India. In
order to gain first-hand experience of the implementation, the Institute has also
attempted a Proof-of-Concept (PoC) on the applicability of BCT to a trade finance
application with active participation of NPCI, banks and solution provider, the details of
which are presented in the White Paper 13.
The results of the PoC have been quite encouraging, giving comfort and confidence in
the implementability of BCT in the Indian financial sector. The PoC provided a good
insight into the workings of the Blockchain eco-system demonstrating the following key
aspects:
• Complete transparency of various events triggered by various counter-parties
• Immutability/Tamper-Evidence
• Automated flow triggered by the occurrence of specific events.
• Private distributed ledger

The IDRBT White paper has suggested a phased adoption of BCT by the Indian banking
system, the stages of which are as follows:
i. Intra-bank usage of BCT
Banks may setup a private Blockchain for their internal purposes. This not only helps
them to train human resources in the technology, but also benefits by enabling efficient
asset management, opportunities for cross-selling, etc.
ii. Inter-bank usage of BCT
Proof-of-Concept implementation and testing may be carried out in the following order of
increasing application complexity – mainly because of the number of stakeholders
involved in the transaction.

13
Application of Blockchain Technology in Indian banking and financial sector by IDRBT-January 2017
19
Centralized KYC: Secure, distributed databases of client information shared between
institutions helps reduce duplicative efforts in customer onboarding. Secure codification
of account details could enable greater transparency, efficiency in transaction
surveillance and simplify audit procedures.
Cross-Border Payments: BCT enables real-time settlement while reducing liquidity and
operational costs. Transparent and immutable data on BCT reduces fraudulent
transactions. Smart contracts eliminate operational errors by capturing obligations
among FIs to ensure that appropriate funds are exchanged. BCT allows direct interaction
between sender and beneficiary banks, and enables low value transactions due to
reduction in overall costs.
Syndication of loans: Underwriting activities can be automated, leveraging financial
details stored on the distributed ledger. KYC requirements can also be automatically
enforced in real-time. BCT can provide a global cost reduction opportunity within the
process execution and settlement sub-processes of syndicated loans.
Trade Finance: BCT usage for Trade finance enables automation of LC creation,
payment against documents, development of real-time tools for enforcing AML and
customs activities, and associated cost savings.
Capital markets: BCT brings the following advantages in the clearing and settlement
processes: reducing or eliminating trade errors, streamlining back office functions, and
shortening settlement times.
Further areas where BCT can be applied advantageously in BFSI sector would be
Supply-chain finance, Bill discounting, Monitoring of consortium accounts, Servicing of
securities and Mandate management system.
Use cases of BCT banking operations in India
A few banks in India in the recent past have reported successful use of BCT in their
operations, especially in the areas of trade finance, international remittances, etc. and
reported that this has potential to be used in larger scale in many operations of their
bank.
Unlike regular trade transactions where documents are authorized and physically
transferred, in a block chain transaction all parties can view the authorization live. A key
feature is that the records cannot be tampered and any changes can be introduced only
by creating a fresh entry. Besides eliminating the need for moving paper across
countries, the transaction eliminates the need for financial messaging between banks
20
and introduces the convenience of instant cross-border remittances for retail
customers. Examples- SBI, Axis Bank, ICICI Bank, etc.
3.1.7 Developments in Payments landscape in India

Fintech enablement in India has been seen primarily across payments, lending,
security/biometrics and wealth management. The modes of payments in India have
leapfrogged from cash to alternate modes of payments registering phenomenal growth.
The innovations have happened in all spheres - from common USSD channel access
through NUUP, Immediate Payment Service (IMPS) – initiation of transactions through
various options for real-time payments to end customer, with the latest being the Unified
Payments Interface (UPI). Some of the developments in this regard are discussed below.

3.1.7.1 Fast Payments

Leveraging on the high mobile density in India, with a population of more than one billion,
many PSPs utilize mobile payment apps to link underlying payment instruments with
mobile phone numbers for fast payments via the Immediate Payment Service (IMPS) or
for issuance of m-wallets. The Unified Payment Interface (UPI) developed by NPCI
provides complete interoperability for merchant payments as well as P2P payments. The
UPI enables users to link their bank accounts with their mobile phone numbers through
an application provided by the payment service providers (PSPs) and obtain a virtual
address which can be used for making and receiving payments. Introduction of UPI has
the potential to revolutionize digital payments and take India closer towards being a
“Less Cash” society.

3.1.7.2 Process Innovation

With the nation-wide implementation of Aadhaar, providing a unique identification

number to all residents of India, NPCI has launched an Aadhar Enabled Payment
System (AEPS) that is a safe and convenient channel enabling micropayments with
every transaction validated by biometric authentication. In a further impetus to digital
innovations, Unique Identification Authority of India (UIDAI) in collaboration with TCS
plans to roll out an Android-based Aadhaar-Enabled Payment System (AEPS). The
application can be downloaded by merchants on a smartphone and would require a
fingerprint scanner to use it. The application is intended to facilitate undertaking
transactions without any Card or PIN.
21
3.1.7.3 Wallets

The traditional modes to make payments include cheque, electronic payment modes viz.,
NEFT, RTGS, etc. and card (debit and credit) payments. The need for prepaid payment
instruments in the form of physical card or e-wallet was felt to give non-bank customers
the facility to use electronic modes of payments and give existing bank customers a
safeguard measure that limits the extent to which they are exposed. The emergence of
bank (State Bank Buddy, Citi MasterPass, ICICI Pockets) and non-bank (PayTM,
Mobikwik, Oxigen, Citrus Pay, etc.) payment wallets in India has changed the landscape
of payments. Many start-ups have entered the space to simplify mobile money transfer,
such as Chillr application, which provides peer-to-peer money transfer without using
bank account details. Several leading banks have launched their own digital wallets
leveraging NPCI’s IMPS platform. These digital wallets are integrated with social media
features as well. Digital Innovators are also promoting the Online to Offline (O2O) model
to facilitate digital payments at local stores.

3.1.7.4 BHIM (Bharat Interface for Money)

BHIM is a mobile app developed by NPCI, based on the Unified Payment Interface (UPI)
and was launched on 30 December 2016. It is intended to facilitate e-payments directly
through banks and as part of the drive towards cashless transactions. BHIM allow users
to send or receive money to other UPI payment addresses or scanning QR code or
account number with IFSC code or MMID (Mobile Money Identifier) Code to users who
do not have a UPI-based bank account. BHIM allows users to check current balance in
their bank accounts and to choose which bank account to use for conducting
transactions, although only one can be active at any time. Users can create their own
QR code for a fixed amount of money, which is helpful in merchant transactions.

3.2 Innovations in digital banking and investment services in India

3.2.1 Innovation in retail financial services
The form of Retail Financial Services is completely dictated by consumers and as they
evolve so will retail financial services. Hence innovation is not a luxury anymore, it's a
necessity. More importantly we are also seeing the advent of nimble startups, which are
slowly and steadily changing how retail financial services are delivered to the consumers
and hence putting pressure on traditional banks to take notice and align their functioning
accordingly. It is therefore extremely important for banks to innovate in the retail financial
22
services space in tune with the changing times or else there is a grave risk of their
becoming less relevant to existing customers.

3.2.2 Innovation in Mobile Banking Services

Mobile banking companies have come a long way. Innovation in mobile banking has
grown in sophistication, using advanced technologies such as touch and voice
capabilities and machine learning algorithms. Mobile banking innovators focus on
enabling customers to bank the way they want to with minimum limitations, using mobile
banking apps.

3.2.3 Innovation in Financial Services though Digital Banking

3.2.3.1 Customers are rapidly adopting technology in their daily lives driven by the
growth in internet and mobile penetration, availability of low cost data plans and shift
from offline to online commerce. Banks are keeping abreast of their evolving needs and
behavior and have enabled access to a wide range of banking and financial services
through different digital platforms. Banks in India are putting in place robust foundations
for digital infrastructure and are innovating using digital technologies across all channels
to deliver the power of speed and convenience to all customer segments across urban
and rural markets. Some incumbents, in order to defend market share, have
encouraged the development of a whole ecosystem of digital banking products and
services built upon their infrastructure.
To cater to the fast changing expectations of customers, constant development of new
products and services and enhancements, a dedicated focus on digital innovation is of
prime importance. Innovation objectives to be identified early on and well-articulated by
banks aspiring for a leadership position in the entire value chain. There was a time when
cost leadership and service range leadership offered differentiation; however, the way to
maintain sustainable leadership going forward will be 'experience leadership' through
customer-driven Innovation.

3.2.3.2 Banks thus need to have dedicated resources, both people as well as
infrastructure, to form an agile innovation unit, with a view to position themselves at the
forefront of digital innovations amidst changing customer expectations and sea-change
in the competitive landscape.

23
3.2.3.3 Now that digital innovation practice has reached a critical mass, banks are
shifting gears to create a stronger innovation culture via the Internal Social Collaboration
platform and adopting cutting edge technologies like Artificial Intelligence, Block Chain
and Internet of Things (IOT), among others. Customers are taken into a new world of
multi-channel banking, where they can access services from home, at the office, or on-
the-go through Mobile Banking, SMS Banking, Phone Banking, ATMs and Net Banking.

3.2.3.4 Managing investments for Private Banking clients is now simpler and faster.
Clients can now easily access research reports both online and on mobile via the apps,
capitalize on investment opportunities quickly through Net Banking and Mobile Banking,
and track investments using investment tracking apps. The focus on making customers
accomplish more comes with the assurance that the services are secure and protected.
Banks have set up a Digital Security infrastructure which works with other teams to
monitor and set up new security enhancements.

3.2.3.5 Some banks in India are proposing to form a block chain consortium along with
other global banks such as SBI, Citi, Deutsche, JP Morgan, Nomura, HSBC, UBS,
Barclays, Bank of America, BNP, RBS, Macquarie, Westpac, etc.

3.2.3.6 Some of the banks are also collaborating with Indian IT service providers in areas
of voice enabled system for the customers to open new accounts on the basis of
Aadhaar authentication.

3.2.3.7 Banks are also collaborating with IT service providers for e-Sign(digital signature)
facility to help digitally signing the loan documents. This will help in faster approval
process, lesser paper work and lesser paper storage space.
3.2.3.8 Some of the innovations and related initiatives taken by Indian banks in
collaboration with FinTech start-ups/academia and other service providers in the recent
past are SBI FinTech IPDaaS Software Developed with IIT-KGP; Zing HR using
Microsoft AI; Digital Village; cross border remittances, etc. Such start-ups are listed in
Annex-1.

3.2.4 Innovations in branch banking through Intelligent Robotic Assistant

AI and robotics have the potential to transform data analytics and customer experience
in banking. Until recently, application of robotics was unheard of in banking and was
considered for application primarily in the manufacturing & medical sectors. With use of
24
Intelligent Robotic Assistant (IRA), robotics are being brought into the mainstream of
customer service and support. IRA is designed to assist branch staff in large branches,
which have high footfalls, by guiding customers to carry out their banking transactions. AI
is becoming an integral part of the banking system, functions, processes and customer
interactions. Both Robotics and AI will help banks manage both internal and external
customers much more effectively and help reduce operational costs exponentially in the
future. The potential of AI and Robotics based solutions is enormous and will
revolutionize the way people do banking.
Digital transformation and innovation in the BFSI space will ride on three pillars -
BlockChain, Artificial Intelligence and Internet of Things. It is said that 'technology
becomes truly useful when it becomes invisible'. With the onset of interconnected
devices riding on a self-learning and evolving AI and BlockChain keeping a track of each
and every transaction, banking will no longer be just apps, websites or physical
branches. Widespread adoption of biometric authentication and AI based voice enabled
financial services and advisory may make banking relatively 'invisible'.
However, a strong caveat here is that ideas are not good enough. There has to be a
strong focus on execution. Buzz words on innovation have to progress to functional use
cases, and be implemented to create true value.
With the change that banking has seen in the last 20 years, it is difficult to say how it'll
look like in the future. Although the essence of banking, which is collecting money from
those who have surplus savings and using it to lend to those who need it, will remain
unchanged, what the customers and the bank staff will experience may be transformed
by FinTech.

It is believed that banking will not be just about saving, spending or servicing
transactions. It will be about banks acting as the alter ego of their customers, aiming to
maximize their wealth and meet their financial needs seamlessly. Financial advisory,
Investment Management, facilitating commerce on both borrower and lender side will
take center stage and, taking a futuristic view, the entire value chain will be about
“Automation (Blockchain – Robotics Process Automation), Experience (Artificial
Intelligence, NLP & Language support) and Assistance (Humanoids, Holographic
Banking & Robo-advisory).

25
3.2.5 Innovation in Investment services
Technology plays an important role and brings efficiency in terms of cost, reduction in
turnaround time, increasing the reach, anytime availability to the clients, etc. Towards
this the mutual funds industry has adopted technology and the use of same is increasing
day by day. Product manufacturers, i.e. individual mutual funds/asset management
companies (AMCs) are providing online facilities by which investors can subscribe,
redeem and monitor their portfolio by logging onto their websites. AMCs have integrated
the online processes with payment systems which enable investors to make seamless
payment. Some of the AMCs have also developed mobile applications for investors to
access their portfolio through smart phones.

Further, Mutual Fund Distributors (MFDs) have also adopted technology in distribution of
mutual funds. There are distributors such as Scripbox, FundsIndia, MyUniverse,
ArthaYantra, etc, who operate only in the online space and cater to the tech savvy
investors. The processes like onboarding of investors, risk profiling, analysis of their
portfolio, recommendation of schemes, asset allocation, rebalancing of portfolio etc. are
online and driven by technology.

With an objective to use technology in an innovative manner so that an investor can

transact seamlessly in a presence-less and paperless manner, SEBI has engaged with
various stakeholders of industry to leverage the advancement in technology and
digitalize the whole process of investment in securities market. After involving UIDAI and
all stakeholders, SEBI has issued instructions on Aadhaar based e-KYC, which has
made onboarding of a new investor in securities market (especially in mutual funds)
totally paperless and presence-less.

3.3 Scope for Growth of FinTech and digital banking in India

India has a large untapped market for financial service technology startups as 40 percent
of the population are currently not connected to banks and 87 percent of payments are
made in cash. With mobile usage expected to increase to 64 percent in 2018 from 53
percent currently, and internet penetration steadily climbing, the growth potential for
FinTech in India cannot be overstated. Moreover, by some estimates, as much as 90
percent of small businesses are not linked to formal financial institutions. These gaps in
access to institutions and services offer important scope to develop FinTech solutions
(such as funding, finance management) and expand the market base.

26
4. Regulatory Initiatives: Recent global regulatory Initiatives on FinTech
4.1 Global experiences on regulatory actions

FinTech or digital innovations have emerged as a potentially transformative force in the

financial markets. A recent FSB study highlighted some of the potential benefits of
FinTech, including efficiency improvements, risk reduction and greater financial
inclusion. The study also identified some of the key challenges associated with FinTech,
such as difficulty of regulating an evolving technology with different use cases,
monitoring activity outside the regulated sector, and identifying and monitoring new risks
arising from the technology.
The developments in increasing digitization in banking present regulatory and
supervisory challenges for several reasons. First, financial technology is increasing the
channels for provision of finance, both from banks and non-banks (e.g. platform-based
lending). Second, technological innovation is affecting existing bank business models,
which in turn could undermine their overall business strategies. Third, the rise of FinTech
may lead to fundamentally different bank risk profiles. In this regard, best practices and
principles for the management and supervision of risks arising from financial technology
are much needed.
Financial innovation has become a focal point for a lot of attention from regulators, and
some jurisdictions have decided to take a more active approach in facilitating this
innovation. To do this, they have put in place a variety of regulatory and supervisory
initiatives such as regulatory sandboxes, innovation hubs or teams, innovation
incubators or accelerators, etc.
Regulatory uncertainty surrounding FinTech could potentially hamper its development.
As a result, international standard setting bodies (BCBS, FSB, CPMI, WBG, etc.)
including regulatory authorities of different jurisdictions are taking steps to actively
monitor FinTech developments both domestically and in cooperation with international
organizations. Some developments in this regard are as under:

4.1.1 Basel Committee on Banking Supervision (BCBS):

BCBS has set up a Task Force on FinTech (TFFT) to identify and assess the risks
arising from the digitalisation of finance with a focus on the impact of financial technology
on banks’ business models, the provision of finance and systemic risk, as well as
associated supervisory challenges. The Task Force has been mandated to investigate
27
the impact of FinTech on banks and the implications for banking regulation and
supervision. The work of the TFFT will involve initial mapping of the FinTech industry and
technologies, in order to gain a general understanding of the major innovations and how
banks are adopting new technologies. The second phase will involve a scenario-analysis
of the potential impact of FinTech on the banking industry, as well as ‘deep dive’ case
studies of specific technologies and their banking application. The third phase will aim to
assess risks for banks and any implications for supervision, with a view to making
recommendations on how the Committee should proceed, based on the information
collected.

4.1.2 Financial Stability Board (FSB)

FSB has set up a task force named Financial Innovations Network (FIN) for the
assessment of FinTech, inter alia recommending that innovations be examined through
the lens of authorities’ and Secretarial Standards Board’ (SSB) responsibilities. BCBS
and the FSB have conducted a joint survey of their members’ FinTech-related activities,
including the use of regulatory sandboxes and innovation hubs.
FSB has considered the financial stability implications of distributed ledger technology,
and continues to work in this area, jointly with Committee on Payments and Market
Infrastructures (CPMI), to identify key issues that market participants and policymakers
need to address. FSB is conducting an in-depth study of the financial stability
implications of peer to peer lending with the BIS’ Committee on the Global Financial
System.
FSB is currently undertaking a study of the key elements underlying the broad swath of
FinTech innovations and examining the financial stability implications of those elements.
That work has identified three elemental 'promises' common to a broad range of FinTech
innovations 14: (i) greater access to and convenience of financial services, (ii) greater
efficiency of financial services, and (iii) to push toward a more decentralised financial
system, in which FinTech firms may be disintermediating traditional financial institutions.
4.1.3 Committee on Payments and Market Infrastructures (CPMI)
CPMI is also looking at digital innovations as well as “FinTech” developments and their
implications for payments and market infrastructures. The CPMI is continuing to monitor
developments and evolution of digital currency schemes and their wider implications. To
14
http://www.fsb.org/wp-content/uploads/Chatham-House-The-Banking-Revolution-Conference.pdf

28
focus its activities, the CPMI has established a dedicated Working Group to look at the
impact of digital innovations and to analyse the implications of such innovations on
payment services and systems, having particular regard to the technical and
infrastructure aspects of products and services based on innovative technologies, such
as block chain and distributed ledgers.

4.1.4 European Commission

The European Commission in November 2016 launched a Task Force on Financial
Technology (TFFT) that aims to assess and make the most of innovation in this area,
while also developing strategies to address the potential challenges that FinTech poses.
The work of this Task Force builds on the Commission's goal to develop a
comprehensive strategy on FinTech.

4.1.5 World Bank Group

The World Bank participates actively in SSB work streams relevant to FinTech. The
WBG works with national authorities to put in place enabling frameworks for adoption of
technology, market entry/level playing fields, and expansion of financial access – as
technical, policy, or financing partner IFC: investments, risk-sharing, also dialogue with
private sector players in this space e.g. through SME Finance Forum. 15

4.2 Regulatory Sandboxes / Innovation Hub

4.2.1 Innovation Hubs
Support, advice or guidance provided to regulated or unregulated firms in navigating the
regulatory framework or identifying supervisory, policy or legal issues and concerns is
generally termed as ‘innovation hub’. Some of the key benefits of having an innovation
hub are:
• Reduce regulatory uncertainty.
• Reduce the time it takes to bring an innovative product to market.
• Support innovators by providing needed services.
• Improve access to supervisory authorities for financial market operators by
creating a central point of contact.

15
http://pubdocs.worldbank.org/en/877721478111918039/breakout-DigiFinance-McConaghy-FinTech.pdf

29
 • Play an active role as a catalyst for promoting interaction among financial
practices and innovative technologies, research and study, and the needs of the
economic society.

4.2.2 Regulatory Sandbox

Live or virtual testing of new products or services, in a (controlled) testing environment,
with or without any ‘regulatory relief’ is termed a ‘sandbox’. The testing environment
could be available to regulated or unregulated firms, or both. Regulator provides the
appropriate regulatory support by relaxing specific legal and regulatory requirements,
which the sandbox entity will otherwise be subject to, for the duration of the sandbox.
4.2.3 Benefits of Sandbox
Sandboxes appear to offer a number of benefits. Users of a sandbox can test the
product’s viability without the need for a larger and more expensive roll out. If the product
appears to have the potential to be successful, the product might then be authorized and
brought to the broader market more quickly. Finally, if concerns are unearthed while the
product is in the sandbox, appropriate modifications can be made before the product is
launched more broadly.
4.2.3.1 The objective of Sandbox
Sandbox should help to encourage more FinTech experimentation within a well-defined
space and duration where regulators will provide the requisite regulatory support, so as
to increase efficiency, manage risks better and create new opportunities for consumers.
4.2.3.2 Eligible Applicant for Sandbox
Regulators need to specify the target audience which may include existing financial
institutions, FinTech firms, and professional services firms partnering with or providing
support to such businesses, etc. The applicant should clearly understand the objective
and principles of the sandbox.
4.2.3.3 Criteria for joining the sandbox
The proposed financial service to be launched under the sandbox should include new or
emerging technology, or use existing technology in an innovative way. The proposed
financial service should address a problem, or bring benefits to consumers or the
industry. The criteria should also specify the following parameters:
• Type of innovation, product
• Who can apply for the sandbox (e.g. only start up or also incumbents)?
30
 • Are there any limitations regarding the number of participants?
• What is the authority's timeframe for the approval of application?

4.2.3.4 Boundary conditions for the sandbox and evaluation criteria

When a sandbox operates in the production environment, it must have a well-defined
space and duration for the proposed financial service to be launched, within which the
consequences of failure can be contained. The appropriate boundary conditions should
be clearly defined, for the sandbox to be meaningfully executed while sufficiently
protecting the interests of consumers and maintaining the safety and soundness of the
industry.
Regulators creating the sandbox should specify the following:
• Start and end date of the sandbox
• Target customer type
• Limit on the number of customers involved
• Other quantifiable limits such as transaction thresholds or cash holding limits
• Associated risk disclosure for participating in the sandbox

4.2.3.5 Exit Strategy

An acceptable exit and transition strategy should be clearly defined in the event that the
proposed financial service has to be discontinued, or can proceed to be deployed on a
broader scale after exiting the sandbox. There should also be an exit plan to ensure a
smooth exit from the market in case sandbox participant fails.
4.2.3.6 Consumer protection
The sandbox entity should ensure that any existing obligation to its customers of the
financial service under experimentation must be fully fulfilled or addressed before exiting
or discontinuing the sandbox.
4.2.3.7 Regulatory requirements to be followed by the Sandbox applicants
Applicants for sandbox must comply the following regulatory requirements to ensure the
interests of consumer and safety and soundness of the financial sector:
• Confidentiality of customer information
• Fit and proper criteria
• Handling of customer’s moneys and assets by intermediaries
• Prevention of money laundering and countering the financing of terrorism

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 • Number of customers
• Transaction volume
• Specific customer groups
• Information to customer

4.2.3.8 Facilities generally granted to sandbox participants

Possible regulatory relaxation that may be considered by the regulators for sandbox are
as under:
4.2.3.8.1 Quantitative prudential requirements
 Statutory / Liquidity requirements
 Minimum paid-up capital
 Capital adequacy
 Licence fees
 Financial soundness

4.2.3.8.2 Corporate governance

 Board composition
 Management experience
 Fit and proper criteria

4.2.3.8.3 Risk management

 Technology risk management,
 Outsourcing guidelines, etc.

4.2.4 Regulatory Sandbox/Innovation hubs created in other jurisdictions:

4.2.4.1 Australia
Australian Securities and Investments Commission (ASIC) released a detailed regulatory
framework during May 2016 on innovation hub/sandbox allowing eligible FinTech
businesses to test certain specified services without holding an Australian financial
services (AFS) or credit licence. This allows eligible businesses to notify the regulator
and then commence testing without an individual application process. There are five
elements in the said framework as discussed under:
I. The first element is engagement with other FinTech initiatives, including physical
hubs and co-working spaces for start-ups. ASIC makes senior ASIC staff
available from time to time to present information and answer questions.

32
 II. The second element is informal guidance from ASIC to help new businesses
consider the important regulatory issues. Eligible businesses can request
guidance from ASIC through its website. ASIC expects that this guidance will
minimise the time and cost of applying for a licence or relief from the law.
III. Thirdly, ASIC has established new ‘Innovation Hub’ webpages for innovative
businesses to access information and services targeted at them.
IV. The fourth element is a senior internal taskforce to coordinate the work on new
business models. The taskforce draws together learnings and skills from across
ASIC.
V. The final element is the Digital Finance Advisory Committee (DFAC) that meets
quarterly, which was established to advise ASIC on its efforts in this area. DFAC
members are drawn from a cross-section of the FinTech community, as well as
academia and consumer backgrounds. Other financial regulators are observers
on DFAC.

4.2.4.1.1 Eligibility criteria for Sandbox

The FinTech entities willing to provide financial services are exempted from licensing
subject to the following conditions:
• Banned from engaging in credit activities
• Already hold a credit licence
• Already be a credit representative of a credit licensee
• A related body corporate of a credit licensee

4.2.4.1.2 Boundary conditions

Boundary conditions for participants in the sandbox are:
- Have no more than 100 retail clients (unlimited wholesale clients)
- Plan to test for no more than 12 months
- Have total customer exposure of no more than USD 5 million
- Have a maximum annual rate of interest at 24%
- Have adequate compensation arrangements
- Have dispute resolution processes in place
- Meet disclosure and conduct requirements

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4.2.4.1.3 Consumer protection:
FinTech entities are required to maintain adequate compensation arrangement and
register with an External Dispute Resolution (EDR) scheme in order to provide
consumers with an outlet to settle disputes with sandbox business. The entities need to
comply with key consumer protection provisions in the financial services and credit laws.
FinTechs are required to tell their clients that:
(a) they do not hold a licence;
(b) the service they will provide is being tested under the FinTech licensing exemption
(c) some of the normal protections associated with receiving services from a licensee will
not apply.

4.2.4.1.4 Dispute resolution framework

To rely on the FinTech licensing exemption, FinTechs must also have in place a dispute
resolution system that consists of:
(a) Internal dispute resolution (IDR) procedures
(b) Member of one or more ASIC-approved external dispute resolution (EDR) schemes.

4.2.4.1.5 ASIC Role:

ASIC retains the right to refuse or withdraw relief and may give a person a written notice
that they cannot rely on the FinTech licensing exemption, due to concerns about poor
conduct while relying on the exemption; failure to meet one or more of the conditions of
relief; or previous misconduct.

4.2.4.1.6 Next step after the testing period

After the 12-month testing period ends, FinTechs are required to cease their operations,
unless granted an AFS or credit licence; or have entered into an arrangement to provide
services on behalf of an AFS or credit licensee; given the individual relief extending the
testing period. Further, after the end of the testing period, FinTechs will no longer be able
to offer financial services or engage in credit activities unless they comply with the law
like other businesses.

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4.2.4.1.7 FinTech set up in ASIC
ASIC has created the Innovation Hub/Sandbox with 2-3 staff sourced from its various
functions.

4.2.4.1.8 International co-operation/MOU and agreement

ASIC has an innovation hub agreement with the UK's FCA Innovation Hub during March
2016. ASIC has also entered into an agreement with Singapore's MAS to help innovative
business to expand in each other’s market faster during June 2016.

4.2.4.2 Financial Conduct Authority (FCA), UK, Regulatory Sandbox

FCA, UK has introduced a regulatory sandbox during June 2016. The sandbox aims to
create a ‘safe space’ in which businesses can test innovative products, services,
business models and delivery mechanisms in a live environment without immediately
incurring all the normal regulatory consequences of engaging in the activity in question.
The proposal is directed at authorised and unauthorised firms of both small and large
scale.
The sandbox contributes to achieving the FCA’s competition objective by lowering
barriers to entry (e.g. reducing time-to-market for innovative ideas), enabling greater
access to finance for innovators, and enabling more products to be tested and potentially
introduced to the market. Currently the FCA sandbox is running on a cohort approach.
There was a two month period (May to June 2016) for firms to apply to the first cohort
which aims to carry out testing activities around October 2016. The selection process is
a competitive process. Based on the eligibility criteria, FCA may select the appropriate
firms to join the sandbox. After a firm is chosen to enter the sandbox, FCA would work
on a detailed testing proposal and the issuance of one or more of the tools the sandbox
offers. Currently there are no extra charges or fees for firms which want to use the
sandbox. Standard fees however might apply for the authorisations process.
Deposit taking is excluded from the sandbox proposal and restricted authorisation option
is not available to firms looking for a banking license. The sandbox may be useful for
firms who are not currently authorised that need to become authorised before being able
to test their innovation in a live environment.

35
The second cohort was opened for applications from around November 2016 to mid-
January 2017.
4.2.4.2.1 Eligibility criteria for Sandbox
The key requirements for applying the sandbox are that is the applicant has a genuine
innovation that addresses a consumer need. To conduct a regulated activity in the UK,
the firm must be authorised or registered by the FCA, unless certain exemptions apply.
Firms who are accepted into a cohort will need to apply for the relevant authorisation or
registration in order to be able to test. The FCA has set up a tailored authorisation
process to work closely with firms accepted into the sandbox to enable them to meet
these requirements. Any authorisation or registration will be restricted to allow firms to
test only their ideas as agreed with the FCA. The process should make it easier for firms
to meet their requirements and reduce the cost and time to get the test up and running.
The evaluation criteria by FCA for FinTech entities are as under:
i. Is the firm looking to deliver innovation which is either regulated business or
supports regulated business in the UK financial services market?
ii. Does the firm have a UK nexus and is it related to financial services?
iii. Is it a genuine innovation? Is the innovation ground-breaking or constitutes a
significantly different offering in the marketplace?
iv. Is there consumer benefit? Does the innovation offer a good prospect of
identifiable benefit to consumers?
v. Is there a need for a sandbox?
vi. Does the business have a genuine need to test the innovation on real customers
and in the FCA sandbox? Which tool is suitable for testing and why?
vii. Is the firm ready for testing? Is the business ready to test their innovation in a live
environment?

4.2.4.2.2 FCA Role:

The FCA Sandbox offers four different tools to create the safe space for firms as listed
under:
I. Restricted authorization
II. Individual guidance
III. Waivers or modifications to rules
IV. No enforcement action letters
36
For non-FCA authorized firms, FCA has set up a limited authorization process that
allows firms to meet the requirements necessary for sandbox purposes only. Upon
successful completion of the sandbox, such firms can apply to have their limited FCA
authorizations converted into full authorizations. Technology businesses that seek to
provide services to FCA authorized firms can also apply for the sandbox and the above
tools if they need clarity around applicable rules before testing.
4.2.4.2.3 Consumer Protection
Safeguards exist against potential customer detriment when innovative financial products
or services are tested in real life situations. Approaches taken to protect consumers
include:
• Customers give informed consent to be included in testing, and they are notified
of the potential risks and available compensation
• FCA agrees on a case-by-case basis the disclosure, protection and compensation
appropriate to the testing activity
• Customers have the same rights as customers who engage with other authorised
firms
• Businesses undertaking sandbox trials are required to compensate any losses to
customers and must demonstrate that they have the resources (capital) to do that
• Consumers will have Financial Ombudsman Service (FOS) and Financial
Services Compensation Scheme (FSCS) protection provided that the tested
solutions fall within their jurisdiction.
• The parameters for sandbox activities will have to take into account that testing
should not cause risks to the financial system (i.e. the scale of testing has to be
limited).
• FCA may consider propositions where they are satisfied that there is a
prospective direct or indirect consumer benefit
• Every sandbox firm is required to have a fair exit strategy for consumers.

4.2.4.2.4 Next Step on completion of testing period

Following completion of sandbox testing, the FCA will work with participants to determine
the most appropriate strategy for next steps.

37
4.2.4.2.5 International co-operation/MOU and agreement
FCA Innovation Hub has an innovation hub agreement with the ASIC, Australia
Innovation Hub during March 2016. The UK (HM Treasury and the FCA) and Singapore
(MAS) concluded a “FinTech Bridge” agreement. The agreement will enable the
regulators to “refer” FinTech firms to each other. According to the FCA and the MAS, the
agreement also sets out how the regulators plan to share and use information on
financial services innovation in their respective markets.

4.2.4.3 Monetary Authority of Singapore (MAS), Singapore

MAS has introduced a regulatory sandbox during June 2016. Financial institutions (FIs)
in Singapore are free to launch new solutions without first seeking its guidance, as long
as they are satisfied with their own due diligence and there is no breach of legal and
regulatory requirements. MAS published its final “regulatory sandbox” guidelines during
November 16, 2016 to encourage and enable experimentation of solutions that utilise
technology innovatively to deliver financial products or services. The Sandbox would be
deployed and operated by the applicant, with MAS providing the appropriate regulatory
support by relaxing specific legal and regulatory requirements, which the applicant would
otherwise be subject to, for the duration of the Sandbox. The guidelines aim to improve
the clarity, flexibility and transparency of the regulatory sandbox. The Sandbox is
applicable to both FIs and FinTech companies.

4.2.4.3.1 Objective of Sandbox

MAS aims to transform Singapore into a smart financial centre by encouraging the
adoption of innovative and safe technology in the financial sector. To this end, the
sandbox can help to encourage more FinTech experimentation within a well-defined
space and duration where MAS will provide the requisite regulatory support, so as to
increase efficiency, manage risks better, create new opportunities and improve people’s
lives.

4.2.4.3.2 FinTech set up

The MAS formed the FinTech and Innovation Group (FTIG) in August 2015 in order to
drive the Smart Financial Centre initiatives. The FTIG is led by a Chief FinTech Officer
and consists of three offices, namely Payments & Technology Solutions Office,

38
Technology Infrastructure Office and Technology Innovation Lab. The group is
responsible for formulating regulatory policies and developing strategies to facilitate the
use of technology and innovation to better manage risks, enhance efficiency, and
strengthen competitiveness in the financial sector.

4.2.4.3.3 Criteria for joining the sandbox

The major criteria for evaluation to join the sandbox are as under:
a. The proposed financial service includes new or emerging technology, or uses existing
technology in an innovative way
b. The proposed financial service addresses a problem, or brings benefits to consumers
or the industry
c. The applicant has the intention and ability to deploy the proposed financial service in
Singapore on a broader scale after exiting the sandbox
d. The test scenarios and expected outcomes of the sandbox experimentation should be
clearly defined
e. The sandbox entity should report to MAS on the test progress based on an agreed
schedule
f. The appropriate boundary conditions should be clearly defined, for the sandbox to be
meaningfully executed while sufficiently protecting the interests of consumers and
maintaining the safety and soundness of the industry
g. Significant risks arising from the proposed financial service should be assessed and
mitigated
h. An acceptable exit and transition strategy should be clearly defined
4.2.4.3.4 Time frame for regulatory approval
MAS will review the application and inform the applicant of its potential suitability for a
sandbox within 21 working days after receiving the required information.
4.2.4.3.5 Boundary conditions for the sandbox and evaluation criteria
Given that the sandbox would operates in the production environment, it must have a
well-defined space and duration for the proposed financial service to be launched, within
which the consequences of failure can be contained. The appropriate boundary
conditions set by MAS are as under:
• Target customer type
39
 • Limit on the number of customers involved
• Other quantifiable limits such as transaction thresholds or cash holding limits
• Associated risk disclosure for participating in the sandbox

4.2.4.3.6 Exit Strategy

An acceptable exit and transition strategy should be clearly defined in the event that the
proposed financial service has to be discontinued, or can proceed to be deployed on a
broader scale after exiting the sandbox. There should also be an exit plan to ensure a
smooth exit from the market in case sandbox participant fails.

4.2.4.3.7 Consumer protection

The sandbox entity should ensure that any existing obligation to its customers of the
financial service under experimentation must be fully fulfilled or addressed before exiting
the sandbox or discontinuing the sandbox. Customers need to be informed that the
FinTech solution is operating within a Sandbox. For the purpose of transparency and
provision of information to customers, relevant information of all approved sandbox
applications such as the name of the applicant, and the start and expiry dates of the
sandbox experimentation, will be published on MAS’ website.

4.2.4.3.8 Agreement with other Regulators

In March 2016 UK (HM Treasury and the FCA) and Singapore (MAS) concluded a
“FinTech Bridge” agreement. The agreement will enable the regulators to “refer” FinTech
firms to each other. According to the FCA and the MAS, the agreement also sets out
how the regulators plan to share and use information on financial services innovation in
their respective markets. The MAS has an agreement in place during June 2016 with
Australia's ASIC to help innovative businesses expand in each other’s market faster.

4.2.4.3.9 Development of Insurance Technology (Insurtech) ecosystem

In response to a growing demand for personalised services and addressing individual
needs, MAS provides significant investment and resources to spur the growth of
insurtech in Singapore. Over the years incumbent insurers have built accelerators of

40
digital labs. Examples include Aviva Digital Garage, Metlife’s Lumen Lab, AXAá data
Innovation Lab in Singapore.

4.2.4.4 Dutch Central Bank (DNB)-Authority for Financial Markets (AFM)

Dutch Central Bank (DNB) and Netherlands Authority for the Financial Markets (AFM)
created a pilot FinTech Innovation Hub in June 2016 16 to support market participants that
seek to market innovative financial services or products but are unsure about the rules.
The Hub aims to create room for innovation in the financial sector. The Hub offers new
entrepreneurs and incumbents the opportunity to submit questions about regulations
directly to a supervisory authority, irrespective of whether they are currently subject to
supervision. The Hub is primarily intended to provide informal support to new entrants at
an early stage of developing an innovative product or financial service. Innovation Hub
facilitates access to the supervisory authorities for financial market operators by offering
a central point of contact by the both supervisors and providing a coordinated approach
to possible support. The Hub has created a central site for innovation-related issues.
These include consultations, policy proposals, frequently asked questions and other
useful information for new and current market players.

4.2.4.4.1 Objective of Sandbox

DNB's stated objective is to seek to achieve solid and ethical financial institutions and a
stable financial sector. The AFM stated focus is on orderly and transparent financial
market processes, clear relations between market operators and diligent customer care.
According to both, these objectives are best ensured in a financial sector that offers
scope for effective competition and variety. The Dutch competent authorities outline
three policy options that may facilitate market entry for new and innovative financial
services or activities provided by new or established players in the market.
- Creating a “regulatory sandbox”, which leverages the scope offered by the law when
interpreting the rules. By doing so the supervision standards will not be relinquished,
but merely reviewed and fine-tuned to facilitate innovation.
- To facilitate access to the Dutch financial sector, banks could also take advantage of
partial authorisation, for instance if they do not plan to take on all the activities
covered by the authorisation.
16
https://www.afm.nl/nl-nl/professionals/nieuws/2016/jun/innovation-hub

41
- Provisional authorisation might also prove to be an option that offers the best
solution for some initiatives.

4.2.4.4.2 Criteria for joining the sandbox

The regulatory sandbox is available to all financial services companies looking to operate
an innovative financial product, service or business model, whether as supervised
players or newcomers. To guarantee the security of the financial system as much as
possible, financial services companies must meet a number of criteria and will be eligible
for the sandbox if the following preconditions are met:
- The innovative product, service or business model contributes to one or more of the
objectives of the financial supervision laws: The solidity of financial services
companies and stability of the financial system; orderly and transparent financial
market processes, clear relationships between market operators and careful
treatment of customers.
- The application of the innovative product, service or business model runs into policy
or legal barriers that the financial services company cannot reasonably overcome,
although it does meet the underlying aim of such policies or laws.
- The financial services company’s corporate processes include procedures and
measures to protect the solidity of the financial services company, the interests of
those buying its financial services or products and of any of its other stakeholders.

4.2.4.4.3 Time frame for regulatory approval

The regulatory sandbox is available from January 01, 2017 and participants are able to
apply anytime. The supervisor in charge will determine how and under what conditions
the sandbox can be put in place, and how such arrangements are recorded will depend
on the type of sandbox. That said, both the financial services company and the
supervisor will be clear beforehand on how the arrangement is set up, how long it will
remain in place and what terms and conditions apply.

4.2.4.4.4 Boundary conditions for the sandbox and evaluation criteria

After a pre-set period, the duration of the sandbox may differ on a case-by-case basis.
Depending on the type of arrangement, the supervisor may find that the sandbox needs
adapting, can stay in force indefinitely or should be discontinued. However, the
supervisors can partially or wholly end, change or constrain the sandbox, or impose

42
additional requirements at any time. As the Netherlands are part of the European Union
and the Single Supervisory Mechanism, the authorities have indicated that most
applications for sandbox are approved within the scope of their own policies.

4.2.4.4.5 Exit Strategy

The exit plan should identify the possible and most likely causes of the business failing
and the triggers that will set in motion the exit plan. In addition, the exit plan should
describe the decision-making process and procedures that will follow once the exit plan
is activated and identify the team or crisis team that will execute the exit plan.
Furthermore, the exit plan should offer at least one alternative if the basic scenario
proves not feasible for any reason. Finally, the exit plan should identify essential
functions that will need to continue once the exit plan is activated.

4.2.4.5 USA: OCC Special Purpose National Bank Charters for FinTech Companies
5.2.4.5.1 On December 2, 2016, the OCC released a paper entitled 'Exploring Special
Purpose National Bank Charters for Fintech Companies' that sets forth the OCC’s plans
to allow FinTech companies to apply to become special purpose national banks. The
OCC requested comment on the proposal, with the comment period closing on January
15, 2017. The OCC’s special purpose charter is a licensing system, not a space for
piloting or testing new products. The charter is designed to be a more permanent
license, while participants in the sandboxes often need to go through another application
process, expedited for some, at the end of their pilot or testing program. Sandboxes
often have limitations on the test market, such as number of clients and products, while
the OCC’s special purpose charter does not restrict the same. Fintech companies
receiving an OCC special purpose charter would generally be subject to the same type
of regulatory oversight as a national bank.

4.2.4.5.1 Eligibility:
Fintech companies that are eligible to apply for charters are those that engage in
fiduciary activities or in at least one of the three “core banking” activities that include
receiving deposits, paying checks, or lending money. The eligibility decision will be made
by the OCC on a case-by-case basis.

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4.2.4.5.2 Regulatory applicability:
• Fintech companies with special charters will be subject to the same laws, regulations,
examination, reporting requirements, and ongoing supervision as other national
banks.
• State laws, as they apply to national banks, including fair lending, unfair and
deceptive acts and practices, and debt collection, will also apply.
• The OCC may extend a framework for receivership of an uninsured national bank to
FinTech companies with special charters that are not insured.
• Most special purpose national banks become members of the Federal Reserve
System. In that case, status and Federal Reserve regulations for member banks will
be applicable to special purpose national banks.
• A FinTech company that proposes to accept deposits other than trust funds would be
required to apply to, and receive approval from, the FDIC for deposit insurance.
• Fintech companies can receive a charter without being insured by the FDIC, if they
do not take deposits.
• If special purpose national banks engage in activities that are regulated under a
federal consumer financial law, they may be subject to oversight by the CFPB.
• The OCC has the right to apply additional conditions in connection with granting
special purpose charters, such as capital, liquidity, safety and soundness, compliance
risk management and encouraging financial inclusion and fair lending.

4.2.4.5.3 The OCC paper states that entities interested should provide the
following:
• A robust, well-developed business plan
• A governance structure that commersurate with the risk and complexity of the firm -
the Board of Directors must have a prominent role
• Capital levels, liquidity, and compliance risk management commensurate with risks
and products
• A financial inclusion plan – in particular, lenders should demonstrate a commitment to
financial inclusion
• A recovery plan and exit strategy

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4.2.4.6 HKMA 17
HKMA has commissioned ASTRI to carry out a comprehensive study on distributed
ledger technology (DLT). First stage of this research project is completed and a white
paper has been published. HKMA-ASTRI FinTech Innovation Hub - equipped with high-
powered computing resources and supported by the experts at ASTRI to allow banks,
payment service providers, FinTech firms and the HKMA to brainstorm innovative ideas,
tries out and evaluates new FinTech solutions in a safe and efficient manner.
FinTech Supervisory Sandbox was launched in September 2016 in order to create a
regulatory environment that is conducive to FinTech development. The stated purpose of
the Sandbox is to enable banks to conduct pilot trials of their FinTech initiatives in a
controlled production environment without the need to achieve full compliance with the
HKMA's usual supervisory requirements. So far, two banks have already made use of
the Sandbox to conduct pilot trials of their biometric authentication and securities trading
services.

4.3 Regulatory response in other jurisdictions

4.3.1 Bank of Japan FinTech Center- April 2016 18
The Japan Financial Services Authority (JFSA) established the “FinTech Support Desk”
in Dec, 2015. The Desk is a one-stop contact point for inquiries and opinions pertaining
to business involving FinTech in relation to Japan’s financial environment. The staff
members are partially dedicated to FinTech and innovation. Bank of Japan also created
a FinTech center in April 2016. The Center plays an active role as a catalyst for
promoting interaction among financial practices and innovative technologies, research
and study, and the needs of the economic society. The center engages to support,
advise or guide regulated and unregulated firms to develop FinTech and enhance
financial services. The Center is a section of the Payment and Settlement Systems
Department of the Bank of Japan. Companies from a wide range of sectors have access
to the Center. They include banks, financial institutions, IT firms, consulting companies,

17
http://www.bis.org/review/r161111c.htm
18
http://www.bis.org/review/r160823d.pdf

45
law firms, and start-up/venture companies. The Bank has also built up a “FinTech
network” comprised of a wide range of staff drawn from the relevant departments of the
Bank. This FinTech Network, for which the FinTech Center functions as the secretariat,
promotes the sharing of information and expertise related to FinTech in a cross-sectoral
manner within the Bank.

4.3.2 China: China Banking Regulatory Commission (CBRC)

The P2P lending industry in China is the largest in the world with hundreds of platforms
offering diverse services but it is not regulated currently. As per the media reports,
China's P2P lending sector is currently estimated at USD 60 billion. China Banking
Regulatory Commission (CBRC), Ministry of Public Security, Cyberspace Administration
of China, and the Ministry of Industry and Information Technology issued guidelines on
P2P lending during August 2016. The major areas of regulatory framework are:
P2P platforms will not be able to take deposits, nor provide any forms of guarantee for
lenders; not be permitted to sell wealth management products; P2P firms can neither
guarantee investment returns nor investment principal.

4.3.3 Bank of Italy

The Bank of Italy is currently interested in analyzing the implications of technological
innovations in payment systems and financial markets. In light of the above, the Bank of
Italy is monitoring market developments, and in particular new emerging actors and new
service offerings, to observe and consequently to assess and mitigate potential market
risks and misbehaviors. Considering the high interest of market operators in the
blockchain and distributed ledger technology (DLT), the Bank of Italy set up an internal
working Group with the aim of analyzing new developments in the adoption of this
technology.
The objectives of the working Group are: i) analysing possible future scenarios in which
blockchain and distributed ledger technologies can be used by financial intermediaries;
ii) supporting the Bank’s supervisory department and oversight department in analyzing
any initiative presented by supervised entities and in defining any policy stance; iii)
managing the interaction with market operators; and (iv) research.

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5. Emerging Regulatory and Supervisory issues in India
5.1 Regulatory and Supervisory response in India
FinTech has significant implications for the entire financial system in India. The multiplicity of
firms and a mosaic of business models complicate the classification of the various types of
activities, products and transactions covered under the FinTech spectrum.
Though the western world has been using the term 'FinTech' for some time, it has only
recently become a buzzword in India. Notwithstanding this, FinTech has, since quite some
time, gathered momentum in the country. However, as of now, the FinTech risks are being
looked at more in terms of what is associated with the traditional IT systems, such as cyber-
security risks. While the IT related risks are no doubt multiplying manifold under FinTech, the
whole gamut of issues under the FinTech umbrella, particularly those of regulatory concern,
have to be responded to on priority. It is, therefore, necessary to examine these issues and
outline the contours of an appropriate regulatory strategy. However, FinTech treads across
several activities that are within the scope of different financial sector regulators.

5.1.1 RBI issued a consultation paper on P2P lending in April 2016. Some of the issues
raised in the consultation paper are as under:
• Regulations may also be perceived as too stringent, thus stifling the growth of an
innovative, efficient and accessible avenue for borrowers who either do not have
access to formal financial channels or are denied loans by them.
• The market for P2P lending is currently in a nascent stage and they neither pose
an immediate systemic risk nor any significant impact on monetary policy
transmission mechanism.
• In its nascent stage, this industry has the potential to disrupt the financial sector
and throw surprises. A sound regulatory framework will prevent such surprises.
• P2P lending promotes alternative forms of finance, where formal finance is unable
to reach and also has the potential to soften the lending rates as a P2P Lending
result of lower operational costs and enhanced competition with the traditional
lending channels.

47
 • If the sector is left unregulated altogether, there is the risk of unhealthy practices
being adopted by one or more players, which may have deleterious
consequences.

It has been proposed in the consultation paper to bring the P2P lending platforms under
the purview of Reserve Bank’s regulation by notifying P2P platforms as NBFCs.
5.1.2 Monitoring framework for new technologies / innovations
The RBI as regulator and supervisor of payment systems has been playing the role as
the catalyst / facilitator for innovations in payment systems. The Payment and Settlement
System Vision – 2018 also covers this aspect appropriately under the Strategic Initiatives
– Responsive Regulation and Effective Oversight. In order to ensure that regulations
keep pace with the developments in technology impacting the payment space, the global
developments in technology such as distributed ledgers, blockchain, etc. will be
monitored, and regulatory framework, as required, will be put in place. Further, the
payments eco-system is dynamically evolving with the advancements and innovations
taking place, particularly in the area of FinTechs. In order to provide a platform for
innovators to showcase their models to the industry, particularly in the areas of interest
to payment systems and services, the Reserve Bank has organized an innovation
contest through the Institute for Development and Research in Banking Technology
(IDRBT). Learnings from such interfaces will also be used as inputs for policy
adaptations. RBI has taken various initiatives in the technology-enabled banking space
as listed below:
(i) Issued in-principle approvals for Payments Banks, of which some have
since been licensed
(ii) Allowed entry of non-banks in the payments space both as payment
system operators and technology service providers
(iii) Introduced Bharat Bill Payments System (BBPS)
(iv) Published a consultative paper on Card Payment Infrastructure
(v) Issued a consultation on Peer to Peer (P2P) lending
(vi) Issued Directions on Account Aggregators
(vii) Authorised payment solutions provided by NPCI such as NACH, AEPS,
IMPS, Unified Payment Interface (UPI)
(viii) Given in-principle approval for National electronic toll collection project.

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 (ix) Set up the framework for the electronic Trade Receivables Discounting
System (TReDS) to improve flow of funds to MSMEs

5.2 Impact on Financial inclusion

The Government of India and the Reserve Bank are actively promoting financial
inclusion with schemes like Jan Dhan Yojana, Aadhaar enrolment and licensing of
Payment Banks /Small Finance Banks, to name just a few. The FinTech companies
across the nation are taking the advantage of these initiatives for expanding financial
inclusion in the following areas by leveraging technology.
S. Area of Financial Inclusion Use of
No. FinTech
1 Augment the government social cash transfer in order to increase the Easy cash
personal disposable income of the poor. It would put the economy on transfer App
a medium-term sustainable inclusion path.
2 Banks should make special efforts to step up account opening for Modification to
females belonging to lower income group under this scheme for existing Bank
social cash transfer as a welfare measure (Sukanya Shiksha FinTech App.
Scheme).
3 Aadhaar should be linked to each individual credit account as a Integration of
unique biometric identifier which can be shared with Credit Aadhaar
information bureau to enhance the stability of the credit system and Infrastructure
improve access.
4 Bank’s traditional business model should be changed with greater Enhanced
reliance on mobile technology to improve ‘last mile’ service delivery. Mobile
Banking
5 Increase the formal credit supply to all agrarian segments through Digitisation of
Aadhaar-linked mechanism for Credit Eligibility Certificates (CEC). land records
6 Corporates should be encouraged to nurture Self Help Groups Loan /
(SHGs) as part of Corporate Social Responsibility (CSR) initiative. Payment App.
7 Replacement of Government’s current agricultural input subsidies on Direct Account
fertilizers, irrigation and power by a direct income transfer scheme as Transfer App
a part of second generation reforms. with the help of
Aadhaar
Infrastructure
8 Introducing universal crop insurance scheme by Government Crop
covering all crops starting with small and marginal farmers with Insurance App
monetary ceiling of Rs. 2 lakhs.
9 To provide credit guarantees in niche areas for micro and small Multiple
enterprises (MSEs). It would also explore possibilities for counter Guarantee
guarantee and re-insurance. App for
agencies
10 Introduction of UID for all MSME borrowers and information from it UID for
should be shared with credit bureaus. MSME App.

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5.3 Initiatives taken by other financial market regulators in India
5.3.1 SEBI
5.3.1.1 Specifically, considering the financial sector and the evolution of SEBI over the
last two and a half decades, it is believed that increasing preponderance of technology
has been largely beneficial to the financial markets, increasing the efficiency of trading
systems, reducing overall cost of transactions and most importantly democratising the
reach of financial markets and increasing retail participation. SEBI on its part has also
made its best efforts to evolve with the changing technological landscape. Screen Based
Trading, nationwide trading systems and dematerialisation of shares are amongst the
biggest gifts of the technology revolution which has brought significant reforms in the
Indian capital market.
5.3.1.2 In the recent past one of the most pertinent innovations in financial sector is the
adoption of algorithmic and machine based trading. Additionally, tools like robot advisors
in the investment advisory space are another innovation gathering speed in recent times.
Another important innovation is the emergence of social media, which serves as the
carrier of news - financial or otherwise - faster than any other mode and more importantly
with a very wide reach.
5.3.1.3 It has also been observed that market participants in other securities markets are
exploring the usage of BlockChain or Distributed Database technology to provide various
services such as clearing and settlement, trading, etc. Indian securities market may also
see such developments in near future and, therefore, there may be a need to understand
the benefits, risks and challenges such developments may pose.

5.3.2 Insurance Sector

5.3.2.1 A number of emerging forces are creating pressure across the insurance value
chain, with the potential to redefine the structure of the Indian market. Insurance is
typically considered one of the functions within financial services where the adoption of
innovation has been the slowest. However, over the past decade, many innovative
practices such as digital channels and process automation have been gradually adopted
by many insurers. This has been especially true in personal lines of business while large
commercial lines have continued to focus on establishing a “personal touch” across the
value chain. Traditional broker / agent in-person distribution faces significant competitive
pressures from digital channels in personal lines. Distribution partnerships with banks

50
and retailers through white-labelling and over-the-counter products have become
increasingly popular.
5.3.2.2 In some geographies, customer-centric high-touch services have emerged to
provide differentiated claims experience. Some of the initiatives taken in the recent past
are:
• The adoption of digital channels has begun to replace manual time-consuming
processes to empower customers and / or workforce
• Innovation labs within insurance companies are being established to combine
brand and product managers with technological and analytical resources
• New products increasingly require integration with 3rd party data providers
• Advanced statistical models are being deployed to understand the correlation
between measurable factors and risk (actuarial) using historical data
• A large portion of pricing risks with collected data (underwriting) has been
automated over the years to improve accuracy and speed, especially with the
advent of out-of-box solutions

5.3.2.3 Advancing technologies, changing customer preferences and the market

landscape are enabling a number of innovations and trends, which are likely to create
pressure across the insurance value chain. As a result, the insurance value chain will be
increasingly disaggregated in the future, changing the nature of the insurance business.
The rise of online aggregators and the potential entry of technology players could
disaggregate the distribution of personal and small commercial policies and separate
insurers from the ownership of customer relationships.
5.3.2.4 New sources of capital and investment management capabilities, such as hedge
funds and investment banks, are aggressively moving into the insurance industry
through innovative securitisation products, offering more cost-effective options to fund
policies. In order to remain competitive in the face of a disaggregating value chain
insurers will need to reconsider which core competencies they will invest in to maintain a
strong competitive position.
5.3.2.5 FinTech companies take an approach that is more collaborate than disruptive.
This has given the financial services sector a sense of security because incumbent
players are not threatened by start-ups that are out not to disrupt but to collaborate,
seemingly cementing the financial institutions position as undefeated incumbent.

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Insurance companies may collaborate with Insurtech entities or start-ups to provide
better customer experience in a cost effective manner.
5.4 Cyber security and FinTech

Since early 1990s (accelerated in 2000s) with entry of New Pvt. Sector banks, the PSU
banks have also embraced technology by leaps and bounds in the last decade or so. But
the key shift has been brought in by consumer demand for real-time and always ON
(anytime/anywhere) banking aided by growing demand coming from explosive growth in
use of personal computing devices and internet connectivity, innovative products (plastic
cards, now contactless cards, future - internet of things) by consumers. The banks have
also been trying to make their processes more efficient and continuously looking for
ways to leverage enhanced level of engagement with customers with a view to offering
innovative products and services keeping in view cost, convenience and profitability
factors. Being a largely service based industry, there is a high degree of dependency on
technology for delivering services (be it from sourcing to servicing) by banks and
competitive pressures to continually innovate in order to retain customers in the wake of
entry of niche players/new players/entrants (banks, small finance banks, payment
banks).

The advancements in technology and shift in consumer preferences driven by (SMAC –

social media, mobility – mobile computing, analytics – big data, cloud computing, etc.)
have further brought on opportunities and challenges in terms of their utility/efficiency,
complexity of products, deployment architecture, accompanied by persistent concerns
over consumer protection in this era of instant communication and real time transactions,
sometimes through opaque channels. The propensity to adopt the latest and deploy the
emerging technologies, computing devices is not perhaps commensurate with the growth
in understanding/awareness of their pitfalls, by both consumers and banks alike. In the
eagerness to provide innovative products and services through digital channels and
reducing cost of transactions/services/processes, banks are resorting to outsourcing
(managed products/services), quicker development and deployment cycle of
products/services/processes without due emphasis/rigor in security design and testing
and this, often leaves loopholes for attackers to exploit.

Along with the benefits that the technology advancements have brought in, with
increased reach of connectivity (internet) and geo political/macro-economic factors, we
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are beginning to see another side/dark side of the technology in the form of cyber-
attacks. The sophistication of cyber-attacks are on the rise and may well continue in the
future with connected devices set to exceed the human population at some point in the
future.
Cyber Security is an issue that has been growing in importance with the advancements
in technology. From a securities market point of view, some developed jurisdictions have
observed cases of hacking of trading accounts for market manipulation. However, the
same is as yet unheard of in Indian market, largely on account of separation of trading
and bank accounts. Consequently, while infeasible (from the point of view of
manipulator/offender) because of the practicality issue of hacking multiple accounts,
hacking of trading accounts and like activities, is not impossible in the Indian context.
However, the real danger here could be an attack on the systems of Market
Infrastructure Institutions or even the Regulator for that matter as targets of economic
terrorism or warfare.

5.4.1 Customer Data Protection (CDP)

The FinTech entities are heavily dependent on technology for each and every product
they offer to their consumers. These entities may collect various personal and sensitive
information about the customer and become the owners/custodians of such data.
Therefore the onus of CDP lies with these entities ranging from data Preservation,
Confidentiality, Integrity and Availability of the same, irrespective of whether the data is
stored/in transit within themselves or with customers or with the third party vendors; The
confidentiality of such custodial information should not be compromised at any situation
and to this end, suitable systems and processes across the data/information lifecycle
need to be put in place by the FinTechs.
Section 43A of the Information Technology Act, 2000, provides for payment of
compensation by a body corporate in case of negligence in implementing reasonable
security practices and procedures in handling sensitive personal data or information
resulting in wrongful loss to any person. In terms of section 72A of that Act, disclosure of
information, knowingly and intentionally, without the consent of the person concerned
and in breach of the lawful contract has been also made punishable with imprisonment
for a term extending to three years and fine. Hence, that data protection is generally
governed by the contractual relationship between the parties, and the parties are free to
53
enter into contracts to determine their relationship defining the terms personal data,
personal sensitive data, its dissemination, etc. As such, it may be necessary to
emphasize the need for an exhaustive stand-alone legislation on data protection in India
keeping in mind the innovations in FinTech and risk to personal data which comes to the
possession of these entrepreneurs.

5.4.2 Classification of Customer / Organization Data (CCOD)

The FinTech entities should classify data / information based on information
classification / sensitivity criteria of the organization. It becomes important to
appropriately manage and provide protection within and outside organization
borders/network taking into consideration how the data/information are stored,
transmitted, processed, accessed and put to use within/outside the bank’s network, and
level of risk they are exposed to depending on the sensitivity of the data/information.

5.4.3 Adherence to Safe Transaction Principles (STP)

A transaction in the IT parlance is termed as successful, if the transaction does not suffer
from loss of confidentiality, loss of integrity, and loss of availability. These three together
are referred as the security triad / the CIA triad. The three consequences of lack of CIA
leads to “Data Leakage to Unauthorized Parties”, “Data Tampering / Destruction by an
Unauthorized Party”, “Non Availability of the Data / System at times it is really needed”.
The FinTech entities need to satisfy these principles in order to build faith in the new
ecosystem.

5.4.4 Network Management and Security (NMS)

The FinTech entities should establish a common / individual Security Operation Centre
(SOC) to monitor the adherence to Standard Operating Procedures (SOP) of the all
major IT activities. A Security Incident and Event Management Systems (SIEM) is of
great help to monitor these, which the entities may induct as part of their monitoring
services.

5.4.5 Configuration / Patch Management Systems

The FinTech entities should install systems and processes to identify, track, manage and
monitor the status of patches to operating system and application software running at

54
end-user devices directly connected to the internet and in respect of Server operating
Systems / Databases / Applications / Middleware, etc.

5.4.6 Audit Management

The FinTech entities should be subject to Detailed Application Control Review (DACR) of
the entire Application Development Life Cycle (ADLC) as well as functionalities.

5.4.7 Quality Management

The FinTech entities should acquire industry quality management certifications facilitated
by International Organization for Standardization (ISO) / Payment Card Industry Security
Standards Council, etc as applicable.

5.4.8 Vulnerability Assessment and Penetration Testing (VAPT)

The FinTech entities should periodically assess / reassess the systemic vulnerabilities by
conducting VAPT tests.

5.4.9 Audit Log Management System (ALMS)

The FinTech entities should implement ALMS to periodically validate settings for
capturing of appropriate logs / audit trails of each device, system software and
application software, ensuring that logs include minimum information to uniquely identify
the log for example by including a date, timestamp, source addresses, destination
addresses, and various other useful elements of each packet and/or event and/or
transaction.

5.4.10 Incident Response & Management Framework (IRMF)

The FinTech entities need to have clear procedures for responding to cyber incidents
and a mechanism for dynamically recover from cyber threats. Technical progress fosters
innovation, but it also entails new risks. At the same time, the primary mandate of the
regulator is to protect the users of financial services and the stability of the financial
system. In this section, we analyse two issues the regulator needs to focus on: the threat
of cyber-attacks and the risks related to the outsourcing of certain traditional bank
activities. Companies in the banking and financial sectors are prime targets for
cyber-attacks, and the emergence of online services, designed to be simple and

55
interactive, only heightens this risk. In a worst case scenario, it is possible to imagine a
wave of concerted attacks triggering a liquidity squeeze in the markets and threatening
the solvency of sector participants. For regulators, however, the difficulty is knowing how
to evaluate these new risks. There are no historical examples that can be used to
construct realistic scenarios. All regulators can do is to take a pragmatic approach,
defining plausible attack scenarios and testing the defence mechanisms put in place by
digital enterprises. This task is made all the more difficult by the fact that ongoing
financial innovation is constantly opening up new possibilities of attack. Only by
developing in-depth expertise in this field can the regulators expect to effectively fulfil
their role.
The second source of risk is the outsourcing of certain tasks in the financial transaction
processing chain. Before the technological revolution, it was usual for banks to carry out
all tasks in the value chain internally, so that all these tasks were subject to supervisoey
oversight. These days, this is increasingly rare, both for conventional players and new
market entrants. In the case of conventional banks, for example, cost pressures have
pushed them to offload some tasks to unregulated entities.

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6 Way Forward – for stakeholders
6.1 Regulation
6.1.1 FinTech powered business should ideally be undertaken by only regulated entities,
e.g. banks and regulated payment system providers. The forms of business which can
be undertaken by, say, a banking company are specified in section 6 of the Banking
Regulation Act, 1949 and no banking company can engage in any form of business other
than those referred to in that section. This provision however also enables a banking
company to do such other things which are incidental or conducive for the promotion or
advancement of its business. Banking companies can therefore form subsidiaries for
undertaking any business which supports their main business. Subsidiaries can also be
formed for undertaking such other business which Reserve Bank may, with the approval
of the Central Government, consider to be conducive to spread banking in India or to be
otherwise useful for necessary in the public interest [section 19(c), BR Act]. These
provisions give room for banking companies to undertake focused innovative FinTech
business relevant to their operations, via a dedicated subsidiary, while remaining within
the legal framework of the Banking Regulation Act. However, as FinTech innovations are
typically multiple-use, with significant applications beyond financial regulation, it may be
inefficient and counterproductive to restrict core FinTech activities to only those entities
and applications which are covered under financial regulation/supervision.

6.1.2 The Payment and Settlement Systems Act, 2007 provides for authorisation,
regulation and supervision of payments systems by Reserve Bank. A payment system is
defined in that Act as a system that enables payment to be effected between a payer
and a beneficiary, involving clearing, payment or settlement service or all of them, but
does not include a stock exchange or clearing corporation set up under a stock
exchange. It is further stated by way of an explanation that a “payment system” includes
the systems enabling credit card operations, debit card operations, smart card
operations, money transfer operations or similar operations. As the bulk of FinTech
innovations do not amount to ‘payment system’ as defined under that Act, they will not
fall under its regulatory framework.

6.1.3 Section 35A of the Banking Regulation Act empowers the Reserve Bank to issue
directions to banking companies in public interest and in the interest of banking polices,
etc. Reserve Bank is also empowered under section 36 of the BR Act to caution or
57
prohibit banking companies generally and generally to give advices to banking
companies. As regards payment systems, section 17 of the Payment and Settlement
Systems Act gives the RBI the power to issue directions to payment systems and
systems participants. It may be possible for the Reserve Bank to invoke these
provisions in case FinTech innovations used by these regulated entities require RBI
intervention. However, there is scope for developing a legal framework that sets out the
broad contours of what principles financial innovations should conform to.

6.1.4 Faced with the profound changes that FinTech is bringing to the banking and
financial sectors, regulators need to take care to avoid two pitfalls. The first is
overprotecting incumbents by erecting barriers to entry for newcomers. Doing so would
discourage financial innovation and stifle competition in the financial sector. The second
potential pitfall is choosing instead to unduly favour newcomers by regulating them less
stringently than incumbents, in the name of fostering competition.
Regulators have a difficult role to play as their decisions have both a direct and indirect
impact on competition between incumbent firms and newcomers. They have to provide a
level playing field for all participants, but at the same time foster an innovative, secure
and competitive financial market.
6.1.5 The Watal Committee Report has noted that the current law does not impose any
obligation on authorised payment systems to provide open access to all PSPs. This has
led to a situation where access to payment systems by new non-bank payments service
providers, including FinTech firms, is restricted. Most of them can access payment
systems only through the banks, which are also their competitors in the payments
service industry. This, according to the Committee, has restricted fast-paced expansion
of digital payments in India by hindering competition from technology firms 19.
6.1.6 FinTech companies that require to connect to banking systems to serve their
customers tend to face restrictive practices. This anti-competitive setting may not be
conducive for innovation and consumer interest. Moreover, India may not then reap the
full benefits from global innovation as international technology based PSPs would not
find it attractive to grow in India. That said, the approach of RBI has been to regulate
non-bank payments service providers lightly. This has enabled them to emerge as
significant players in a relatively short time frame. This growth now needs to be nurtured

19
Watal Committee: http://www.finmin.nic.in/reports/watal_report271216.pdf
58
in a balanced way, so that banks have competitive pressure to innovate and non-banks
have adequate opportunity to compete, without losing sight of systemic stability.
6.1.7 Globally, the above approach has been recognised and structural changes have
been put in place to ensure that the consumers benefit the most from this technology led
payments revolution. This is true for many progressive economies including countries in
European Union (including UK), Australia and South Africa. The common themes across
these jurisdictions is to promote increased participation of non-banks in payments, and
promote access and competition in the payments industry.
6.1.8 The Watal Committee Report recommends that the regulator should enable a
formal framework for a regulatory sandbox. A regulatory sandbox can be used to carve
out a safe and conducive space to experiment with FinTech solutions, where the
consequences of failure can be contained.
6.1.9 IDRBT, an institute established by the Reserve Bank of India exclusively for
research and development in the area of banking technology, has been working closely
with banks and technology companies. The institute, at the instance of RBI, organized a
payment system innovation contest in the year 2016. There have been several entries
from academicians, banks, start-ups from India and other countries. The Institute
awarded prizes to best entries, after a rigorous evaluation process. Similarly, the Institute
has brought out a white paper on application of block chain technology in banking and
finance. The white paper also describes a Proof of Concept exercise in the area of trade
finance, done with active participation of NPCI, banks and an international solution
provider. The institute has facilities for testing mobile apps, which are being used by
banks.
6.1.10 In view of IDRBT’s unique positioning as a RBI established institute, and its
expertise and experience, it is felt that IDRBT is well placed to operate a regulatory
sandbox, in collaboration with RBI, for enabling innovators to experiment with their
solutions for eventual adoption. The Institute may continue to interact with RBI, banks,
solution providers regarding testing of new products and services and over a period of
time upgrade its infrastructure and skill sets to provide a full-fledged regulatory sandbox
environment. The Reserve Bank of India may actively engage with the Institute in this
regard. Other regulators may also leverage the expertise of IDRBT to provide sandbox
for respective sectoral solutions.

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6.1.11 It is possible, however, to outline a number of general regulatory principles. The
first should be to maintain a neutral stance with regard to technological advances.
Regulations should foster healthy competition between players, regardless of whether
they offer conventional approaches or use new technological solutions. We need to
avoid putting unnecessary obstacles to growth for new entrants. The second principle is
that we have harmonised sets of rules, inter-operability and platform utilization security
protocols, covering a given activity across all players simultaneously, rather than treating
players differently according to their characteristics, an approach that would artificially
segment the market and hence limit competition. The third principle is that regulators
must also act in the interests of users, protecting them in a changing environment that
can pose new, unanticipated risks. The fourth principle is that systemic stability concerns
should be addressed.
6.1.12 Respecting these principles in equal measure will clearly be difficult, and giving
one principle priority could undermine the others. The role of the regulator is to find the
right balance.
6.1.13 Regulators are responding to challenges posed by technological innovation and
are seeking to strike a balance between mitigating the potential risks associated with this
development, and not impeding the positive effects of innovation. The range of actions
taken by various regulators include:
 Research and publishing papers on FinTech developments
 Proactive engagement with existing firms and new entrant FinTech firms
 Modifications to supervisory processes;
 New guidance or regulations

6.1.14 It would be difficult for a regulator to imagine and fully anticipate what kind of
innovations can take place in the market and their impact on the broader market and
institutions. Generally, the need for a certain service creates demand for the product,
which the entrepreneurs tap, and try to make a business model out of it. At times,
products are designed in advance and the market is created for such product. While
encouraging such innovations, as already stated, the challenge would be to keep in mind
systemic risk, which may arise with greater innovation; consequently, risk management
measures would need to be in place.

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Illustratively, a securities market regulator (e.g. SEBI) would want to minimise the impact
of tail events like flash trades, freak trades or malfunctioning of Algos, etc. For example:
• The technology should not prove a hindrance or obstacle for surveillance or
investigation function of SEBI.
• Cases have been observed in the recent past of usage of tools like SMS to spread
misinformation relating to specific scrips; there is the possibility of usage of similar
tools to spread general market wide panic. The challenge in this case is twofold;
firstly, in terms of prevention of such activity, which presently at least, seems
infeasible for all practical purposes. Secondly, the challenge of establishment of
audit trail post the concerned event makes it difficult to identify and nail the actual
culprit/brain behind the activity. Such acts are observed to have taken place under
layers and layers of front entities, some of which may not even be within the
jurisdictional reach or ambit of the regulator, geographically, legally or otherwise
and necessary supervisory response might require inter-regulatory and cross
jurisdictional coordination, in addition to the technological capacity to identify such
issues.

6.1.15 The use of technology has been of great help for increasing the reach of the
financial services and has also facilitated the ease of doing business. Regulators can be
open to considering all these FinTech options and facilitating the same, so long as these
serve to subserve their regulatory mandate without compromising on the risk associated
with such innovations. As and when such products are introduced or emerge in the
market, the issue for consideration before the regulator would be to assess the product
and its implications for stakeholders, and how to monitor its use.

6.1.16 Realignment of regulatory approach

Regulators therefore need to examine how their approach can be brought more closely in
line with a financial sector that is undergoing structural change. Regulators need to also
examine whether and how their regulations impose barriers to innovation and whether,
and to what extent, these can be removed. There is a need to develop a deeper
understanding of various FinTech products and their interaction with the financial sector
and thereby their implications on the financial system, before actively regulating this
space.

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In this regard, the following steps are recommended by the Working Group:
 The regulatory actions may vary from “Disclosure” to “Light-Touch Regulation &
Supervision” to a “Full-Fledged Regulation and Supervision”, depending on the
risk implications. As suggested per the matrix in the Annex-2.
 To develop a more detailed understanding of risks inherent in platform based
FinTech.
 To identify sector specific FinTech products, study regulatory approaches by
various financial sector regulators, and devise the regulatory approach.
 To provide an environment for developing FinTech innovations and testing of
applications/APIs developed by banks/FinTech companies.
 An appropriate framework may be introduced for “Regulatory Sandbox/innovation
hub” within a well-defined space and duration where financial sector regulators
will provide the requisite regulatory support, so as to increase efficiency, manage
risks and create new opportunities for consumers, for Indian context, similar to
other regulatory jurisdictions.
 In view of IDRBT’s unique positioning as an RBI established institute, and as
indicated by some of its activities, it is felt that IDRBT is well placed to act as
regulatory sandbox in collaboration with RBI for enabling innovators to experiment
their solutions for eventual adoption. The Institute may continue to interact with
RBI, banks, solution providers regarding testing of new products and services and
over a period of time upgrade its infrastructure and skill sets to provide full-fledged
regulatory sandbox environment. The Reserve Bank of India may actively engage
with the Institute in this regard.

 In order to identify and monitor the challenges associated with the development of
major FinTech innovations and to assess opportunities and risks arising for the
financial system from these innovations, a ‘dedicated organizational structure’
within each regulator should be created.
 Financial sector regulators require to engage with FinTech entities in order to
chalk out appropriate regulatory response and to re-align existing regulatory and
supervisory framework.
 Regulatory and legal reforms which are essential to enable the sustained
development of a digital financial industry for the future.

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  Partnerships/engagements with regulators, existing industry players, clients and
FinTech firms will enable the development of a more dynamic and robust financial
services industry.
 Models of engagement and risk-benefit checklist to be developed by each
regulator for identified FinTech based activities.

6.1.17 Reg Tech

6.1.17.1 Reg Tech is a sub-set of FinTech that focuses on technologies that facilitate the
delivery of regulatory requirements more efficiently and effectively than existing
capabilities. In July 2015 the FCA issued a call for input entitled “Supporting the
20
development and adoption of Reg Tech”.
6.1.17.2 Some of the key Reg Tech processes and their benefits are as under:
 Alternative reporting methods: Technology that allows data to be provided (or
taken) in a different way.
 Shared utilities: Technology that allows firms to share services via the cloud
and/or online platforms.
 Semantic tech and data point models: Technology that converts regulatory text
into a programming language.
 Shared data ontology: A formal naming and definition of the types, properties, and
interrelationships of entities.
 Robo-Handbook: Interactive echnology that allows firms to understand the impact
of regulations on their systems and processes.
 Big data analytics: Advanced analytics solutions that can interpret vast amounts of
structured and unstructured data that could be stored in ‘data lakes’ (storage
repositories).
 Risk and compliance monitoring: Technology that allows an always-on,
noninvasive surveillance of transactions, behaviour and communications.
 Inbuilt compliance: Regulatory requirements can be coded into automated rules
which are applied when relevant.

20
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63
  System monitoring and visualisation: Technology that captures and traces all
messages created by systems and their interactions.

6.1.17.3 The emerging focus of Reg Tech for regulators may include the following:
• Regulatory Reporting: streamlining the existing regulatory reporting structure
across the value chain
• Risk and compliance monitoring
• Protecting Customer interest
• Detecting Financial Crime

6.2 Supervision
Technical innovations will have to be monitored in terms of their potential systemic risks.
Crucially, it seems difficult to draw up a complete list of the associated risks because of
the large spectrum of FinTech businesses. With respect to crowd funding and crowd
lending, for example, unless effective control mechanisms are put in place, asymmetric
information on creditworthiness may encourage moral hazard on unregulated platforms
in the same way as originate-to-distribute schemes did during the crisis. For many
innovations, consumer protection issues might become important because these
innovations are put into effect at the interface with the customer.
While innovative players and new technologies are entering the financial industry with
impressive rapidity, regulation should not aim for an artificial separation between
FinTechs on the one hand and traditional banking on the other. While there may be good
reasons for fostering an innovation-friendly environment for FinTechs, these should be
addressed independently of supervisory and regulatory concerns. Also supervisory
authorities risk a conflict of interest between those dissimilar mandates.
Regulators and supervisors need to gear up their organizational structure and human
resources (HR) practices to meet the challenges of innovation, in terms of adapted HR
hiring, learning and educational programmes. To enhance supervisory effectiveness
across the regulatory authorities, the WG recommends the following initiatives to meet
the challenges faced by the regulators/supervisors:
 Identify organizational structure changes that regulatory agencies can apply for
responding to new innovations

64
  Assess and put in place the different skill sets required for regulating/supervising
FinTech innovations, including lateral induction
 Identify specific technologies that regulatory agencies may benefit from having or
may need to have appropriate expertise to supervise.
 Realignment of existing supervisory framework
 Developing policy stance based on enhanced knowledge

6.3 Banks / NBFCs/Securities market/Insurance Companies

6.3.1 Technological innovations help making the financial system more efficient,
especially if they lead to an increase in competition. New technological processes often
result in greater user-friendliness. More competition leads to a greater choice of
providers and products at a lower price, especially if there is competition in each
segment of the value chain. Innovative new entrants provide an incentive for established
financial institutions to become more competitive and focus more on their customers,
whilst at the same time also offering added value themselves to consumers. Moreover,
competition can have a positive impact on integrity in the sector, because customers –
pampered by greater choice – demand more transparency and integrity.
6.3.2 Banks may be encouraged to collaborate with FinTech/start-ups to improve their
customer experience and operational excellence. Banks may also undertake FinTech
activity in areas like payments, data analytics and risk management.
6.3.3 The impact of technological innovations on many incumbents in the banking
industry has been limited to date, which may be due to limited technological capabilities
and lack of awareness at the consumer level.
6.3.4 Additionally, technological innovations tend to follow a so-called “hype cycle”.
According to this concept, there is typically a tendency to overestimate the implications
of new technologies in the short term and underestimate the implications in the longer
term.
6.3.5 The key risks emerging across various FinTech scenarios are as under:
 The potential increase of profitability/solvency risk, and of multiple aspects of
operational risk (both systemic and idiosyncratic elements).
 While incumbent banks’ business models are already under pressure in the
current low interest rates environment and with more stringent regulations,
additional challenges are posed by the FinTech developments.

65
  With the rise of FinTech, IT interdependencies between market players (banks,
FinTech and others) and market infrastructures are growing, which increases the
potential for an IT risk event at a significant market player to escalate into a wider
systemic event.
 Additionally, within individual banks, the complexity surrounding the delivery of
financial services is expected to increase, making it more difficult to manage and
control operational risk.
6.4 Data Security, Privacy and Fraud – set of principles/Model code of conduct
Every FinTech company should invest in fraud prevention. Some studies show that it is
easier to track frauds undertaken through electronic means than physical fraud. FinTech
companies can use technology and analytics to prevent and predict frauds. The onus
could be on the FinTech players to utilize their technological expertise, and assist/
engage with regulators to draft appropriate guidelines to prevent fraud. There is dearth of
coherent data protection and privacy law in the country and it is suggested to bring this to
the notice of the financial sector regulators / Government.

6.5 Government
6.5.1 Investment in FinTech and start-ups
Some Governments and regulators are backing disruptors as a way of introducing more
competition and transparency and preserving competitiveness of their financial service
industry.
Government may take supportive approach to FinTech / start-ups like other sovereigns
in Asia. In order to develop and promote Singapore as smart financial center,
Government of Singapore through MAS has committed USD 160 mio during next 5 years
to the FinTech and Innovation Scheme 21. Similarly Hong Kong Government announced
in November 2016 USD 370 mio VC Fund investment as part of their drive to position HK
as Asia’s FinTech hub 22.
Given that FinTech companies are in their infancy but are growing at a rapid pace, the
Government may consider introducing tax subsidies for merchants that accept a certain

21
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22
https://www.crowdfundinsider.com/2016/09/90450-investhk-initiativeshk-first-hong-kong-FinTech-week/

66
proportion of their business revenues from the use of digital payments as opposed to
cash.

6.5.2 Self-regulatory body set up by FinTech companies

A self-regulatory body comprising of representatives of various FinTech companies may
be set up to undertake consultation/ engagement with regulators to facilitate the orderly
growth of the FinTech industry and address regulatory concerns.

6.6 Consumers
6.6.1The rise of FinTech has been driven by rising customer expectations for more
personalized and digital experiences, increased access to VC funding, reduced barriers
to entry, and accelerated advancements in technology.
6.6.2 The requirement of increasing the levels of education/ awareness of customers
should be highlighted by all market regulators as well as the self-regulatory body for
FinTech companies.

67
7 List of Recommendations

 There is a need to develop a deeper understanding of various FinTech products and

their interaction with the financial sector, before regulating this space. [para- 6.1.16
page-61]
 The regulatory actions may vary from “Disclosure” to “Light-Touch Regulation &
Supervision” to a “Full-Fledged Supervision”, depending on the risk implications.
[para- 6.1.16 page-62]
 The need to develop a more detailed understanding of risks inherent in platform
based FinTech. [para- 6.1.16 page-62]
 To identify sector specific FinTech products and study regulatory approaches by
various financial sector regulators, frame regulatory approach. [para- 6.1.16 page-
62]
 To provide an environment for developing FinTech innovations and testing of
applications /APIs developed by banks and FinTech companies. [para- 6.1.16 page-
62]
 An appropriate framework may be introduced for “Regulatory Sandbox/innovation
hub”, for Indian context, similar to other regulatory jurisdictions. [para-6.1.16 page-
62]
 IDRBT is well placed to act as regulatory sandbox in collaboration with RBI for
enabling innovators to experiment their solutions for eventual adoption. [para-6.1.10
page- 59]

 In order to identify and monitor the challenges associated with the development of
major FinTech innovations and to assess opportunities and risks arising for the
financial system from these innovations, a ‘dedicated organizational structure’ within
each regulator may be created. [para-6.1.16 page- 62]
 Financial sector regulators should engage with FinTech entities in order to chalk out
appropriate regulatory response and re-align existing regulatory and supervisory
framework. [para-6.1.16 page- 62]
 Regulatory and legal reforms are essential to enable the sustained development of a
digital financial industry for the future. [para-6.1.16 page- 62]

68
 Partnerships/engagements with regulators, existing industry players, clients and
FinTech firms will enable the development of a more dynamic and robust financial
services industry. [para-6.1.16 page- 63]
 Regulators may decide to use Reg Tech technologies that may facilitate the delivery
of regulatory requirements more efficiently and effectively than existing capabilities.
[para-6.1.17 page- 63]
 The organizational structure and human resources (HR) practices of regulators need
to be geared up to meet the challenges of innovation, in terms of adapted HR hiring
profiles, learning and educational programmes. [para- 6.2 page-64]
 Identify organizational structure considerations that regulatory agencies can apply in
responding to new innovations. [para-6.2 page-64]
 Individual regulatory agencies to assess the different skill sets that they have
assigned towards evaluating FinTech innovations. [para- 6.2 page-65]
 Identify specific technologies that regulatory agencies may benefit from having or
may need to have appropriate expertise to supervise. [para- 6.2 page-65]
 Realignment of existing supervisory framework. [para- 6.2 page-65]
 Developing policy stance enhancing knowledge. [para- 6.2 page- 65]
 The adoption of digital channels to replace manual time-consuming processes to
empower customers and / or workforce in insurance sector. [para- 5.3.2.2 page-50]
 Innovation labs within insurance companies may be established to combine brand
and product managers with technological and analytical resources. [para- 5.3.2.2
page-51]
 Advanced statistical models may be deployed to understand the correlation between
measurable factors and risk (actuarial) using historical data in insurance business.
[para- 5.3.2.2 page-51]
 There is need for a stand-alone Data Protection Law in the country. [para-5.4.1
page-53]
 Given that FinTech companies are in their infancy but are growing at a rapid pace,
the Government may consider introducing tax subsidies for merchants that accept a
certain proportion of their business revenues from the use of digital payments as
opposed to cash. [para- 6.5.1 page-66]

69
 The requirement of increasing the levels of education/ awareness of customers
should be highlighted by all market regulators as well as the self-regulatory body for
FinTech companies. [para- 6.6.2 page-67]
 Banks may be encouraged to collaborate with FinTech/start-ups to improve their
customer experience and operational excellence. Banks may also undertake FinTech
activity in areas like payment, data analytics and risk management areas. [para-6.3.2
page-65]
 Models of engagement and checklist to be developed by each regulator for each
activity. [para-6.1.16 page- 63]
 FinTech companies take an approach that is more collaborate than disruptive.
Insurance companies may collaborate with Insurtech entities or start-ups to provide
better customer experience with cost effective manner. [para- 5.3.2.5 page- 51]

70
 Annex-1

S.No Name of Start-up Technology offered

1 Fairassets Technologies India P2P Lending
Pvt. Ltd.
2 Tonetag Sound mobile based mobile to mobile, mobile to
POS payment without internet without Bluetooth
solution
3 Coinn Mobile Technologies Bluetooth based Payment solution
Pvt. Ltd
4 Abhar Technologies & Service IOT, Enterprize non IT project management
Pvt. Ltd.
5 Neural Brain Technologies Pvt. Machine learning based Analytics for productivity
Ltd. analytics
6 Skybits Technologies Pvt Ltd. AI and machine learning based solution for email
segregation, auto response and face recognition .
7 FTL technologies Systems Pvt. Online market place
Ltd.
8 Vibil Technologies Pvt Ltd Machine Learning and OCR based real time
eKYC verification with adhaar, RTO ,passport,
PAN, Cibil ,Income tax offices.
9 Signzy Technologies Pvt. Ltd. Machine Learning and OCR based real time
eKYC verification with adhar, RTO,passport,PAN,
Cibil and Income tax offices
10 S2pay digital Payment Solution without buddy and state bank
11 Lyncbiz India Pvt. Ltd. Gamification
12 VuNet Systems Pvt Ltd MLP based Data Analytics(Specially fopr ATM
and network)
13 Paydigital technologies pvt ltd Independent payment solution mainly for
institutions and Universities. Icollect can
independently manage this solution.
14 Liv artificial intelligence pvt ltd.
Voice recognition, Artificial Intelligence, Natural
Language processing
15 Propalms Technologies Pvt Ltd Server Virtualization ,work from home
(Accops)
16 Prime Chain Technologies Pvt Block chain Technologies
Ltd
17 Think Analytics India Pvt Ltd Data analytics
18 Woas Technologies Pvt Enterprise WhatsApp and rapid small application
Ltd.(Wooqer) development
19 Active.AI Artificial Intelligence, Natural Language
processing
20 Custmore Interactive Solutions Customer engagement plateform
Pvt. Ltd.

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 Annex-2
Disclosure Light Touch Full-fledged
Mobile wallet
e-commerce platform
Payment bank
Recharge
Bill payments
Online marketplace providing customized rate
quotes on loans and insurance products
Online Lending
Financial inclusion technology provider
Multi-Purpose Prepaid Cash Card
PoS terminal for accepting card payments
Payment device maker
Payment gateway
Payment services through retail outlets
Loyalty relationship management company
Real-time market data and financial news
Online investment platform for mutual funds
Insurance aggregator and selling platform
Analytics, Risk Compliance Solutions for Banking
Small business lending
Online platform that provides working capital for
SMBs in India
Multi-brand gift card store
B2B backend technology provider
Web mobile based personal finance management
platform
Cloud based management platforms for lending
institutions
Smartphone application for P2P money transactions
Virtual marketplace for money borrowers and lenders
Managed subscription billing service for SaaS
BFSI software provider
Branchless Mobile Banking
Alternative payments solution for e-commerce
companies to allow users to buy and pay later
Online retail brokerage firm
Care coordination solutions for healthcare
organizations
Fraud Customer experience management solutions
for financial, retail and telecom industry
Cloud based compliance platform
Market intelligence platform for private market
investing
Free Income Tax preparation and e-filing portal
Web-based deal origination tool for PE firms and
investment banks
Financial planning and management tool
Credit management services
Online selling and comparison platform for insurance
72
References / Bibliography

1 M/s Backwaters Tech Pvt. Ltd., Faircent Technologies India and Deutsche Bank and Bill & Melinda
Gates Foundation

2 KPMG-The pulse of Fin Tech- https://home.kpmg.com/xx/en/home/media/press-

releases/2016/03/kpmg-and-cb-insights.html

3 Drawing on a categorization from WEF, The Future of Financial Services, Final Report, June 2015

4 Committee on Payments and Market Infrastructures, “Digital Currencies,” November 2015.

5 Fintech: Describing the Landscape and a Framework or Analysis by STANDING COMMITTEE

ON ASSESSMENT OF VULNERABILITIES of FSB-March 2016

6 In the US, new P2P lending was USD 12 billion in 2014, (USD 7 billion in unsecured consumer
loans and USD 5 billion in small business loans). In the UK, P2P platforms originated about EUR 2.7
billion in 2015. Source: Morgan Stanley (2015) “Global Marketplace Lending: Disruptive Innovation in
Financials”. Source-Bloomberg

7 Fintech: Describing the Landscape and a Framework or Analysis by STANDING COMMITTEE

ON ASSESSMENT OF VULNERABILITIES of FSB-March 2016

8 CGFS, Fixed Income Market Liquidity, January 2016

9 The Pulse of Fintech, KPMG, 2016

10 India emerging a hub for Fintech start-ups, Business Standard, http://www.business-

standard.com/article/companies/india-emerging-a-hub-for-fintech-start-ups-116051700397_1.html, 17
May 2016

11 India emerging a hub for fintech start-ups, Business Standard website, http://www.business-
standard.com/article/companies/india-emerging-a-hub-for-fintech-start-ups- 116051700397_1.html,
accessed on 25 May 2016.

12 Statista website, https://www.statista.com/outlook/295/119/fintech/india, accessed on 25 May

2016, 17 May 2016

13 Application of Blockchain Technology in Indian banking and financial sector by IDRBT-January

2017

14 http://www.fsb.org/wp-content/uploads/Chatham-House-The-Banking-Revolution-Conference.pdf

15 http://pubdocs.worldbank.org/en/877721478111918039/breakout-DigiFinance-McConaghy-Fin
Tech.pdf

16 https://www.afm.nl/nl-nl/professionals/nieuws/2016/jun/innovation-hub

17 http://www.bis.org/review/r161111c.htm

18 http://www.bis.org/review/r160823d.pdf

19 Watal Committee: http://www.finmin.nic.in/reports/watal_report271216.pdf

73
20 https://www.fca.org.uk/publication/feedback/fs-16-04.pdf

21 https://www.straittimes.com/business/banking/225m-boost-for-finnacial-technology

22 https://www.crowdfundinsider.com/2016/09/90450-investhk-initiativeshk-first-hong-kong-fintech-
week/

74
 Abbreviations

ADLC - Application Development Life Cycle

AEPS - Aadhaar Enabled Payment System
AFM - Authority for Financial Markets
AFS - Australian Financial Services
AI - Artificial Intelligence
ALMS - Audit Log Management System
AMC - Asset Management Company
API - Application program interface
ASIC - Australian Securities and Investments Commission
ASTRI - Applied Science and Technology Research Institute, Hong Kong

BCBS - Basel Committee on Banking Supervision

BCT - Block Chain Technology
BFSI - Banking and Financial Services Industry
BHIM - Bharat Interface for Money
BIS - Bank for International Settlements

CAGR - Compound annual growth rate

CBRC - China Banking Regulatory Commission
CDP - Customer Data Protection
CEC - Credit Eligibility Certificates
CFPB - Consumer Financial Protection Bureau
CGFS - Committee on the Global Financial System
CPMI - Committee on Payments and Market Infrastructures
CRISIL - Credit Rating Information Services of India Limited
CSR - Corporate Social Responsibility

DACR - Detailed Application Control Review

DCs - Digital currencies
DFAC - Digital Finance Advisory Committee
DLT - Distributed ledger technologies
DNB -Dutch Central Bank

75
E

EDR - External Dispute Resolution

FCA - Financial Conduct Authority

FDIC - Federal Deposit Insurance Corporation
FIN -Financial Innovations Network
FinTech - Financial Technology
FMI - Financial Market infrastructure
FOS -Financial Ombudsman Service
FSB - Financial Stability Board
FSCS - Financial Services Compensation Scheme
FSDC-SC - Financial Stability and Development Council - Sub Committee
FTIG - Fin Tech and Innovation Group

HKMA - Hong Kong Monetary Authority

IDR - Internal dispute resolution

IDRBT - Institute for Development and Research in Banking Technology
IFSC - Indian Financial System Code
IIT-KGP – Indian Institute of Technology, Kharagpur
IMPS - Immediate Payment Service
IOT - Internet of Things
IRA - Intelligent Robotic Assistant
IRDA - Insurance Regulatory and Development Authority
IRMF - Incident Response & Management Framework
ISO - International Organization for Standardization

JFSA - Japan Financial Services Authority

KYC - Know Your Customer

76
L

LC - Letter of Credit

MAS - Monetary Authority of Singapore

MDR - Merchant Discount Rate
MFD -Mutual Fund Distributor
MMID -Mobile Money Identifier
MOU - Memorandum of Understanding
MSEs - Micro and Small enterprises

NACH - National Automated Clearing House

NASSCOM - National Association of Software and Services Companies
NEFT - National Electronic Fund Transfer
NLP – Neuro-Linguistic Programming
NMS - Network Management and Security
NPCI - National Payments Corporation of India
NUUP - National Unified USSD Platform

O
OCC - Office of the Comptroller of the Currency

P2P - Peer-to-peer
PFRDA - Provident Fund Regulatory and Development Authority
PoC - Proof-of-Concept
PPI- Pre-paid payment instrument
PRA - Prudential Regulation Authority
PSP - Payment service provider

QR - Quick Response

RBI - Reserve Bank of India

RTGS - Real Time Gross Settlement System

77
S

SEBI - Securities and Exchange Board of India

SHG - Self Help Group
SIEM - Security Incident and Event Management System
SMAC - Social media, Mobile computing, Analytics & Cloud
SOP - Standard Operating Procedure
SSB -Secretarial Standards Board

TFFT - Task Force on Fin Tech

UIDAI - Unique Identification Authority of India

UPI - Unified Payments Interface
USSD - Unstructured Supplementary Service Data

VC - Venture Capital

WBG - World Bank Group

78