Response to discussion Paper on innovative uses of consumer data by financial institutions

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1. In what capacity (i.e. consumer, financial institution, technology providers, etc.) have you had experience with innovative uses of consumer data?

Our organization is expected to work on that subject in order to respond to several comities and survey in the name of our members.
We are also part of many NGO and comities in charge of either the thought about or the management of new technologies in our jobs.
One of our representative for instance (also CEO of a financial firm) is in our name, Chairman of the national organization in charge of managing the new expected language for robots and aggregators, including users (our members), data providers and IT developer/aggregators.
One other representative (our chairman, also CEO of a firm) is member of the national comity for finance, consultative body for the ministry of finance and economic’s affairs. This comity is in an ongoing manner working on that subjects.

2. Based on your knowledge, what types of consumer data do financial institutions use most?

Mostly and perhaps much more efficiently than in the past, usual behaviors and especially spending and investment habits.
Obviously, but it is not new, personal and social topics and items (name, age, family, incomes, …).

3. Based on your knowledge, what sources of consumer data do financial institutions rely on most?

It depends on their model.
More Fintech they are and more they have a large offer, more items and topics they need to identify.
For a traditional firm “focusing its offer” the major criteria and data about its clients are enough.
Nevertheless, they will need to target clients in the market. And including for that last class of firms, it might be much more relevant than by the past, to define precisely the type of client interested in its offer.
Then, it becomes useful to work with an external firm, which can help them to identify the targeted clients and that firms may obtain much more data, in order to serve one or another financial institution.
EBA is focusing its work on “some” financial institution, but must keep in mind that with PRIIPS and the targeted market, financial firms offering that kind of products will need to address only to dedicated clients their messages and then, they will need more help from firms detaining the data.

4. Based on your knowledge, for what purposes do financial institutions use consumer data most?

First because we are in a capitalist world and we need efficiency. But also, because it’s a waste of time and it leads to a very poor image, to send stupid, insane messages to clients. The world changed for them too. They receive much more information than by the past. If you are expecting from your client a decision, to act in the way you propose and at the end of the end, to appear clever and a good choice for him, you need to send precise and efficient offers.

For what we understood, they offer internal products, mostly credits and investment solutions.
But we can also consider as efficient and some targeted insurance’s contracts, security offers, phone subscription.
Some firms propose press and convenience goods.

5. How do you picture the evolution of the use of consumer data by financial institutions in the upcoming years? How do you think this will affect the market?

It seems clear we will have a more targeted market.
For some reasons, not especially linked to data but having much more to see with diversification and turnover/margin without risk, we could have a huge increase of offers from other universe than finance.
In our opinion, data will be a treasury for those who will obtain and be able to analyze it. For a good use of it, we may be facing to an increasing situation of exchange and mobility of the data.

6. Do you consider the potential benefits described in this chapter to be complete and accurate? If not, what other benefits do you consider should be included?

Yes we consider it complete.
Perhaps could we add a benefit to authorities and States because of less fraud from both clients and firms and less mistakes made by the offering firms.

7. Are you aware of any barriers that prevent financial institutions from using consumer data in a beneficial way? If so, what are these barriers?

Of course.
National rules about protection of private life are very important and we must keep in mind the need for citizens not to be too much under control and known from someone they don’t nothing about.
And if ever their data may be under the hands of someone from the same firm, they well known, they may also be very tense about that idea. It is just humanbeing!

8. Do you consider the potential risks described in this chapter to be complete and accurate? If not, what other risks do you consider should be included?

Yes it seems to be complete to us.

9. Have you observed any of these risks materialising? If so, please provide examples.

Unfortunately, and obviously, we did.
Nevertheless, few of the defined risks are not actually risks because they have much to see with the idea of “business as usual”.
The risk “R2” is not a risk. It has always been like that. Firms are aiming to keep their clients. The more you well know them, the best you can do for them and better are your chance to keep them amongst your business. It was taught in the oldest High School from the beginning of the 20th century almost.
The risk “R5” can’t be avoid, except when the law decides a dedicated politic in order to help one or another part of the people. If we have a glance to the European and the National regulation, we can see it became more and more focused on the client protection. By the fact, providers became less and less allowed to propose non “suitabling” products to clients. In a certain point of view, we might say “everything came from the European regulation” and it has generated the all complexity and need for IT and data processing systems and …and targeted offers with positives and negatives effects.

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ANACOFI

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Financial advisors organisation