Primary tabs

Finance Norway

It is important that the impact on competition in regulated markets from actors subject to a different regulatory regime than the incumbents is thoroughly analysed. Further, it is also of importance to analyze the impact on innovation from the market participants (incumbents) offering services to Fintech based on innovation hubs, startup labs, open banking and other ways of collaboration.
Credit institutions can both be purely incumbent actors but can at the same time be innovative fintech actors. Actually, credit institutions have been fintechs for decades. As innovative activities inside or outside a credit institution are regulated differently, we support the split of analyses of prudential risks and opportunities between credit institutions and fintech"."
Fintech delivers their services both to credit institutions and to customers directly. They do it both on their own or in collaboration with credit institutions. We see also that collaboration can be based on fully/partly ownership by credit institutions. Threats can arise both from security issues as well as operational aspects. The analysis should therefore cover both aspects.
As pointed out in sec 89 of the discussion paper, it is important to cover use of DLT/Blockchain in all kinds of banking services, not only for payments.
It is well acknowledged that fintech contributes well to the innovation in many parts of the financial markets. We welcome the discussions on what risks and threats this imposes on the markets, services and participants that are introduced. As has been mentioned by the EU commission recently, there has to be a fair balance between the risks and the needs of the different stakeholders.
In addition to the issues identified we also see cases where incumbent credit institutions collaborate with fintech and by that contribute to that they both take advantage of products and services developed in the intersection between them.
Sustainable business models should secure that producing costs are covered by the users of the services. An analysis should cover a study on to what extent this criterion could be met, to avoid cross-subsidizing between customer groups or products.
This question is covered by the answers to the preceding questions.
NA
NA
We support the approach to protect consumers from risks arising from both fraud and cyber threats that arise as results of innovation, regardless of where the risks originate from. In this respect, it would be recommendable to look to the regulatory requirements related to similar risks connected to services provided by credit institutions.
NA
NA
NA
NA
An analysis of whether the Digital first" principle is sufficiently implemented across the member states should be carried out."
NA
NA
NA
NA
Credit institutions are subject to well defined regulation and capital requirements that make them well suited for imposing low risks in the value chain for payment services.
We see that fintech activities from outside credit institutions in some areas have significant impact on both financial, technical and operational risks in the systems.
Fintech having impact on financial stability or entering into possession of customer funds, should be subject to a resolution regime and contribute to financing it in relation to the risk they inflict on the market.
NA
NA
NA
Mr. Jan DIGRANES
+4790967654