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Finance Norway

Question 1: Are the issues identified by the EBA and the way forward proposed in section 4.1 relevant and complete? If not, please explain why.
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.
Question 2: Are the issues identified by the EBA and the way forward proposed in subsection 4.2.1 relevant and complete? If not, please explain why.
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".
Question 3: What opportunities and threats arising from FinTech do you foresee for credit institutions?
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.
Question 4: Are the issues identified by the EBA and the way forward proposed in subsection 4.2.2 relevant and complete? If not, please explain why.
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.
Question 5: What opportunities and threats arising from FinTech do you foresee for payment institutions and electronic money institutions?
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.
Question 6: Are the issues identified by the EBA and the way forward proposed in subsection 4.3.1 relevant and complete? If not, please explain why.
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.
Question 7: What are your views on the impact that the use of technology-enabled financial innovation and/or the growth in the number of FinTech providers and the volume of their business may have on the business model of incumbent credit institutions?
This question is covered by the answers to the preceding questions.
Question 8: Are the issues identified by the EBA and the way forward proposed in subsection 4.3.2 relevant and complete? If not, please explain why.
NA
Question 9: What are your views on the impact that the use of technology-enabled financial innovation and/or the growth in the number of FinTech providers and the volume of their business may have on the business models of incumbent payment or electronic money institutions?
NA
Question 10: Are the issues identified by the EBA and the way forward proposed in subsection 4.4.1 relevant and complete? If not, please explain why.
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.
Question 11: Are the issues identified by the EBA and the way forward proposed in subsection 4.4.2 relevant and complete? If not, please explain why.
NA
Question 12: As a FinTech firm, have you experienced any regulatory obstacles from a consumer protection perspective that might prevent you from providing or enabling the provision of financial services cross-border?
NA
Question 13: Do you consider that further action is required on the part of the EBA to ensure that EU financial services legislation within the EBA’s scope of action is implemented consistently across the EU?
NA
Question 14: Are the issues identified by the EBA and the way forward proposed in subsection 4.4.3 relevant and complete? If not, please explain why.
NA
Question 15: Are the issues identified by the EBA and the way forward proposed in subsection 4.4.4 relevant and complete? If not, please explain why.
An analysis of whether the "Digital first" principle is sufficiently implemented across the member states should be carried out.
Question 16: Are there any specific disclosure or transparency of information requirements in your national legislation that you consider to be an obstacle to digitalisation and/or that you believe may prevent FinTech firms from entering the market?
NA
Question 17: Are the issues identified by the EBA and the way forward proposed in subsection 4.4.5 relevant and complete? If not, please explain why.
NA
Question 18: Would you see the merit in having specific financial literacy programmes targeting consumers to enhance trust in digital services?
NA
Question 19: Are the issues identified by the EBA and the way forward proposed in subsection 4.4.6 relevant and complete? If not, please explain why.
NA
Question 20: Are the issues identified by the EBA and the way forward proposed in section 4.5 relevant and complete? If not, please explain why.
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.
Question 21: Do you agree with the issues identified by the EBA and the way forward proposed in section 4.6? Are there any other issues you think the EBA should consider?
NA
Question 22: What do you think are the biggest money laundering and terrorist financing risks associated with FinTech firms? Please explain why.
NA
Question 23: Are there any obstacles present in your national AML/CFT legislation which would prevent (a) FinTech firms from entering the market, and (b) FinTech solutions to be used by obliged entities in their customer due diligence process? Please explain.
NA
Contact name
Mr. Jan DIGRANES