Innovative Fintechs Don’t Need No PSD2 Regulation

[Pink Floyd fans won’t need any explanation for this post's title. As for the others… well, it’s never too late to become fans of Pink Floyd!]

The recent buzz around Artificial Intelligence and Machine Learning has spawned the next generation of Personal Finance Management applications. While the forerunners in the cateogory like Mint (now part of Intuit, Inc.) are still available on the web, most of the new players are mobile-only. Going by monickers such as Mobile Money Management App and Money Management Bot - herewith termed MoMMA for the sake of convenience - they all require access to their users’ bank account information.

This has become a bone of contention of late with banks reminding their customers that their TOS forbid them from handing over their online banking credentials to third parties (I don’t know what took all but a handful of banks so long to assert an old clause in their terms of service - actually, I think I know, but that’s a blog post for another day).

As a result, MoMMAs have been looking to “Open Banking” regulations like PSD2 to give them a leg up. For the uninitiated, PSD2 mandates banks to allow fintechs to access banking data of customers.

But banks are not taking this lying down. According to Financial Times, big banks are lobbying to reduce access to customer data envisaged by PSD2, which would substantially dilute the original provisions of "open banking". According to Sebastian Siemiatkowski, chief executive of Swedish online payments company Klarna, quoted by FT, “If it (PSD2) goes ahead as currently written it will not create open banking as the law originally envisaged.”

Fearing an existential crisis, fintechs are fighting back.

They shouldn’t.

In fact, they should stay away from regulation. As I’d highlighted in Fintechs Need Marketers And Lobbyists – Not Lawyers and Fintechs Need Guts More Than Lawyers!, many successful startups have flourished by leveraging “regulatory gaps” rather than regulation.

Instead, MoMMAs should focus on becoming truly innovative and enhancing their value proposition.

Intuitively, everyone knows that "earn more, spend less" is all the money management mantra they need. To get people to use a MoMMA to practice this principle is a hard sell, made even harder by what's offered by the current breed of MoMMAs:

1. Transform the customer banking experience by enabling consumers to compare and save on current accounts, … look for mortgages more easily and access better terms for loans (Source: Finextra article titled Consumers unaware of Open Banking – Equifax)
2. Answer questions like "How much have I spent on Uber this month?" and "Can I afford to go for dinner?" (Source: Finextra article titled Personal Finance bot Cleo)
3. Protect customers from bankruptcy by telling them to avoid that $5.00 coffee. Okay, I’m joking about the bankruptcy but the part about the coffee is true.

IMHO, these features are quite lame because:

• MoneySuperMarket, Which? etc. have been letting us do comparison shopping for current accounts and mortgages for ages without needing any access to our banking info.
• What can we do about the money we've already spent on Uber?
• If we can't go for dinner, do we starve?
• We don't need a fancy MoMMA to tell us that $5.00 for a coffee is a big rip-off anyway - even if we won't bust our budget by buying it. 

Okay then, how can a MoMMA offer true value to its users?

I can readily think of a few ways by which it can do that. A MoMMA can, for instance: 

1. Give truly useful money management tips e.g. Earn $$$ more by sweeping X amount from a checking account to a savings product.
2. Indemnify customers from losses caused by data breach arising out of third party access to customers’ banking info.
3. Access only the info that customers permit them to access and prove that they're accessing nothing more, nothing less. Screen-scraping by using online banking password - currently the most widely used data access technology - fails this test. Once customers have given away their online banking passwords, they've very little visibility into what info the app is actually accessing.
4. Make data sharing UX frictionless. OFX is one prevailing technology that lets the user download only the info they explicitly want to share with the money management app or bot. However, most MoMMAs require frequent updates of transaction info to offer valuable tips, which means users have to keep logging into their online banking portals regularly to download their latest transactions. This can be painful.

Personally, as long as a MoMMA supports the above functionality, I'll gladly start using one.

Let's look at the feasibility of implementing these features.

#1 is related to consumer behavior and product management. #2 has a legal and financial angle. They’re both within the control of the fintech, at least the well-funded one.

#3 and #4 are related to technology. As I'd highlighted in P2FM Services Walk The Tightrope Between Convenience and Security and How Many More PFMs Do We Need? (hyperlinks removed to comply with Finextra Community Rules but these posts will appear on top of Google Search results when searched by their respective titles), data access modalities have posed major challenges to the viability of the first generation of PFMs 8-10 years ago. But, all that's history now. OFX-API seems to have cracked the Holy Grail of data access, going by the gung-ho views expressed by executives of JPMorgan Chase and Intuit when they recently announced their data partnership agreement based on this technology (Source: American Banker).

As a result, fintechs are closer than ever before to being able to leverage their innovativeness to develop a compelling value proposition for PFMs. If they achieve that, they can kick out their ‘open banking’ and PSD2 crutches.

In return for a frictionless UX, tens of millions of customers otherwise perceived to be highly security-conscious make payments with India’s largest mobile wallet app PayTM without entering a single password or PIN.

If MoMMAs give them a similarly compelling value proposition, people won’t care about sharing their financial data with them – with or without PSD2.

I’m not alone in this belief. As Metia's Steve Ellis comments on Finextra, “…the question on sharing personal data is the wrong way round. No-one agrees to share personal data without being offered some kind of fair value exchange for it. Show the consumer a compelling value proposition and they will do it in the blink of an eye.”

Fintechs who're still not convinced that they should shed their reliance on 'open banking' should just pause to contemplate their future if said regulation becomes two-sided and requires fintechs to share their customer info with banks.

Gasp!

I'm sure they'll now agree with my call:

Hey! Fintechs! Leave Them Regs Alone.