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This was implicit in my previous reference to Indian regulator's recent mandate re. Loan flow. Anyway, to make it explicit: Slice & UNI. 

You can clarify all you want but the only thing that matters is what the regulator says and, as I mentioned, its latest announcement clearly implies that fintechs are unregulated entities.

Your article opens with "Fintech is a highly regulated sector".

I made a specific comment that your premise is false. In fact, your premise goes against the founding principle of Fintech, which is that it can do what regulated entities can do but do it faster, better and cheaper than regulated entities because it is not regulated.  

Since I didn't see evidence that you got my specific comment, I gave additional context in my subsequent comment. 

Let me try with some more context.

According to the Indian banking regulator's recent mandate, "Loans must go directly from regulated entities to customer accounts. Loans cannot pass through fintechs."

It follows that fintechs are unregulated. 

QED.

#ProTip: You focus on what to write on a professional forum - Hint: No posts based on false premises - and I'll focus on what to comment on a professional forum.

Opening accounts on stolen identity a/k/a Identity Theft Fraud is an endemic problem with nearly all forms of MOPs - even nearly everything in financial services. 

Is there any evidence to suggest that Identity Theft Fraud is particularly alarming in the case of BNPL? 

Nice post. 

As a n00b, I can do with a bit of elaboration on the steps involved between order placement and order execution, so that I can understand how a trader can place an order but not execute it a/k/a indulge in spoofing.

As a retail punter, I have not seen any difference between the two steps: AFAIK, once I place a BUY order, poof it's gone, I can't stop the order from being executed by the eBroker (as long as there's sufficient funds in my account to cover the order value.)

As they say, in a democracy / capitalism, everything is allowed except that which is banned, and no regulation DOES mean not regulated.

Maybe you're stuck in the old authoritarian / commie era or whatever but startups in ecommerce, rideshare, and epharmacy began by doing stuff that was neither allowed nor banned by law a/k/a leveraged regulatory gap. They then became too big to have to comply and the rules changed to regularize their business models. Crypto did this with mixed success.

Time will tell whether fintechs can  pull off the same strategy - but I'm hopeful: The history of VC-backed industries has shown that, when you alleviate a compelling pain area of the market, you'll always find a way to succeed despite periodic PITA moves by the regulator. 

When I pay with credit card at a supermarket till - as I've been doing ever since I got my first credit card in the late 1980s - I get rewards, deferred payment, fraud protection and a myriad of other benefits.

Why would I pay with an A2A RTP like Zelle / FPS / UPI and forfeit all those benefits?

We've been hearing about Alternative Payments for 15 years. Merchants have always preferred them over credit card. Still they have failed to go mainstream. I suspect that's because they've failed to answer the above question about "what's in it for the consumer?" Unless they do that now, I doubt if they'll succeed in future either. 

Maybe UK Finance doesn't want egg on its face with over-optimistic projections? 

Just one bank sized its FPS infra in 2007-8 for a projected Year 3 load of 2400TPS ~ 76B transactions per year.

Against that, the entire industry has hit 3.6B TPY in Year 14, which is less than 5% of that single bank's projection for Year 3. 

Can't  blame UK Finance for not being more aggressive in its projections of FPS volumes.

"FCA has brought action against 4,226 BNPL firms this year."

OMG.

I never imagined that there'd be this many BNPL firms even all over the world, let alone in just FCA's jurisdiction of UK.

Because regulator may not let them leverage such opportunities?

I don't know about Brazil but many major regs in payments space in India in the last 2-3 years - e.g. Positive Pay, Emandate, CoFT - have added friction to cheque and credit card payments and intentionally or unintentionally diverted cheque and credit card volumes to UPI.