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In principle, I'm totally opposed to the Drunk Under Lamp Post APP Scam Reimbursement Rule but I do like your line "Faster Payments leads to Faster Frauds but Slower Payments does not Slow Fraudsters, what's needed is Cleverer Payments"!  

I've never understood this regulators' obsession with data. 

Data doesn't update itself. Code updates data. Code stores data in the software vendor's proprietary format, which is not intelligible to others, including the owner of the data itself. The vendor controls the code. Even if the software enables downloading of the data in CSV / open formats, the vendor controls access to that feature and can brick it unilaterally anytime. How does the location of data even matter? 

Per my conspiracy theory, SAAS vendors' eagerness to cooperate with regulators on data protection regs is a cunning ruse to divert their attention from the primacy of code and the near-futility of trying to regulate data.

In the context of BaaS, "disruption" can't mean anything in a good way.

Bank v. Neobank: Safety Of Money In The Light Of Synapse - Evolve Fracas

There's no shortage of GenAI pilots. Catch is, as Gartner recently reported, a third of GenAI projects will be axed after the PoC. While AI Maxis might spin that as "YaaY, a vast majority (67%) of GenAI PoCs will turn into full blown projects", it'd help to get some data on how many pilots have actually moved to production. 

The one big difference between technologies of the past and AI now is that AI can ingest unstructured data and produce structured output, so AI Maxis argue that companies need not even build a System of Record to replace SAAS and can run their AI loose on unstructured data created at the edge and AI will produce the same output as SAAS without building an SoR. 

AI offers banks the tantalizing opportunity to cut costs and increase profits by shutting down Pega, Salesforce, Workday, and other SAAS products they currently pay vendors big bucks for, and redevelop similar functionality inhouse by using AI Code Assistants like GitHub Copilot. I call that "SaaS Repatriation".

Last year, when I heard about Drunk Under Lamp Post regulation in UK re. FPS / APP Scam Reimbursement, I predicted that "Banks will thank regulators / PSR for giving them the chance to delay payments and earn float income under the pretense that they're 'carrying out extra due diligence on the authenticity of the payment'". That prediction just came true!

You can either screen all customers subject to sanctions or you can challenge traditional banks but you can't do both.

This is Exhibit A for my long held belief that you can either comply with all the rules that are applicable to traditional banks or you can challenge traditional banks but you can't do both. 

@TasiaVaniuta +1.

Safety of money has indeed become a big question mark in the BaaS model on the back of the Synapse-Evolve fracas, as I pointed out in my blog post titled Bank v. Neobank: Safety Of Money In The Light Of Synapse - Evolve Fracas.

However, while I await their reply to my previous comment, I'm guessing that the author is really talking about Embedded Finance rather than BaaS (assuming they're not talking about Checkout Providers, Merchant Aggregators and Payment Gateways). 

AFAIK, there's no concern regarding safety of money in the case of embedded finance since the End Consumer does not keep any money with the Embedded Finance Provider (unlike BaaS Provider).

For ages, fast growing ecommerce companies have been offering branded checkout, a variety of credit cards, debit cards and BNPL methods of payments by partnering with third party checkout providers (like Bolt), merchant aggregators (like Stripe) and payment gateways (like RazorPay). Can I add another question to your FAQ? "What's the difference between White Label Banking and Checkout Providers, Merchant Aggregators and Payment Gateways?"