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Early Lessons on Regulatory Innovations to Enable Inclusive Early Lessons on Regulatory Innovations to Enable Inclusive FinTech: Innovation Offces, Regulatory Sandboxes, and RegTech This report is from the FinTech Working Group of the United Nations Secretary-General’s Special Advocate for Inclusive Finance for Development (UNSGSA) and Cambridge Centre for Alternative Finance (CCAF) at the University of Cambridge Judge Business School. It would not have been possible without the support of the Monetary Authority of Singapore (MAS) and the supervision and coordination of the Offce of the UNSGSA. The reference citation for the report is as follows: UNSGSA FinTech Working Group and CCAF. (2019). Early Lessons on Regulatory Innovations to Enable Inclusive FinTech: Innovation Offces, Regulatory Sandboxes, and RegTech. Offce of the UNSGSA and CCAF: New York, NY and Cambridge, UK. Foreword from the UNSGSA When the new Global Findex data was released last year, I was so pleased to see that since 2014, 515 million more adults globally have gained access to the fnancial tools they need. As of 2018, a staggering 3.8 billion people—almost 70 percent of all adults—are now fnancially included. Yet, there is still much to do. This new data also reveals the great power For many regulators in emerging and of innovative technologies to expand access developing economies, creating the to fnancial services—and, most importantly, regulatory tools to keep up with the fast ensure that people actually use these services pace of innovation is extremely challenging— to improve their lives. FinTech presents particularly in countries that lack resources amazing opportunities to empower the and staff with the technology skills to unbanked to protect themselves against understand FinTech’s rapid development. hardships and invest in their futures. This is why, in the past year, together with my FinTech Working Group,1 we have decided Last year when I visited Nigeria, I met a catfsh to document and share early lessons learned seller, Flora Edojah, who was able to transform on regulatory initiatives for FinTech with an her simple market stall in Lagos into a thriving emphasis on fnancial inclusion. business with the support of Lidya—a leading FinTech company. Although she approached This report is designed to help regulators, Lidya with no traditional collateral or credit especially from emerging and developing history, the company was able to approve economies, as they consider their own her loan quickly, with every step taking place approaches for regulating FinTech. It online, by analyzing the digital footprint of her reviews early lessons learned on innovative online supply purchases. regulatory initiatives such as regulatory sandboxes, innovation offces, and RegTech. This is just one example that reveals how It also contains a set of Implementation FinTech solutions can make products and Considerations for regulating innovation. business processes cheaper, faster, and more customer-centric by improving users’ This work would not have been possible experiences. FinTech can also drive more without the support from my FinTech competition and collaboration between Working Group, the Monetary Authority of traditional players, start-ups, and tech Singapore (MAS), and the great assistance companies. of the Cambridge Centre for Alternative Finance, who led the writing of the report However, technology is a double-edged with the help of numerous reviewers. sword. Innovations can sometimes amplify threats to consumers, such as large- Going forward, I am confdent that together, scale frauds, data privacy breaches, and we can tackle FinTech’s challenges and seize cybersecurity risks. Technology can also leave its potential to transform people’s lives for the behind unconnected and less digitally literate better. consumers. These new risks, speed, and complexity of FinTech can trigger regulatory overreactions that stife innovation. At the same time, if these risks are left unaddressed, H.M. Queen Máxima of the Netherlands they can harm customers and threaten United Nations Secretary-General’s Special stability. Advocate for Inclusive Finance for DevelopMent 1 UNSGSA FinTech Working Group is made up of members from AFI, Ant Financial, BFA, BMGF, BSP, BTCA, CGAP, IFC, MAS, McKinsey, Omidyar Network, PayPal, RBI, and the World Bank. Early Lessons on Regulatory Innovations to Enable Inclusive FinTech 3 Foreword from the Monetary Authority of Singapore Financial technology is transforming the way fnancial services are produced, distributed, and consumed. It has tremendous potential to improve peoples’ lives. FinTech promotes fnancial inclusion, enhances customer experience, and enables delivery of fnancial services at lower costs and faster speeds, allowing providers to reach out to the unbanked and uninsured segments of the community. This potential is especially relevant in this report. The journey continues as we fne- Southeast Asia where more than half the adult tune our policies and strategies to adapt to population is unbanked. However, the region new developments and constantly learn from also has the third highest mobile penetration the industry and our fellow regulators. rate in the world, behind only China and Those present at the MAS-UNSGSA India. With the power of a mobile phone in roundtable in Singapore last year felt that hand, millions of people in remote and rural regulators would beneft from a review of parts of the region can now make payments, insights drawn from the different FinTech buy insurance, and apply for loans. Poor regulatory approaches being taken around fnancial infrastructure and a lack of personal the world. The FinTech Working Group of the documentation or credit history are no longer UNSGSA and CCAF have done an excellent barriers to fnancial inclusion. job in collating feedback from more than 40 Like all technologies, FinTech is not without regulators. risk. Financial regulators play an important I hope this report will serve as a toolkit for all role in ensuring the balance between regulators as we progress along the FinTech promoting innovation and controlling risk, journey and harness its potential for people. especially in emerging and developing economies. The Monetary Authority of Singapore embarked on its FinTech journey just over Ravi Menon three years ago, learning and experimenting Managing Director along the way. We have introduced a number Monetary Authority of Singapore of innovations, some of which are covered in Early Lessons on Regulatory Innovations to Enable Inclusive FinTech 4 CONTENTS Executive Summary ...................................................................................... 7 Introduction .................................................................................................... 9 Chapter 1: Financial Innovation, Financial Inclusion, and Regulatory Innovation................................................................................10 1.1 Technology-enabled Financial Innovation and Its Impact on Financial Inclusion .............................................................................................. 10 1.2 Financial Innovation, Financial Inclusion, and Regulatory Objectives .............................................................................................................. 14 Chapter 2: Innovative Regulatory Initiatives Around the World 17 2.1 Innovation Offces ............................................................................................. 19 2.1.1 Innovation offces in practice .............................................................................20 2.1.2 Innovation offces and fnancial inclusion ....................................................21 2.1.3 Innovation offces – lessons learned ..............................................................23 2.2 Regulatory Sandboxes .....................................................................................26 2.2.1 Regulatory sandboxes in practice ...................................................................27 2.2.2 Regulatory sandboxes and fnancial inclusion ...........................................28 2.2.3 Regulatory sandboxes – lessons learned .....................................................30 2.3 RegTech ..................................................................................................................33 2.3.1 RegTech in practice ................................................................................................33 2.3.2 RegTech and fnancial inclusion ........................................................................35 2.3.3 RegTech – lessons learned ..................................................................................36 Chapter 3: Implementation Considerations ........................................38 Annex 1: Methodology and List of Interviewees .................................. 42 Annex 2: Further details for Figure 4 – Examples of Innovative Regulatory Initiatives Around the World ...............................44 Annex 3: Further details for Figure 5 – Examples of Global Innovation Offce Initiatives by Jurisdiction .........................50 Innovation Offces.........................................................................................50 Regulator/Central Bank Linked Accelerators ..................................51 Annex 4: Further details for Figure 7 – Examples of Global Regulatory Sandbox Initiatives by Jurisdiction ................... 52 Annex 5: Further details for Figure 11 – Examples of Global RegTech Initiatives by Jurisdiction ...........................................
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