大型银行和大型科技公司：决策者如何应对可能出现的挑战（英文版）.pdf

How policy-makers could respond to a probable discontinuityDISCLAIMER This report is the joint product of the International Banking Federation and Oliver Wyman. Members participated in their personal capacity, and their participation does not imply the support or agreement of their respective public or private institutions. ACKNOWLEDGEMENTS The authors of this report would like to express their appreciation to those whose time, talent, and energy have driven this research and the report completion. They would like to thank the members of the Steering Committee and Working Groups from IBFed, who guided their work at every stage and added their diverse insights in multiple interviews, meetings and reviews. They would also like to extend their appreciation to the Oliver Wyman team, for their project coordination and expert input, as well as to the various colleagues across the firms global financial services, public sector, policy and digital practice groups for their ideas and feedback on the work conducted. They cannot name but must also thank the various professionals, executives, academics and authorities who provided their insights through anonymized interviews. The intellect and collective experience brought to the table by all of those involved was essential to the richness of the research in such a broad and fast-evolving topic. Hedwige Nuyens IBFed Managing Director Lisa Quest Oliver Wyman Maria Jardim Fernandes Oliver WymanIBFED FOREWORD In recent years, technology has fundamentally reshaped our economy and the way all companies interact with their customers. This wave of digitization has touched nearly every industry, and banking is no exception. Banks have embraced this change and are investing in new technologies to bring their customers the latest innovations. In addition, a crop of nimble startups (often known as fintechs) have entered the market, often partnering with banks or connecting directly with customers. More recently, large diversified technology companies have increasingly moved into financial services. These big-tech companies are building financial products that closely resemble traditional offerings, but often offer different protections. Moreover, they are not driven by the same incentives as financial institutions. These big-technology companies create value by establishing, cultivating, and cementing relationships with customers and collecting data on these customers across a broad set of services. They then analyze and apply that data to predict a customers needs and preferences and offer them targeted products and services. Because of financial datas value, big-technology platforms persistently are looking for ways to obtain consumer financial data by offering financial services products. These new business models raise questions for banks as they consider how best to serve their customers in an increasingly digital economy. More importantly, they also raise serious questions for regulators as they seek to ensure that financial services are delivered in a safe, secure, and fair manner. Today, banks are partnering with technology companies of all sizes to deliver the latest innovations to their customers. These partnerships give customers access to new technologies delivered by a trusted partner. This trust is backed up by robust regulation and proactive oversight. However, when a consumer builds a direct relationship with a technology company, they often unknowingly forfeit many of these protections. The following report explores how these new business models are developing and identifies areas where existing financial regulation may not have considered the way technology is being used to offer financial services today. Rob Nichols IBFed ChairmanIBFED FOREWORD There is no doubt that big tech has changed how many of us live our lives. The way we work, shop, socialise, find and share information has been transformed by these technological powerhouses. In banking, the advance of technology is altering the sectors landscape, helping firms to reshape their customer offering and drive efficiency. While major fintech operators have emerged, so far, in the West at least, big tech has yet to expand its dominance into financial systems on a considerable scale. But its only a matter of time before they do. As this report, IBFeds first, demonstrates, while the rise of big tech creates new opportunities, it also brings new risks. The challenge of a concentration of market power, the diffusing of accountabilities and financial activities outside of the traditional regulatory framework. The banking system is built on stability, resilience and trust. It works within strict rules on issues such as consumer protection, anti-money laundering and governance. If financial products move outside of this sphere how do we maintain these high standards? With thanks to Oliver Wyman for their work with IBFed, this report explores how these challenges can be met and the reforms required to regulate the next evolution of the market. Its clear that finance and big tech is set to increasingly converge, its important the actions are taken now to prepare. That way we can realise the benefits for banks, technology firms and, most importantly, the customers we serve. Bob Wigley Chairman of UK Finance Adjunct Professor, University of Queensland, Faculty of Business, Economics and LawOLIVER WYMAN FOREWORD The banking system has experienced disruptive change constantly through history. Comparatively ancient history gives us the word “credit” (from Latin “credo”, meaning I believe) that became a recognizable “business” in Renaissance Italy. Banking constantly re-invented itself with the central banking and public funding innovations of the seventeenth century (Netherlands and Britain), systems anchored on precious metals (Spanish empire and subsequently the gold standard) and of course the waxing and waning of great banking dynasties (Medici, Fugger, Rotshchild, JPMorgan, Warburgs). Great crises were almost always the catalyst of major banking reform and restructuring, perhaps as far back at the Latin American crisis of 1825 and of course more recently in the Great Financial Crisis of 2008/9. Entering the 2020s, the banking sector is facing the formidable challenge of responding to COVID- related changes to customer behavior and the adverse impact of economic weakness. In parallel, there is the presence of a potential new class of competitors with powerful networks and deep investment pockets (the so-called big techs). This combination of factors will most likely drive significant discontinuity in the banking sector. This report analyses the competitive dynamics in major markets. The status quo is defined by continued dominance of traditional banking players, and a niche penetration by big techs and specialist fintech in most major markets. However, in a few major markets, the analysis highlights how the unique scale and “ecosystem” model of bigtechs has the potential to fundamentally change competitive dynamics in banking. We have spoken with a broad range of industry participants and policymakers across most major markets to gauge current views and challenges for the future. This report raises important questions for policy- makers, banks and society in general. Big tech technology capabilities can bring benefits in customer outcomes and efficiency that can be put to good use for society to serve inclusion, to fight financial crime, to improve the cyber and operational resilience of our financial system, to name a few. But they also raise new types of risks and challenge the traditional “vertical” (sector- oriented) model of regulation and supervision, which may no longer serve societys best interest today. The main question for banks is how to prepare for the possibility of a major incursion of thebigtechsinto their core markets, where this has not happened already. It is possible that big techs choose not to engage in core banking markets, but the general sense from our interviews it is not a question of if but when. Banks may therefore need to rewrite their past formula of success, and transform the way they serve customers, interact with third-parties and make the very fundamental strategic choices of whether they wish to compete as a “network” business model or compete in specific businesses serving others network. Financial services policy-makers quite rightly have prioritized COVID response and forebearance in the banking sector. However, there is a clear need to get on the front foot to support and shape an orderly modernization of the financial sector that will be required in the post-COVID economic and financial regeneration. The two extremes of policymaker response are unattractive: 1. unfettered, open competition with a blanket relaxation of participation rules will pole-axe weak banking business models and create financial stability risks and probably consumer protection issues; 2. high barriers to entry for non-banking players will slow down innovation and protract the existence of non-viable banking models. There is an optimal policy response somewhere in between the two extremes: this will require policy-makers to think differently with respect to competitive boundaries, accept higher uncertainty and faster responses and possibly re-think the institutional architecture that governs the intersection of financial services and technology sectors. In a world that is understandably concerned with COVID response, we hope these insights highlight the risks of a disruptive change that could result from banking sector weakness and restructuring, and encourage policy-makers and the banking sector to invest time in shaping successful future business models and the orderly transition required. Davide Taliente Managing Partner For Oliver Wyman EMEA Jacob Hook Managing Partner For Oliver Wyman APROliver Wyman 7 GAFAM now account for 5 of the 6 largest companies in the world and represent 18% of S Docomo, Rakuten, and Naver in Japan and Korea; and Vodafone and Orange in Africa). They are known collectively as the “regional players.” In many ways, these big techs amplify the fintech proposition already underway (see Exhibit 1). First, they bring astonishing scale and growth. GAFAM now accounts for five of the six largest companies in the world and represents 18 percent of the SnumberofendcustomersforKlarn a;annualactiveuserfor Alipay. C Mer chantacquiringvalueforJPMor ganforcompar ability(i.e.e x cludingFXtr ading,cheques, etcOliver Wyman 17 CASE STUDY Amazon began its lending business in 2015 with credit cards and the Amazon Credit Builder program in partnership with Synchrony Bank. In 2011, it entered merchant lending by launching Amazon Lending in the United States, offering revolving credit for small and medium sellers in the Amazon e-commerce platform using Amazons own capital or bank partners funding (for example, BAML). It scaled its activities to $1 billion in loan origination in 2018, the equivalent to a midsized national SME lender in the United States. Amazon Lending uses SME transaction records on the platform to assess credit worthiness and to set optimal interest rates and credit limits. More transactions enable better understanding of risks and scoring in the future in a virtuous cycle, opening the opportunity for other targeted products and services such as cash management or factoring. Merchant SMEs, in turn, see their sales facilitated via the platform, encouraging higher volumes, more products, and higher retention. This facilitates growth for both parties. A similar principle applies to private consumers with credit cards. Despite this, it should be noted that Amazon Lending is not open to any customer; rather, merchants need to be offered a loan. Comparison between traditional SME bank loan and Amazon Lending Bank SME loans Amazon SME lending APR/Fees 4 13% APR origination fee applies 10 14% APR no origination fees Distribution channel Mostly offline Amazon seller platform (invite-only) Approval time Typically three to five weeks five days Credit assessment data Credit bureau, financial statements, and so on Business data (transactions, etc.) in the Amazon marketplace Collateral Typically required unsecured loan also available Inventory to act as collateral Prepayment Penalty typically applies No prepayment penalty Sour ce:CB Insights(2019), PayPal, bank websites,Oliver Wyman research AMAZONS CREDIT BUSINESSOliver Wyman 18 BIG BANKS, BIGGER TECHS? | Big Tech In Banking Nonetheless, this motivation is reinforced by high investor expectations for continuous rewards for outsized growth. This will necessarily drive big techs businesses into adjacencies to their core businesses through their privileged data and share of attention for the most important customer needs. In addition, big techs sheer scale and power in the daily activities of consumers enables them to quickly deploy digital capabilities to new use cases in a test-and-learn fashion, quickly surpassing any fintech or incumbent in doing so. Not to mention that they are too big to be acquired by incumbents. WHAT IS THE REAL NATURE AND SCALE OF OPERATIONS? Given their ecosystem mindset for entering financial services, big techs have focused on retail and SME products that entail frequent customer contact and facilitate their core businesses, such as payments, e-wallets, and e-commerce consumer finance. This targeted approach has allowed them to enter the market with specific, activity-based licenses such as e-money and small lending licenses. In general, there has been limited appetite from big techs to focus on activities or parts of financial value chains with high regulatory costs, in particular in activities related to deposit-taking that require full banking licenses. This implies that most financial services provided by big techs are “overlays” on top of incumbents products and infrastructure, while big techs focus on the customer-facing layer. Payments is a good example here: Most mobile payment apps run on existing payment rails from traditional providers, and money balances are linked to traditional current accounts provided by banks. Apple Pay, for example, enables contactless payments via Apple devices but builds on participating banks infrastructure and customers current accounts with those banks, from which amounts paid are debited. Apple Pay is now available in more than 40 countries across numerous restaurants, shops, and online apps. In turn, front-end activity in corporate banking, investment banking, and long-term lending has also so far been limited, due to the requirement of more complex and specialized financial expertise, larger balance sheets, as well as more sophisticated and customized needs. Although many fintechs support wholesale markets with targeted technology capabilities (as seen in foreign exchange and algorithmic trading), there is still a lack of interest from the big techs given the low level of adjacency to