EU Consultation Fintech Action Plan Survey

NB: This 'EU Consultation on a Fintech Action Plan / New Digital Finance Strategy' Survey was announced on Tuesday 16th June at the "Ireland for Fintech" Webinar. Although we would encourage you to complete the EU Consultation Paper direct at https://ec.europa.eu/info/consultations/finance-2020-digital-finance-strategy_en, Fintech Ireland has created this complementary Survey for firms that may not wish to complete the EU Consultation Paper and would prefer to join a COLLECTIVE response. Unless necessary, we have followed the wording and format of the European Consultation. This Survey should only be completed by fintechs located in the Ireland, both the Republic of Ireland and Northern Ireland.

If you choose to complete this Survey by Fintech Ireland it is IMPORTANT that you have a copy of the Commission's Consultation Paper to hand for context and background. The link is in the above paragraph

Personal Data: The only personal data we are requesting is that of the person who is completing this survey on behalf of a fintech company (i.e. the agent of the company) and replicates the data being collected through the EU Consultation Paper. By completing the survey you, as agent of the company, are confirming that you are authorised to provide any and all of the information you furnish to Fintech Ireland and you hold us harmless should you fail to obtain the necessary authorisation from your company. You agree that we may process any personal data you, in your capacity as agent for the company, furnish to us for the purposes of contacting you to confirm the data furnished to Fintech Ireland. The information we receive in this Survey will be passed on to the European Commission and you have permitted us to to do so. The Commission's personal data protection provisions are here - https://ec.europa.eu/info/law/better-regulation/specific-privacy-statement.

Otherwise we will keep confidential and we will not share with anyone the specific answers you provide us except in aggregate form nor will we identify the name of any person or company to any person outside of Fintech Ireland except as provided for above.

Fintech Ireland is a registered trading name of the data controller Visible Compliance Limited (Irish company registration number 406557).

If you have any questions about this Survey please contact hello@fintechireland.com

2.First Name(Required.)

3.Surname(Required.)

4.Email (this will not be published)(Required.)

5.Scope(Required.)

International

Local

National

Regional

6.Organisation name(Required.)

7.Organisation size(Required.)

Micro (1 to 9 employees)

Small (10 to 49 employees)

Medium (50 to 249 employees)

Large (250 or more)

8.Transparency register number (obtain from transparency register) NOT MANDATORY

9.Country of Origin (country of origin of company or you if not a company)(Required.)

11.[Q EC] FIELD OF ACTIVITY OR SECTOR: Please specify your activity fields or sector(s): (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)(Required.)

12.[Q1 EC] What are the main obstacles to fully reap the opportunities of
innovative technologies in the European financial sector (please mention no
more than 4)?
Please also take into account the analysis of the expert group on Regulatory
Obstacles to Financial Innovation in that respect: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

13.[Q2 EC] What are the key advantages and challenges consumers are
facing with the increasing digitalisation of the financial sector (please
mention no more than 4)?

For each of them, what if any are the initiatives that should be taken at
EU level?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

14.[Q3 EC] The European Commission services are considering four key priority
areas for policy action to spur the development of digital finance:
(1) ensuring that the EU financial services regulatory framework is technology-neutral and innovation friendly; (2) reaping the opportunities offered by the EU-wide Single Market for digital financial services for consumers and firms; (3) promoting a data-driven financial sector for the benefit of EU consumers and firms; and (4) enhancing the operational resilience of the financial sector. DO YOU AGREE WITH THE CHOICE OF THESE PRIORITY AREAS?

Yes

Don’t know / no opinion / not relevant

15.[Q3.1 EC] Please explain your answer to question 3 and specify if you see
other areas that would merit further attention from the Commission: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

16.[Q4 EC] Do you consider the existing EU financial services regulatory
framework to be technology neutral and innovation friendly?

Yes

Don’t know / no opinion / not relevant

17.[Q4.1 EC] If not, please provide specific examples of provisions and
requirements that are not technologically neutral or hinder innovation: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.):

18.[Q5. EC] Do you consider that the current level of consumer protection for the retail financial products and services established by the EU regulatory framework is technology neutral and should be also applied to innovative ones using new technologies, although adapted to the features of these products and to the distribution models?

Yes

Don’t know / no opinion / not relevant

19.[Q5.1 EC] Please explain your reasoning on your answer to question 5, and where relevant explain the necessary adaptations: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.):

21.[Q6 EC - comment] If you see other technologies whose use would be limited in the financial services due to obstacles stemming from the EU financial services legislative framework, please specify and explain: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.):

22.[Q6.1 EC] Please explain your answer to question 6, specify the specific
provisions and legislation you are referring to and indicate your views on
how it should be addressed (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.):

24.[Q7 EC comment] Please specify what are the other ways the EU could support the uptake of nascent technologies and business models relying on them while also mitigating the risks they may pose (5000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

26.[Q8 EC comment] Please specify in which other financial services you expect technology companies to gain significant market share in the EU in the five upcoming years (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

27.[Q8.1 EC comment] Please explain your answer to question 8 and, if necessary, describe how you expect technology companies to enter and advance in the various financial services markets in the EU Member States (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

28.[Q9. EC] Do you see specific financial services areas where the principle
of “same activity creating the same risks should be regulated in the same
way” is not respected?

Yes

Don’t know / no opinion / not relevant

29.[Q9.1 EC comment] Please explain your answer to question 9 and provide examples if needed (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

31.[Q10 EC comment] Please specify which other prudential and conduct risk(s) you expect to change with technology companies gaining significant market share in financial services in the EU in the five upcoming years: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

32.[Q10.1 EC comment] Please explain your answer to question 10 and, if necessary, please describe how the risks would emerge, decrease or increase with the higher activity of technology companies in financial services and which market participants would face these increased risks: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

34.[Q11 EC comment] Please specify which other consumer risk(s) you expect to change when technology companies gain significant market share in financial services in the EU in the five upcoming years: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

35.[Q11.1 EC comment] If necessary, please describe how the risks would emerge, decrease or increase with the higher activity of technology companies in financial services and which market participants would face these increased risks: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

36.[Q12 EC] Do you consider that any of the developments referred to in the questions 8 to 11 require adjusting the regulatory approach in the EU (for example by moving to more activity-based regulation, extending the regulatory perimeter to certain entities, adjusting certain parts of the EU single rulebook)?

Yes

Don’t know / no opinion / not relevant

37.[Q12.1 EC comment] Please explain your answer to question 12, elaborating on
specific areas and providing specific examples: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method.)

38.[Q13 EC comment] Building on your experience, what are the main challenges
authorities are facing while supervising innovative/digital players in finance
and how should they be addressed?

Please explain your reasoning and provide examples for each sector you are
referring to (e.g. banking, insurance, pension, capital markets): (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

39.[Q14 EC comment] According to you, which initiatives could be put in place at EU level to enhance this multi-disciplinary cooperation between authorities?

Please explain your reasoning and provide examples if needed: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

40.[Q15 EC] According to you, and in addition to the issues addressed in
questions 16 to 25 below, do you see other obstacles to a Single Market for
digital financial services and how should they be addressed?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

42.[Q16 EC comment] Please specify what else should be done at EU level to facilitate interoperable cross-border solutions for digital on-boarding: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

44.[Q17 EC comment] Please specify what else should be done at EU level to facilitate reliance by financial institutions on digital identities gathered by third parties (including by other financial institutions) and data re-use/portability): (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

45.[Q18 EC comment] Should one consider going beyond customer identification and develop Digital Financial Identities to facilitate switching and easier access for customers to specific financial services?

Should such Digital Financial Identities be usable and recognised throughout the EU?

Which data, where appropriate and in accordance with data protection rules, should be part of such a Digital Financial Identity, in addition to the data already required in the context of the anti-money laundering measures (e.g. data for suitability test for investment services; data for creditworthiness assessment; other data)?:

Please explain your reasoning and also provide examples for each case you
would find relevant: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

46.[Q19 EC] Would a further increased mandatory use of identifiers such as Legal Entity Identifier (LEI), Unique Transaction Identifier (UTI) and Unique Product Identifier (UPI) facilitate digital and/or automated processes in financial services?

Yes

Don’t know / no opinion / not relevant

47.[Q19 EC comment] If yes, in which framework(s) is there the biggest potential for efficiency gains?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

48.[Q20 EC comment] In your opinion (and where applicable, based on your experience), what is the main benefit of a supervisor implementing (a) an innovation hub or (b) a regulatory sandbox as defined above?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

50.[Q21 EC comment] Please specify how else could the relevant EU authorities enhance coordination among different schemes in the EU: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

51.[Q21.1 EC comment] If necessary, please explain your reasoning and also provide examples for each case you would find relevant: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

52.[Q22 EC comment] In the EU, regulated financial services providers can scale up across the Single Market thanks to adequate licenses and passporting rights. Do you see the need to extend the existing EU licenses passporting rights to further areas (e.g. lending) in order to support the uptake of digital finance in the EU?

(5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

53.[Q23 EC comment] In your opinion, are EU level initiatives needed to avoid fragmentation in the Single Market caused by diverging national measures on ensuring non-discriminatory access to relevant technical infrastructures supporting financial services?

Please elaborate on the types of financial services and technical infrastructures where this would be relevant and on the type of potential EU initiatives you would consider relevant and helpful:

(5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

55.[Q24 EC comment] Please specify what else should be done at EU level to achieve improved financial education and literacy in the digital context:

(5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

56.[Q25 EC comment] If you consider that initiatives aiming to enhance financial education and literacy are insufficient to protect consumers in the digital context, which additional measures would you recommend?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

57.[Q26 EC comment] : In the recent communication "A European strategy for data", the Commission is proposing measures aiming to make more data available for use in the economy and society, while keeping those who generate the data in control.

According to you, and in addition to the issues addressed in questions 27 to 46 below, do you see other measures needed to promote a well-regulated data driven financial sector in the EU and to further develop a common European data space for finance?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

59.[Q27 EC comment] Please specify in which other area(s) you would see the need to facilitate integrated access to these data in the EU: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

61.[Q28 EC comment] Please specify what else would be needed to make these data easily usable across the EU: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

62.[Q29 EC comment] In your opinion, under what conditions would consumers favour sharing their data relevant to financial services with other financial services providers in order to get better offers for financial products and services?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

64.[Q30 EC comment] If you see other benefits of implementing an open finance policy in the EU, please specify and explain: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

66.[Q31 EC comment] If you see other risks of implementing an open finance policy in the EU, please specify and explain: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

67.[Q32 EC comment] In your opinion, what safeguards would be necessary to
mitigate these risks?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

69.[Q33 EC comment] If you see other financial products that would benefit of an open finance policy, please specify and explain: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

70.[Q33.1 EC comment] Please explain your answer to question 33 and give examples for each category: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

71.[Q34 EC comment] What specific data (personal and non-personal) would you find most relevant when developing open finance services based on customer consent?

To what extent would you also consider relevant data generated by other services or products (energy, retail, transport, social media, e-commerce, etc.) to the extent they are relevant to financial services and customers consent to their use?

Please explain your reasoning and provide the example per sector: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

73.[Q35 EC comment] Please specify what other element(s) should be considered to implement an open finance policy: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

74.[Q36 EC] Do you/does your firm already deploy AI based services in a production environment in the EU?

Yes

Don’t know / no opinion / not relevant

75.[Q36.1 EC comment] If you/your firm do/does already deploy AI based services in a production environment in the EU, please specify for which applications?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

76.[Q37 EC comment] Do you encounter any policy or regulatory issues with your use of AI?

Have you refrained from putting AI based services in production as a result
of regulatory requirements or due to legal uncertainty?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

77.[Q38 EC comment] In your opinion, what are the most promising areas for AI-applications in the financial sector in the medium term and what are the main benefits that these AI-applications can bring in the financial sector to consumers and firms? [comment]: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

79.[Q39(1) EC comment] Please specify what other main challenge(s) or risk(s) the increased use of AI-based models is likely to raise for the FINANCIAL INDUSTRY: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

81.[Q39(2) EC comment] Please specify what other main challenge(s) or risk(s) the increased use of AI-based models is likely to raise for the CUSTOMERS/INVESTORS: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

83.[Q39(3) EC comment] Please specify what other main challenge(s) or risk(s) the increased use of AI-based models is likely to raise for the SUPERVISORY AUTHORITIES: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

85.[Q40 EC comment] Please specify what other way(s) could be best to address these new issues: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

87.[Q41 EC comment] Please specify what are the other main barrier(s) for new providers of RegTech solutions to scale up in the Single Market: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

89.[Q41 EC comment] Please specify what are the other main barrier(s) for new providers of new Financial service providers to scale up in the Single Market: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

90.[Q42 EC] In your opinion, are initiatives needed at EU level to support the deployment of these solutions, ensure convergence among different authorities and enable RegTech to scale up in the Single Market?

Yes

Don’t know / no opinion / not relevant

91.[Q42 EC comment] Please explain your answer to question 42 and, if necessary, please explain your reasoning and provide examples: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

92.[Q43 EC comment] In your opinion, which parts of financial services legislation would benefit the most from being translated into machine-executable form?

Please specify what are the potential benefits and risks associated with
machine-executable financial services legislation: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

93.[Q44 EC comment] The Commission is working on standardising concept
definitions and reporting obligations across the whole EU financial services
legislation.

Do you see additional initiatives that it should take to support a move
towards a fully digitalised supervisory approach in the area of financial
services?

Please explain your reasoning and provide examples if needed: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

94.[Q45 EC comment] What are the potential benefits and drawbacks of a stronger use of supervisory data combined with other publicly available data (e.g. social media data) for effective supervision?

Please explain your reasoning and provide examples if needed: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

95.[Q46 EC comment] How could the financial sector in the EU contribute to funding the digital transition in the EU? Are there any specific barriers preventing the sector from providing such funding?

Are there specific measures that should then be taken at EU level in this respect?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

96.[Q47 EC comment] Are there specific measures needed at EU level to ensure that the digital transformation of the European financial sector is environmentally sustainable?: (5,000 characters max including spaces and line breaks, i.e. stricter than the MS Word characters counting method).

97.[ADDITIONAL INFORMATION] Should you wish to provide additional information (e.g. a position paper, report) or raise specific points not covered by the questionnaire, you can upload your additional document(s) here:

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