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

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* 1. I am giving my contribution as

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* 2. First Name

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* 3. Surname

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* 4. Email (this will not be published)

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* 5. Scope

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* 6. Organisation name

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* 7. Organisation size

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

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

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* 10. Field of activity or sector (if applicable)

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* 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.)

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* 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.)

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* 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.)

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* 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?

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* 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.)

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

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* 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.):

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* 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?

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* 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.):

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* 20. [Q6(a) EC] In your opinion, is the use for financial services of the new
technologies listed below limited due to obstacles stemming from the EU
financial services regulatory framework or other EU level regulatory
requirements that also apply to financial services providers?
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant  5 fully relevant
Distributed Ledger Technology (except cryptoassets)
Cloud computing
Artificial Intelligence/Machine learning
Internet Of Things (IoT)
Biometrics
Quantum computing
Other

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* 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.):

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* 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.):

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* 23. [Q7 EC] Building on your experience, what are the best ways (regulatory
and non-regulatory measures) for the EU to support the uptake of nascent
technologies and business models relying on them while also mitigating the
risks they may pose?
Please rate each proposal from 1 to 5:

  1. irrelevant 2. rather not relevant 3. neutral 4 rather relevant 5 fully relevant N/A
Setting up dedicated observatories to monitor technological and market trends (e.g. EU Blockchain Observatory & Forum; Platform
Observatory)
Funding experimentation on certain applications of new technologies in finance (e.g blockchain use cases)
Promoting supervisory innovation hubs and sandboxes
Supporting industry codes of conduct on certain applications of new technologies in finance
Enhancing legal clarity through guidance at EU level for specific technologies and/or use cases
Creating bespoke EU regimes adapted to nascent markets, possibly on a temporary basis
Other

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* 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.)

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* 25. [Q8 EC] Question 8. In which financial services do you expect technology companies which have their main business outside the financial sector (individually or collectively) to gain significant market share in the EU in the five upcoming y e a r s ?
Please rate each proposal from 1 to 5:

  1 very low market share - below 1% 2 low market share 3 neutral 4 significant market share 5 very significant market share - above 25% N/A
Intra-European retail payments
Intra-European wholesale payments
Consumer credit provision to households with risk taking
Consumer credit distribution to households with partner institution(s)
Mortgage credit provision to households with risk taking 
Mortgage credit distribution to households with partner institution(s)
Credit provision to SMEs with risk taking
Credit distribution to SMEs with partner institution(s)
Credit provision to large corporates with risk taking
Syndicated lending services with risk taking
Risk-taking activities in Life insurance products
Risk-taking activities in Non-life insurance products
Risk-taking activities in pension products
Intermediation / Distribution of life insurance products
Intermediation / Distribution of nonlife insurance products
Intermediation / Distribution of pension products
Other insurance related activities, e.g. claims management
Re-insurance services
Investment products distribution
Asset management
Others

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* 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.)

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* 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.)

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* 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?

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* 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.)

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* 30. [10 EC] Which prudential and conduct risks do you expect to change with technology companies gaining significant market share in financial services in the EU in the five upcoming years?
Please rate each proposal from 1 to 5:

  1. significant reduction in risks 2. reduction in risks 3. neutral 4 increase in risks 5 significant increase in risks N/A
Liquidity risk in interbank market (e.g. increased volatility)
Liquidity risk for particular credit institutions
Liquidity risk for asset management companies
Credit risk: household lending
Credit risk: SME lending
Credit risk: corporate lending
Pro-cyclical credit provision
Concentration risk for funds collected and invested (e.g. lack of diversification)
Concentration risk for holders of funds (e.g. large deposits or investments held in a bank or fund)
Undertaken insurance risk in life insurance
Undertaken insurance risk in non-life insurance
Operational risks for technology companies and platforms
Operational risk for incumbent financial service providers
Systemic risks (e.g. technology companies and platforms become too big, too interconnected to fail)
Money-laundering and terrorism financing risk
Other

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* 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.)

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* 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.)

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* 33. [Q11 EC] Which consumer risks do you expect to change when technology companies gain significant market share in financial services in the EU in the five upcoming years? Please rate each proposal from 1 to 5:

  1. significant reduction in risks 2. reduction in risks 3. neutral 4 increase in risks 5 significant increase in risks N/A
Default risk for funds held in non-banks and not protected by Deposit Guarantee Scheme
Liquidity risk 
Misselling of insurance products
Misselling of investment products
Misselling of credit products
Misselling of pension products
Inadequate provision of information
Inadequate complaint and redress process and management
Use/abuse of personal data for financial commercial purposes
Discrimination e.g. based on profiles
Operational risk e.g. interrupted service, loss of data
Other

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* 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.)

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* 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.)

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* 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)?

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* 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.)

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* 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).

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* 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).

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* 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).

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* 41. [Q16 EC] What should be done at EU level to facilitate interoperable crossborder solutions for digital on-boarding?

Please rate each proposal from 1 to 5:

  1. irrelevant 2. rather not relevant 3. neutral 4 rather relevant 5 fully relevant N/A
Harmonise rules governing customer due diligence requirements in the Anti-Money Laundering (AML) legislation
Harmonise rules governing the acceptable use of remote identification technologies and services in the AML legislation
Broaden access for obliged entities to publicly held information (public databases and registers) to enable verification of customer identities
Provide further guidance or standards in support of the customer due diligence process (e.g. detailed ID elements, eligible trusted sources; risk assessment of remote identification technologies)
Facilitate the development of digital on-boarding processes, which build on the e-IDAS Regulation
Facilitate cooperation between public authorities and private sector digital identity solution providers
Integrate KYC attributes into eIDAS in order to enable onboarding through trusted digital identities
Other

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* 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).

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* 43. [Q17 EC] What 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?

Please rate each proposal from 1 to 5:

  1. irrelevant 2. rather not relevant 3. neutral 4 rather relevant 5 fully relevant N/A
Make the rules on third party reliance in the Anti-Money Laundering legislation more specific
Provide further guidance relating to reliance on third parties for carrying out identification and verification through digital means, including on issues relating to liability
Promote re-use of digital identities collected for customer due diligence purposes in accordance with data protection rules
Promote a universally accepted public electronic identity
Define the provision of digital identities as a new private sector trust service under the supervisory regime of the eIDAS Regulation
Other

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* 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).

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* 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).

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* 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?

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* 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).

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* 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).

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* 49. [Q21 EC] In your opinion, how could the relevant EU authorities enhance coordination among different schemes in the EU?

Please rate each proposal from 1 to 5:

  1. irrelevant 2. rather not relevant 3. neutral 4 rather relevant 5 fully relevant N/A
Promote convergence among national authorities in setting up innovation hubs and sandboxes, through additional best practices or guidelines
Facilitate the possibility for firms to test new products and activities for marketing in several Member States (“cross border testing”)
Raise awareness among industry stakeholders
Ensure closer coordination with authorities beyond the financial sector (e.g. data and consumer protection authorities)
Promote the establishment of innovation hubs or sandboxes with a specific focus (e.g. a specific technology like Blockchain or a specific purpose like sustainable finance)
Other

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* 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).

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* 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).

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* 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).

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* 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).

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* 54. [Q24 EC] In your opinion, what should be done at EU level to achieve improved financial education and literacy in the digital context? 

Please rate each proposal from 1 to 5:

  1. irrelevant 2. rather not relevant 3. neutral 4 rather relevant 5 fully relevant N/A
Ensure more affordable access at EU level to financial data for consumers and retail investors
Encourage supervisors to set up hubs focussed on guiding consumers in the digital world
Organise pan-European campaigns and advisory hubs focusing on digitalisation to raise awareness among consumers
Collect best practices
Promote digital financial services to address financial inclusion
Introduce rules related to financial education comparable to Article 6 of the Mortgage Credit Directive, with a stronger focus on digitalisation, in other EU financial regulation proposals
Other

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* 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).

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* 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).

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* 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).

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* 58. [Q27 EC] Considering the potential that the use of publicly available data brings in finance, in which areas would you see the need to facilitate integrated access to these data in the EU?:

Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Financial reporting data from listed companies
Non-financial reporting data from listed companies
SME data
Prudential disclosure stemming from financial services legislation
Securities market disclosure
Disclosure regarding retail investment products
Other

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* 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).

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* 60. [Q28 EC] In your opinion, what would be needed to make these data easily usable across the EU?

Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Standardised (e.g. XML) and machine-readable format
Further development of the European Financial Transparency Gateway, federating existing public databases with a Single EU access point
Application Programming Interfaces to access databases
Public EU databases
Other

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* 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).

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* 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).

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* 63. [Q30 EC] In your opinion, what could be the main benefits of
implementing an open finance policy in the EU? 

Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
More innovative and convenient services for consumers/investors, e.g. aggregators, comparison, switching tools
Cheaper traditional services for consumers/investors
Efficiencies for the industry by making processes more automated (e.g. suitability test for investment services)
Business opportunities for new entrants in the financial industry
New opportunities for incumbent financial services firms, including through partnerships with innovative start-ups
Easier access to bigger sets of data, hence facilitating development of data dependent services
Enhanced access to European capital markets for retail investors
Enhanced access to credit for small businesses
Other

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* 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).

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* 65. [Q31 EC] In your opinion, what could be the main risks of implementing an open finance policy in the EU?

Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Privacy issues / security of personal data
Financial exclusion
Poor consumer outcomes (e.g. unfair pricing strategies)
Misuse of consumers’ financial data
Business confidentiality issues
Increased cyber risks
Lack of level playing field in terms of access to data across financial sector activities
Other

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* 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).

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* 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).

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* 68. [Q33 EC] In your opinion, for which specific financial products would an open finance policy offer more benefits and opportunities? 

Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Savings accounts
Consumer credit
SME credit
Mortgages
Retail investment products (e. g. securities accounts)
Non-life insurance products (e.g. motor, home…)
Life insurance products
Pension products
Other

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* 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).

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* 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).

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* 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).

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* 72. [Q35 EC] Which elements should be considered to implement an open finance policy?

Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Standardisation of data, data formats
Clarity on the entities covered, including potential thresholds
Clarity on the way data can be technically accessed including whether data is shared in realtime (e.g. standardised APIs)
Clarity on how to ensure full compliance with GDPR and ePrivacy Directive requirements and need to ensure that data subjects remain in full control of their personal data
Clarity on the terms and conditions under which data can be shared between financial services providers (e. g. fees)
Interoperability across sectors
Clarity on the way data shared will be used
Introduction of mandatory data sharing beyond PSD2 in the framework of EU regulatory regime
If mandatory data sharing is considered, making data available free of cost for the recipient
Other

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* 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).

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

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* 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).

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* 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).

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* 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).

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* 78. [Q39 EC] 1. FINANCE INDUSTRY: In your opinion, what are the main challenges or risks that the increased use of AI-based models is likely to raise for the financial industry, for customers/investors, for businesses and for the supervisory authorities?
 
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
1.1. Lack of legal clarity on certain horizontal EU rules
1.2. Lack of legal clarity on certain sector-specific EU rules
1.3. Lack of skills to develop such models
1.4. Lack of understanding from and oversight by the supervisory authorities
1.5. Concentration risks
1.6. Other

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* 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).

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* 80. [Q39 EC] 2. CONSUMER/INVESTORS: In your opinion, what are the main challenges or risks that the increased use of AI-based models is likely to raise for the financial industry, for customers/investors, for businesses and for the supervisory authorities?
 
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
2.1. Lack of awareness on the use of an algorithm
2.2. Lack of transparency on how the outcome has been produced
2.3. Lack of understanding on how the outcome has been produced
2.4. Difficult to challenge a specific outcome
2.5. Biases and/or exploitative profiling
2.6. Financial exclusion
2.7. Algorithm-based behavioural manipulation (e.g. collusion and other coordinated firm behaviour)
2.8. Loss of privacy
2.9. Other

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* 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).

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* 82. [Q39 EC] 3. SUPERVISORY AUTHORITIES: In your opinion, what are the main challenges or risks that the increased use of AI-based models is likely to raise for the financial industry, for customers/investors, for businesses and for the supervisory authorities?
 
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
3.1. Lack of expertise in understanding more complex AI-based models used by the supervised entities
3.2. Lack of clarity in explainability requirements, which may lead to reject these models
3.3. Lack of adequate coordination with other authorities (e.g. data protection)
3.4. Biases
3.5. Other

Question Title

* 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).

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* 84. [Q40 EC] In your opinion, what are the best ways to address these new issues?
 
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
New EU rules on AI at horizontal level
New EU rules on AI for the financial sector
Guidance at EU level for the financial sector
Experimentation on specific AI applications under the control of competent authorities
Certification of AI systems
Auditing of AI systems
Registration with and access to AI systems for relevant supervisory authorities
Other

Question Title

* 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).

Question Title

* 86. [Q41 EC] PROVIDERS OF REGTECH SOLUTIONS -  In your opinion, what are the main barriers for new RegTech solutions to scale up in the Single Market?
 
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Lack of harmonisation of EU rules
Lack of clarity regarding the interpretation of regulatory requirements (e.g. reporting)
Lack of standards
Lack of real time access to data from regulated institutions
Lack of interactions between RegTech firms, regulated financial institutions and authorities
Lack of supervisory one stop shop for RegTech within the EU
Frequent changes in the applicable rules
Other

Question Title

* 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).

Question Title

* 88. [Q41 EC] FINANCIAL SERVICE PROVIDERS -  In your opinion, what are the main barriers for new RegTech solutions to scale up in the Single Market?
 
Please rate each proposal from 1 to 5:

  1 irrelevant 2 rather not relevant 3 neutral 4 rather relevant 5 fully relevant N/A
Lack of harmonisation of EU rules
Lack of trust in newly developed solutions
Lack of harmonised approach to RegTech within the EU
Other

Question Title

* 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).

Question Title

* 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?

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* 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).

Question Title

* 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).

Question Title

* 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).

Question Title

* 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).

Question Title

* 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).

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* 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).

Question Title

* 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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