

POSTNOTE
Number 525 May 2016

Financial Technology (FinTech)

Overview
 FinTech is providing new financial services,
including crowdfunding, mobile payments
and distributed ledgers such as blockchain.
 FinTech can reduce costs and increase
convenience for consumers and firms, and
enhance competition among businesses.
 Challenges for regulators include how to
protect consumers, yet enable innovation.
Financial Technology (FinTech) describes the  FinTech can increase access to financial
application of digital technology to financial services for some, but it is unclear how
services.1 FinTech presents consumers, wide-spread the benefits will be.
businesses and governments with new  New uses of data through FinTech raises
products and services that may disrupt the questions over privacy and data security.
financial sector.2,3 This POSTnote reviews how  Digital financial services require secure user
and why FinTech is being used, and the identification, which can be hard to achieve.
benefits and challenges it presents to the UK.

FinTech in the UK incubators (that provide office space and networking) and
FinTech is changing the types of financial services accelerators (that offer short mentoring and investment
available, who can access them, and how. For example: programmes).6,10 FinTech is concentrated in London but is
 alternative finance such as peer-to-peer lending allows also developing in Edinburgh, Leeds and Manchester.6,11
consumers or firms to obtain loans without using a bank
 data analytics can be applied to an individual’s financial This note looks at four emerging FinTech areas: alternative
data to give them low-cost automated financial advice finance, data analytics, payments and distributed ledgers. It
 new payment methods, such as apps, allow transactions covers their use and associated challenges, such as access
to be made with a smartphone to services, regulation and establishing online identity.
 distributed ledger technology (e.g. blockchain) enables
new ways of recording and executing transactions. Alternative Finance
Alternative finance describes a range of investing and
The Government wants the UK to be the world’s leading donating services accessed via online platforms.12,13 UK
FinTech centre. It sees FinTech as an opportunity to create alternative finance had a total transaction volume of £3.2bn
jobs and economic growth.4,5 Estimates suggest that in in 2015 (an 84% rise from 2014).14 The largest areas were
2015, UK FinTech: peer-to-peer lending to businesses (47% of market share)
 was worth roughly £6.6bn in annual revenue and consumers (28%), and equity crowdfunding (10%).14
 employed around 61,000 people Factors driving the development and use of alternative
 attracted approximately £524m of investment.6 finance (Box 1) include demand from consumers and
businesses for new funding, a lack of other investment
Uptake of FinTech by consumers has been attributed to opportunities,15-17 and the speed of online services.15,18 The
factors including the widespread use of smartphones and Government has committed £100m of investment into the
the internet,7 a reduction in consumer confidence towards sector via the British Business Bank.19
traditional banks after the financial crisis,2,7 and the lower
costs and convenience of digital financial services.8 Many Peer-to-Peer Lending
new FinTech firms have been created in the UK, enabled by Businesses or consumers can obtain loans by borrowing
the availability of technology, which has reduced set-up from many individual lenders via an online platform (e.g.
costs and helped new companies to enter the market.9 Zopa or RateSetter). Loans are then repaid to lenders with
Established banks are investing in FinTech start-ups via interest.12 Peer-to-peer platforms can offer an alternative to

The Parliamentary Office of Science and Technology, London SW1A 1AA T 020 7219 2840 E [email protected] www.parliament.uk/post
POSTnote 525 May 2016 Financial Technology (FinTech) Page 2

banks by directly connecting lenders and borrowers.

Box 1. Alternative Finance Use in the UK12,14
Typically, administering loans through these online  Peer-to-peer lending. The main use of peer-to-peer business
platforms is cheaper than via traditional banks, and loans in 2015 was in real estate, predominantly by property
platforms may use non-traditional data sources to assess developers. (This is in contrast to 2014, when real estate was a
credit risk.17 Platforms can offer more competitive interest minor sector.) The average peer-to-peer business loan in 2015
rates and increased access to finance for borrowers (excluding real estate) was £73k, and involved 347 lenders. These
loans are estimated to be 12% of all national lending to small
compared to banks.12 Interest from peer-to-peer loans is
businesses. A third of peer-to-peer business borrowers in 2014
eligible for tax relief through the Innovative Finance ISA,20 believed they would have been unlikely to get funds elsewhere. For
and investors can offset losses incurred against income peer-to-peer consumer lending, the average loan in 2015 was
received for tax purposes.21 The Government is planning a £6.6k. The top three loan uses in 2014 were: vehicle purchase,
scheme requiring banks to refer small businesses to home improvement and debt consolidation. Around a quarter of
alternative finance providers if they deny them a loan.22 peer-to-peer business lenders and a third of peer-to-peer
consumer lenders in 2015 were institutions (not individuals).
 Crowdfunding. Equity crowdfunding was the largest
Regulation and Consumer Protection crowdfunding sector in 2015. It grew by 295% from 2014. Around a
Peer-to-peer lending has been regulated by the Financial quarter of this market was in real-estate investments. Equity
Conduct Authority (FCA) since 2014.16,23 The Peer-to-Peer crowdfunding (excluding real-estate projects) was an estimated
Finance Association also has self-regulation requirements 16% of UK early-stage (seed and venture) equity investment. On
for its members.24 The FCA considers peer-to-peer lending average, each investment round raised £523k and involved
77 investors. In 2014, 62% of funders had no prior investment
to be higher risk than holding money on deposit.23 Loans are
experience, and 38% were professional investors or high net-worth
not covered by the Financial Services Compensation individuals. Rewards crowdfunding supported around 6,600
Scheme (designed to protect consumers against institutional projects in 2015. On average, each project raised a total of £1.4k,
bankruptcy).25 Instead, the FCA requires platforms to have a from 326 funders. Donation crowdfunding totalled £12m in 2015
contingency plan to settle loans if they go out of business, (a 500% growth from 2014). Around 17,000 projects each raised a
although it notes that consumer detriment is possible if total of £7.7k, from 41 donors, on average.
arrangements fail to work as expected.16,26 Processes for
dealing with loan defaults differ between platforms.27 clearly indicating the risks. Concerns were also raised over
promotions comparing peer-to-peer loans to savings
Crowdfunding accounts, potentially suggesting that lenders’ capital was
Businesses or individuals can raise money from multiple secure.30 Following the review, the FCA found that most
funders who typically contribute a small sum.28 This gives firms they contacted changed their websites as requested.30
them a new way of generating funds for their businesses,
projects or charitable ventures, and provides funders with Data Analytics
access to a new market. Crowdfunding can be classified by Use of data analytics is enabling new business models in
the returns received by funders, for example: the financial services (POSTnotes 468 and 469).31 Driven by
 equity crowdfunding (e.g. CrowdCube or Seedrs) greater availability of data and analysis tools,2,32,33 firms are
– funders receive shares in a business increasingly looking to generate revenue from data.7 As for
 rewards crowdfunding (e.g. Kickstarter) – funders receive all companies, use of personal data by FinTech businesses
a non-financial reward such as an acknowledgement will be subject to the recently approved EU General Data
 donation crowdfunding (e.g. Spacehive) – funders receive Protection Regulation that comes into force in 2018.34
no material reward.12
Risk Assessment
Regulation and Consumer Protection Data about an individual can be used by businesses to
The FCA regulates equity crowdfunding, but not rewards or calculate personalised risk assessments. This can enable
donation crowdfunding.23 The industry body, the UK more accurate risk management for companies and greater
Crowdfunding Association, also has a code of practice for its access to services for some consumers.35 For instance,
members.29 The FCA regards equity crowdfunding as a installing telematics boxes in a customer’s car to gather data
high-risk investment activity with additional risks compared on their driving habits allows insurers to calculate personal
to peer-to-peer lending.23 Investors only make a return if the premiums.36 Use of new types of data (e.g. social media) in
business they back is successful, which may be unlikely due credit assessments can allow people traditionally unable to
to the high rate of early-stage business failure.23,25 These get loans (e.g. with no credit history) to access them.17,37,38
risks apply to other types of investments, such as venture However, greater use of personal data raises issues for
capital (funding for start-ups and small businesses). privacy and data security, and may lead to unintended
However, the FCA has raised concerns that equity discrimination. For example, software that looks for
crowdfunding is being used by investors with no previous correlations between insurance price and other variables
experience (Box 1) and say that firms need to give investors (e.g. home address), might unintentionally discriminate
the information required to understand the risks involved.30 against people with certain traits (e.g. ethnicity).39-41 In
response to an FCA investigation of data use by insurers,42
A 2014 FCA review of 25 websites (both peer-to-peer the Financial Services Consumer Panel raised concerns
lending and crowdfunding platforms) raised concerns over that consumers may be unaware of how their data are used,
promotions that emphasised benefits of investing without and highlighted a need for them to give explicit consent.43
POSTnote 525 May 2016 Financial Technology (FinTech) Page 3

Automation in Financial Advice Regulation and Legislation

Automated advice services use software to provide personal A new UK Payment Systems Regulator (PSR) was
financial advice with little or no human guidance.44 Data, launched in 2015 to regulate the payments industry.63 The
such as a user’s income or risk tolerance, are analysed to PSR has set up a forum to develop a strategy for the
recommend specific products or services. For example, sector,64 and is reviewing access to, and provision of, UK
companies such as Wealth Horizon45 provide consumers payment systems (e.g. Bacs, Faster Payments and
with automatically-created online investment portfolios.46 LINK).65,66 Payments infrastructure is currently owned by a
Potential benefits of automated services include lower costs small number of banks.66 The PSR says that this does not
and greater access to advice.44,46,47 However, risks for provide effective competition and has proposed that owners
consumers include the possibility that they do not should sell part of their stake.66,67 The payments and
understand the limitations of the service or how their data banking sectors will be affected by new legislation to open
are used, and have a limited ability to seek clarification.44 If up banking data to third parties (Box 2), which could provide
there is an unclear allocation of liability, legal disputes may increased competition and new services for consumers.
arise among those developing the tools, those providing the Concerns have been raised over consumers’ privacy68,69
services, and consumers.44 In a recent review, HM Treasury and the potential for their data to be used fraudulently.52
and the FCA recommended that the FCA creates an Advice
Unit to help firms develop automated advice.48 Distributed Ledger Technology (DLT)
Distributed ledgers are digital records that can be shared
Payments among many different locations or users, without needing to
FinTech is influencing a wide range of payment services have a central intermediary.70,71 The characteristics of
used by both consumers and companies.56 Research distributed ledgers vary, but all involve distributed and
suggests that payments had the highest adoption rate of all secure information sharing (Box 3).72 DLT was originally
FinTech products in 2015,57 and that it was the largest developed for digital currencies73 (the blockchain ledger,
subsector in UK FinTech.6 Emerging models include: which underpins Bitcoin), and these currencies remain the
 Mobile payments – smartphones can be used for main use of the technology (POSTnote 475). However, DLT
contactless transactions, online payments, or purchases could be used more broadly (Box 4),74 and outside of
via an app.58 For example, Starbucks customers can FinTech,70 since it provides a way of creating securely
order and pay for coffee through a pre-paid app.59 shared records for essentially any asset or transaction. An
 Cross-border payments – FinTech firms are facilitating estimate suggests that globally, DLT firms attracted around
low-cost overseas transfers traditionally made via banks. $490m (£350m) in early-stage investment in 2015.75 DLT
Transferwise matches users wanting to send money in research is receiving support from public funding bodies.76,77
opposite directions overseas, allowing international
transfers to be made using (mostly) national payments. Challenges for Distributed Ledger Technology
 Tokenization – instead of directly giving a vendor DLT is at an early stage of development, and its full
sensitive consumer information, such as a credit card implications remain to be seen.70 There is little regulation
number, this information is first converted to a non- specific to DLT, although HM Treasury has announced it will
sensitive token by a trusted intermediary.60 This apply anti-money laundering regulation to marketplaces for
eliminates vendors’ access to users’ payment data, and trading digital currencies.78 Use of DLT in general poses a
can therefore reduce crime risk.61 Tokenization is number of questions, including: how it will affect central
currently used in services such as Apple Pay.62 institutions such as governments; how it might be regulated
if there is no single legal entity in charge; how to address
Box 2. The Open Banking Standard and APIs
the technical and commercial challenges of scaling DLT for
HM Treasury is developing an Open Banking Standard to enable
regulated third-party access to banking data.49 It plans to phase this in widespread use; and how to maximise its benefits.70,72
from 2016 to 2019. Under the Standard, banks will provide application
programming interfaces (APIs) – tools that allow communication Box 3. Characteristics of Distributed Ledger Technology
between two pieces of software.50 With consumers’ permission, APIs Two key features of distributed ledger technology are:
would give FinTech companies access to customers’ banking data.  Distributed storage – identical copies of the ledger are stored by
This could be used to provide consumers with services such as apps multiple parties. This removes central points of failure, allowing the
to manage personal finances or to initiate payments.51,52 ledger to be recovered if a copy is corrupted, and removes
ambiguities in record-keeping (as the ledger is visible to all).70
The Open Banking Working Group developing the standard has said  Mathematical security – the use of cryptography (the encoding
that the Government should further consider several aspects of the and decoding of information) allows information to be time-
proposal, including whether it provides sufficient customer protection stamped, and securely recorded. This provides a robust way of
and if additional regulation is needed.49 Third-party access to data will verifying the transfer of information between different parties.70
also be required under the revised EU Directive on Payments
Services (PSD2). PSD2, which comes into force in January 2018,53,54 Depending on the ledger, different users can be given different rights
aims to enhance consumer protection, promote innovation and to access and modify individual records. Some may have permission
improve the security of payment services.55 Regulatory standards for to alter records, while others may only view them.70 This can enable
PSD2 are being developed by the European Banking Authority and transparency by opening up records to a defined set of people, and
HM Treasury is drafting legislation for its national implementation.51 improve privacy by controlling what is shared and with whom.70
POSTnote 525 May 2016 Financial Technology (FinTech) Page 4

Box 4. Potential Applications of Distributed Ledger Technology Box 5. The FCA’s Project Innovate
 Supply-chain transparency. A distributed ledger could record the Alongside providing innovative businesses with regulatory guidance,
trade and transport details of an item, by associating it with a digital the FCA’s Project Innovate is developing other initiatives such as:
identity.79 For example, the Everledger system uses DLT to track  The regulatory sandbox – a controlled environment in which
the trade and movement of diamonds, providing a way of businesses can trial new ideas on real consumers. This will allow
transparently recording ownership history and reducing crime.70,80 businesses to test products without the normal regulation
 Smart contracts. DLT could facilitate smart contracts that can be associated with pilot activities, and enable new products to enter
executed and enforced automatically, without the need for the market.95 The sandbox recently opened for applications, and
intermediaries.70,72,74,81,82 For example, a smart contract could be testing is due to begin later in 2016.96
created for flight insurance – if a flight was delayed or cancelled,  Regulatory Technology (RegTech) – this refers to how data and
the contract could automatically initiate the claim and pay the policy technology can be used in regulation. For example, RegTech could
holder.83 Smart contracts could reduce contracting and help businesses to achieve regulatory compliance using
enforcement costs.70 However, they are at an early stage of technology such as automated and real-time reporting.97,98,2 It
development, and their legal status is unclear.72 could make compliance easier and less costly, while improving
 Government operations. Distributed ledgers might be used in a transparency and accountability.2,98 RegTech also presents a
range of government services.70 DWP is investigating how DLT potential market opportunity for FinTech firms to develop new
could be used to deliver welfare support. DLT, in conjunction with regulatory tools.2
physical identification (such as a fingerprint recorded on a
smartphone) could be used to verify a claimant’s identity and
transfer funds to their mobile phone. This could enable payments Regulation of Financial Innovation
to be used only by the intended recipient, and could reduce fraud The FinTech market has evolved rapidly, creating new
and overpayments (which are currently estimated at £5bn per products and services for consumers. This presents a
year).70,84 The National Archives is also exploring the possibility of
challenge for regulators: how to promote competition in the
using distributed ledgers to ensure the long-term integrity of digital
public records. This scheme could use a ledger that only the interest of consumers, while ensuring an appropriate degree
Government could modify, and everyone else could view. of consumer protection.2 To help address this, the FCA
 Financial transactions. DLT has applications for settling launched Project Innovate in 2014 (Box 5).99
transactions. FinTech firm R3 recently completed a trial with 40
major banks that simulated using distributed ledgers to execute Identity and Cybersecurity
instant global financial transactions.85 The Bank of England is also
Digital financial services require a secure way for different
investigating using DLT for a central bank run digital currency.86,87
parties to prove their identity online. This establishes the
trust needed to perform transactions and mitigates against
Challenges identity crime, such as fraud.100 There is no consistent
Financial Inclusion approach to confirming a person’s identity online in the
Financial inclusion refers to the accessibility of financial UK.101 Physical biometric data, such as fingerprint
services to all adults in society.88 FinTech could increase recognition, is one tool being considered by some FinTech
financial inclusion by providing tools and education for those firms. The online bank Atom has developed facial and voice
who are not catered for by existing services. For example: recognition security checks for its app (POSTnote 509).102
 M-PESA (launched in Kenya) enables users with no bank Others suggest that behavioural biometrics, such as how
account to transfer money using their mobile phones.89 someone types on their phone, could be preferable as they
 Squirrel offers users help to manage their finances by may be harder to replicate.103
controlling when they can access their savings.90
 FriendlyScore uses social media data to assess Industry and others have proposed that a cross-service
creditworthiness, which may improve access to finance.91 digital ID scheme is needed.100 This could give consumers a
single digital ID to access a range of online services.
However, digital financial services are not equally Proposed benefits include greater user convenience and
accessible across society. The Financial Inclusion reduced regulatory burdens associated with identity
Commission suggests that the benefits of technology may provision across multiple systems.100 In Estonia, a
be less likely to reach those on low incomes, since they are government-led digital ID scheme uses DLT to provide
a less profitable market.88 A 2015 survey found that access to private and public sector services online, such as
adoption of FinTech tended to be higher among younger, electronic health records, tax declaration and banking. The
higher-income and urban-dwelling people.8 FinTech may be UK Government’s identity assurance scheme GOV.UK
hard to access for the digitally excluded, i.e. those who don’t Verify, which uses certified companies (such as the Post
have the skills or technology to use digital services.88,92 Office) for identity verification, aims to provide a single point
Ofcom estimated that 34% of UK adults did not have a of identity verification for multiple online Government
smartphone in 2015 (first quarter).93 Greater use of digital services as well as developing the ID services market.104
financial services may lead to a reduced provision of
physical alternatives, which could disadvantage those who
rely on high-street branches to manage their money.94

POST is an office of both Houses of Parliament, charged with providing independent and balanced analysis of policy issues that have a basis in science and technology.
POST is grateful to Sam Bayliss for researching this briefing, to the Institute of Physics for funding his parliamentary fellowship, and to all contributors and reviewers. For
further information on this subject, please contact the co-author, Dr. Lydia Harriss. Parliamentary Copyright 2016. Image copyright iStockphoto.com
POSTnote 525 May 2016 Financial Technology (FinTech) Page 5

Endnotes
1 Oxford Dictionaries, Definition of fintech, 2015 50 HM Treasury, Call for evidence on data sharing and open data in banking
2 Government Office for Science, FinTech Futures, 2015, 51 OBWG, The Open Banking Standard, 2016
3 KPMG, H2 Ventures, FinTech 100: Leading Global FinTech Innovators Report, 52 HM Treasury, Data sharing and open data in banking: response to the call for

2015, evidence, 2015

4 Harriet Baldwin speech, 2015 53 PSD2, Payments compliance
5 Prime Minister’s Office, Press release, 2015 54 PSD2
6 Ernst & Young, HM Treasury, UK FinTech On the cutting edge: An evaluation of 55 European Commission, PSD2 Press Release, 2015

the international FinTech sector, 2016 56 BNY Mellon, Innovation in Payments: The Future is FinTech, 2015
7 Ernst & Young, UK Trade & Investment, Landscaping UK FinTech, 2014, 57 Ernst & Young, Who will disrupt the disruptors?, 2015
8 EY FinTech Adoption Index 58 Mobile Payments Today, Mobile Wallets 101, 2015
9 TechUK, Taking the Initiative: Leading with Technology in Financial Services, 59 Starbucks app

2015 60 PCI DSS, tokenization guidelines, 2011

10 Ernst & Young, Fintech: Are banks responding appropriately?, 2015 61 First Data, Tokenization
11 Innovate Finance, Regional Strategy, 2015 62 Apple Pay tokenization
12 Nesta, University of Cambridge, Understanding Alternative Finance, The UK 63 PSR

Alternative Finance Industry Report, 2014 64 PSR, Payments Strategy Forum

13 Cambridge Centre for Alternative Finance, Ernst & Young, Moving Mainstream, 65 PSR, Market review into the supply of indirect access to payment systems, 2015

The European Alternative Finance Benchmarking Report, 2015 66 PSR, Interim report: market review into the ownership and competitiveness of
14 Cambridge Centre for Alternative Finance, Nesta, Pushing Boundaries, The infrastructure provision, 2016
2015 UK Alternative Finance Industry Report 67 PSR, Banks should sell their stake in UK payments infrastructure to help
15 Nesta, Banking on each other, 2013 increase innovation and competition, Press release, 2016
16 FCA, policy statement on crowdfunding 68 The Information Commissioner’s Office response to HM Treasury’s Call for
17 WEF, The Future of FinTech, A Paradigm Shift in Small Business Finance, Evidence on Data Sharing and Open Data in Banking, 2015
2015, 69 mydex, Data sharing and open data in banking, 2015
18 Dealindex, Democratising Finance, 2015 70 Government Office for Science, Distributed Ledger Technology: beyond
19 British Business Bank, Making Britain the Global Centre of Financial Innovation blockchain, 2016.
– £100m Extra for British Business Bank Investment Programme, 2014 71 Santander, The FinTech 2,0 Paper: rebooting financial services, 2015
20 Innovative Finance ISA 72 IMF, Virtual Currencies and Beyond: Initial Considerations, 2016
21 HMRC, Bad debt relief for Peer to Peer investments, 2015 73 Satoshi Nakamoto, Bitcoin: A Peer-to-Peer Electronic Cash System, 2008
22 British Business Bank, Finance Platforms and Credit Reference Agencies 74 Barclays, Blockchain: understanding the potential, 2015
23 FCA, Crowdfunding 75 CoinDesk, Bitcoin Venture Capital, accessed 15th April 2016
24 Peer-to-Peer Finance Association Operating Principles 76 EPSRC
25 FCA, The FCA’s regulatory approach to crowdfunding (and similar activities), 77 Digital Catapult Centre, Blockchain, 2015

2013 78 HM Treasury, Digital currencies: response to the call for information, 2015
26 Innovative Finance ISA, What would happen if an Innovative Finance ISA 79 Provenance

provider were to collapse? 80 Everledger

27 Which?, Peer-to-peer lending explained 81 Ethereum
28 UKCFA 82 Deloitte, Blockchain, Enigma. Paradox. Opportunity, 2016
29 UKCFA 83 Bankinnovation.net, What does the future hold for blockchain and insurance?,
30 FCA, A review of the regulatory regime for crowdfunding and the promotion of 2016
non-readily realisable securities by other media, 2015 84 Of the £5bn per year, £3.5 billion is from overpayments by DWP due to fraud,
31 POSTnote 468, Big Data: An Overview, 2014 claimant error and official error (£930 million of which is recovered). The
32 Finextra, What next for advanced analytics?, 2015 remainder comes from the fraud and error estimated to exist in the current tax
33 POSTnote 469, Big Data in Business, 2014 credit system, which will be moving to DWP over the next few years under the
34 Bird & Bird, Guide to the General Data Protection Regulation, 2016 new Universal Credit regime.
35 FCA, Call for Inputs: Big Data in retail general insurance, 2015 85 R3 trial, 2016
36 Deloitte, Overcoming speed bumps on the road to telematics, 2014 86 Central banks and digital currencies - speech by Ben Broadbent, 2016
37 Kreditech 87 Bank of England, One Bank Research Agenda, 2015
38 Karen Gordon Mills and Brayden McCarthy, Harvard Business School Working 88 Financial Inclusion Commission, Financial Inclusion, Improving the Financial

Paper, The State of Small Business Lending: Credit Access during the Recovery Health of the Nation, 2015
and How Technology May Change the Game, 2014 89 M-PESA
39 Executive Office of the President of the United States, Big Data and differential 90 Squirrel

pricing, 2015 91 FriendlyScore

40 Executive Office of the President, Big Data: Seizing Opportunities, Preserving 92 POSTnote 494, UK Broadband Infrastructure

Values, 2014 93 Ofcom

41 University of Southampton Law Research Group, Written Submission to the 94 Social Market Foundation, Balancing Bricks & Clicks, 2016

Commons Select Committee on Science & Technology: “The Big Data Dilemma” 95 FCA, Regulatory Sandbox, 2015
42 FCA, Call for Inputs: Big Data in retail general insurance 96 FCA, Regulatory Sandbox
43 Financial Services Consumer Panel, Call for Inputs: Big Data in retail general 97 FCA, RegTech, Call for Input, 2015

insurance, 2016 98FCA, Call for Input: Supporting the development and adoption of RegTech
44 ESAs, Joint committee discussion paper on automation in financial advice, 2015 99 FCA, Project Innovate
45 Wealth Horizon 100 TechUK, Towards a ‘New Financial Services’, 2014
46 Deloitte, Robo-Advisors, Capitalizing on a growing opportunity, 2015 101 Open Identity Exchange, Discovering the needs for UK identity assurance, 2015
47 HM Treasury, Financial Advice Market Review: terms of reference 102 Atom Bank
48 HM Treasury, FCA, Financial Advice Market Review, 2016 103 Mobile Payments Today, Are physical biometrics really the way to go?, 2016
49 OBWG 104 GOV.UK Verify