ASIC updates – Sandbox and Crowdfunding (plus #FinTech Hub)

In recent weeks, ASIC Commissioner, John Price and his team have been making presentations to the FinTech community on two key topics: the ASIC Regulatory Sandbox, and the forthcoming Equity Crowdfunding legislation.

Image by TeeKay, sourced from Wikimedia

blogged about the sandbox when it was announced last year, and at the time, the proposed safe harbour provisions for FinTech startups were seen as being key to fostering innovation within the sector. However, at the time of the presentation I attended (June 13), there was only one confirmed participant in the sandbox scheme. According to the Commissioner, the low take-up was probably due to the timing of the regulations, being so close to summer holidays.

On the other hand, the sandbox has such a limited application, that the Government is proposing to expand its scope to include the provision of products (not just distribution), the provision of credit services, and to extend the current 12-month license waiver period to two years.

The Commissioner also mentioned the consultation process on RegTech combined with a hackathon event to be held later this year, as evidence of the direction the ASIC Innovation Hub is taking. Let’s just hope they can keep up with how fast the FinTech community (especially in blockchain and crypto-currency) is evolving, since regulation usually lags innovation.

At a separate series of FinTech and startup briefings, Mr Price discussed the new equity crowdfunding provisions, due to take effect on September 29. Currently undertaking a consultation process on the detailed regulations, the legislation applies only to ordinary shares issued by companies with a maximum of $25m in assets and annual turnover, and which become public companies once the legislation comes into force.

Eligible crowd-sourced funding companies (CSF’s) can raise a maximum of $5m per annum, and investors can invest a maximum of $10,000 per company each year. CSF’s cannot invest in other businesses or securities, and cannot have simultaneous multiple offers on participating crowdfunding platforms.

The Commissioner spoke about the temporary reporting and corporate governance concessions under the scheme: eligible public companies don’t need to have Annual Public Meetings or audited accounts for a period of 5 years; and the offer documents do not have to be as detailed as a full IPO prospectus. Whether these concessions will be enough to attract issuers, or whether the limitations prove more of a deterrent, it will be interesting to see if the new legislation meets the expectations of government, ASIC, issuers and investors.

Meanwhile, things are getting interesting for anyone following the FinTech hub story, and the perennial Melbourne-Sydney startup rivalry:

First, the Victorian government has issued an RFP for a Melbourne FinTech Hub (submissions close tomorrow…). The state government has also announced its partnership with Fintech Australia and others to host the intersekt festival, following last year’s Collab / Collide event.

Second, Melbourne’s York Butter Factory has recently announced plans to expand into Sydney. While not purely a FinTech hub, this new venture will feature the Commonwealth Bank as an anchor tenant. With former ANZ CEO Mike Smith as its Chair, YBF might also be expected to make a submission to the Victorian RFP.

Third, Sydney’s Stone & Chalk has just announced it will be opening a new FinTech hub in Melbourne. Given that a number of key Melbourne-based financial institutions (such as ANZ, NAB, AustralianSuper, Findex, Genworth and Liberty Financial) are backing this new venture, could it suggest they can’t wait for the Victorian RFP process to finish?

Next week: StartupVic’s Machine Learning / AI pitch night

 

 

Token Issuance Programs – the new structured finance?

We’ve known for some time now that Blockchain and Bitcoin were designed to disrupt the financial services sector. But I suspect that not even the earliest proponents of distributed ledger technology nor the most avid supporters of crypto-currencies anticipated how far and how quickly that disruption would spread. In addition to P2P payments and lending, alternative stock exchanges, and self-executing smart contracts, recent events suggest that digital assets issued on Blockchain infrastructure are themselves the new source of venture capital, that they may even come to be seen as the new form of structured finance (albeit with less complexity and more transparency).

Image: Maria’s Cakes founder issues her own record…. (Source: Maria Lee website)

In the past few weeks, we have seen Token Issuance Programs (sometimes referred to as ICOs – “initial coin offerings” – or token sales) raise extraordinary amounts of capital – $53m for MobileGo, $150m for Bancor. Even allowing for the fact that VC funding rounds have been increasing in recent years, these results are quite staggering – given that the sellers of these tokens have not had to relinquish any equity, or incur any debt either. Because tokens do not represent shares in a company or units in a corporate bond. Nor are they securities in the usual sense, as they do not create any interest or obligation other than an entitlement to be granted a given number of tokens at a predetermined price.

Of course, these tokens may carry the right to use proprietary software or access marketplace platforms, and even acquire future products. In this way, they also resemble crowdfunding projects. But because of the potential returns generated by the increased value tokens may accrue (a combination of network effects, scarcity and market appreciation), there is buyer demand for new tokens backed by the right project.

These token sale results have also benefited from the increased price of Bitcoin, Ethereum and other leading digital currencies – or perhaps the other way round? – as investors get more comfortable with this new asset class. That’s not to say there isn’t talk of a market correction, or even a bubble. But despite the apparent risks, and the occasional exchange outage, new token issuance and crypto-currency trading are generating growing interest – not just from currency speculators, but also asset managers and traditional investors. No doubt helped by developments in markets like Japan, where crypto-currencies are now a legally recognized form of payment.

As for structured finance, some projects are looking to issue tokens that are linked to or represent an underlying asset, such as a pool of loans. In the case of securitization, for example, Blockchain technology can not only help to structure the token issuance (via smart contracts, for example), it can also provide better transparency on the underlying loan performance (using real-time repayment data from bank feeds, for example).

Of course, there have been some speed bumps along the way for Blockchain-derived assets, most notably the infamous DAO “hack” of last year.  Plus, the price of Bitcoin continues to display considerable volatility, which makes it harder for some investors to embrace. And if anyone is wondering why this week’s blog features an image of a Hong Kong cake shop owner, it relates to the Asian Currency Crisis of 1997-98. Maria’s Bakery was a famous chain of shops that sold coupons at a discount, that could be redeemed for cakes at any time in the future. It was a practice that spread to other retail sectors. But during the market jitters caused by failing currencies and a tightening of credit, there was a run on Maria’s coupons, which coincided with a 2% fall on the Hong Kong stock exchange. This may have been coincidental, but it also demonstrates that financial markets can be sidelined by the most unexpected events. Like, who would have made the connection between over-extended home owners in parts of the USA with the worst global financial crisis for 80 years…?

NOTE: The comments above are made in a purely personal capacity, and do not purport to represent the views of Brave New Coin or any other organisations I work with. These comments are intended as opinion only and should not construed be as financial advice.

Next week: Expert vs Generalist

The FF17 Semi Finals in Melbourne

As part of the recent Melbourne Startup Week, Next Money hosted the Melbourne heat of the FF17 pitch contest, to decide which local FinTech startup will compete at the FF17 finals in Hong Kong later this week.

screen-shot-2017-01-15-at-8-15-03-pmAt the outset, I should declare an interest, as I myself was one of the pitch contestants, but hopefully that doesn’t preclude me from commenting on the event. The competing startups were as follows (as listed on the event Meetup page):

AirWallex

This payments solutions provider has featured in my blog before. Since the last time I saw AirWallex pitch, the market for cross-border remittance and payment solutions has drawn a lot of attention. First, the growing opportunity for exporters to market products and services to Chinese consumers and tourists means that payment platforms like AirWallex (and others like Novatti, LatiPay and Flo2Cash) are partnering with Chinese payment gateways such as WeChat Pay, AliPay, JDPay and Union Pay). Second, cross-border remittance services has become a key use case for Bitcoin and other digital currencies (as evidenced by the recent partnership between Novatti and Flexepin).

Analyst Web

Still in private beta, Analyst Web is aiming to disrupt the market structure (and payment model) for equity research. By enlisting qualified CFAs to write bespoke investment reports on listed companies, then distribute them via subscription services, Analyst Web claims to be bringing quality, objectivity and value for money to this investor service. Currently, investors have to rely on either brokers (who may offer “free” reports to their clients under soft dollar arrangements) to provide research on individual stocks; or subscribe to independent research houses (such as Morningstar). Typically, neither brokers nor the research houses cover the full market – tending to focus on the bigger stocks and those included in benchmark indices. Of course, companies themselves use investor relations services to issue commentary on their market performance and prospects, but these communications perhaps lack objectivity. There are also other models, such as the ASX Equity Research Service, whereby research providers are “sponsored” by the stock exchange to provide reports on qualifying companies to boost market coverage. Some of the challenges Analyst Web will need to overcome are: investor willingness to pay for research; market credibility and acceptance of their reports; and sustainable financial models that appropriately compensate the analysts without compromising independence and objectivity.

Proviso

Proviso has also been mentioned in my blog before, and they continue to impress with their solution to take friction out of the documentation processes for loan origination, and their ability to secure more financial institutions as clients. In my previous commentary, I noted that Proviso risked being disintermediated by an industry-owned utility. While I still think that is a possibility, I also see that the combination of Blockchain solutions (for distributed ledgers and bank data feeds) and more open APIs for financial data and account information may mean that customers themselves may be empowered to drive the process, since it will be easier for them to demonstrate their creditworthiness and establish their cashflow status, but also have better control over the disclosure of their data.

DragonBill

DragonBill, an invoicing solution for SMEs, is yet another of the FF17 contestants to appear in my blog, most recently when they presented at Startup Victoria’s regular pitch night. In addition to offering both direct payment and escrow options for micro-businesses and sole traders, DragonBill continues to mine an interesting niche market among sports clubs and associations – the reason being that many club members are themselves sole traders. As part of its future developments, the business is scoping a solution to help clients manage their superannuation obligations, and to provide informed advice on cashflow management.

BreezeDocs

Similar to Proviso, BreezeDocs is a document automation solution for lenders, although currently focusing on mortgage origination. And like Proviso, at the heart of the solution is the ability to streamline the extraction and processing of data from customer documents. On top of a core OCR capability, BreezeDocs also claims to be using machine learning to train their systems on different document types, formats, structure and content. Despite the use of ETL processes within financial institutions, the disparate nature of financial products and documentation; the way customer, product and transaction data is often maintained in different systems; and the fact that customers will often have accounts and products with different providers can undermine the need for standardised processes.

Vestabyte

As I commented in my previous blog, equity crowding may be about to come into its own as a way to connect investors with entrepreneurs and startups. Vestabyte are certainly enthusiastic exponents of this method for raising capital, but legal constraints mean that their platform still has to operate under a unit trust model, rather than offering access to investments in the form of direct shares in specific assets, companies or ventures. This may change if the proposed legislation can get through Parliament, although it’s far from being a done deal. But in the absence of formal legislation, it sounds like a great opportunity for a FinTech startup seeking funding to test ASIC’s first licensing exemption under its sandbox regime….

coHome

By their own admission, coHome is very much a nascent business – one that is still defining its customer offering. At its heart, this shared ownership service provides a matching service for aspiring property owners, along with some standard documentation for a co-ownership agreement, known legally as a tenancy in common. With multiple parties to the property transaction and mortgage application, coHome aims to streamline the process, make it easier for buyers to connect with other interested parties, and provide customers with appropriate legal safeguards. It’s clearly an admirable objective, and one that deserves to gain attention. But monetizing the service may prove challenging, unless coHome takes a commission from the mortgage providers, lawyers and conveyancers?

BugWolf

Not strictly speaking confined to the FinTech sector, nevertheless BugWolf, a tool for managing user-acceptance testing, has managed to gain traction with at least one of Australia’s Big 4 banks. Using gamification, competitions and other techniques to recruit, engage and manage teams of testers, BugWolf claims to support all aspects of functionality testing across software, websites and mobile apps. Combined with robust reporting and analytics, BugWolf can also help clients achieve shorter product development cycles.

Brave New Coin

I joined the team at Brave New Coin (BNC), a provider of market data for digital assets, in early 2016. So, it was the first time I have pitched, outside of hackathons, client presentations and sales conferences. And the fact that BNC was a last-minute confirmation for this event made it an even more interesting experience. Established about 3 years ago by a team of founders with an interesting mix of publishing, Bitcoin and full stack development experience, BNC has built a suite of data APIs (market prices, indices, exchange rates and analytics) for Bitcoin and most other crypto-currencies and Blockchain assets. While the APIs are typically used by developers, the growing interest in digital assets among brokers, investors and asset managers means that market data on these new asset classes is in demand, and BNC is busily building distribution partnerships and subscription deals with traditional brokers, market data vendors and exchanges. Recent price fluctuations for Bitcoin may suggest continued speculation in this currency, but the launch of investable and tradeable products such as CFDs, futures, ETFs and other derivatives also suggest that digital assets are starting to achieve broader market acceptance.

BankVault

Unlike other solutions to defeat hackers and hoaxers (e.g., anti-virus software, spam-filters, VPNs and proxy servers), BankVault uses virtual machine technology to protect customers’ bank details when they transact online. This means a “new and instant” machine is created for one-time use only, each time a customer launches the BankVault service. Offering both individual subscriptions and enterprise solutions, the business is in the process of launching in the USA.

Conclusion

The winner, based on the judges’ votes, was BugWolf, which came as something of a surprise to a number of the other contestants, myself included. Without wishing to sound churlish, this event was supposed to be about the future of finance (hence FF17…), so it would seem reasonable that the winner would be based in FinTech (as opposed to TechTech?). The result (although highly deserved and based on an impressive pitch), also reinforced my sense that this event did not draw the “usual” FinTech or startup audience in Melbourne, based on the many pitch nights and meetups I have attended over the past few years. From my perspective, neither was it an investor audience, nor a capital markets audience, meaning I wasn’t really sure who I was pitching to. I’m hoping that the organisers will reflect on this event, and look to make some changes for next year.

Next week: A few rules on pitching

What might we expect in 2017?

On a number of measures, 2016 was a watershed year. Unexpected election results, fractious geopolitics, numerous celebrity deaths, too many lacklustre blockbuster films, spectacular sporting upsets (and regular doping scandals), and sales of vinyl records are outpacing revenue from digital downloads and streaming services. What might we expect from 2017?

Detail from "The Passing Winter" by Yayoi Kusama (Photo by Rory Manchee)

Detail from “The Passing Winter” by Yayoi Kusama [Photo by Rory Manchee]

Rather than using a crystal ball to make specific predictions or forecasts, here are some of the key themes that I think will feature in 2017:

First, the nature of public discourse will come under increased scrutiny. In the era of “post-truth”, fake news and searing/scathing social commentary, the need for an objective, fact-based and balanced media will be paramount. In addition, the role of op-ed pieces to reflect our enlightened liberal traditions and the need for public forums to represent our pluralist society will be critical to maintaining a sense of fairness, openness, and just plain decency in public dialogue.

Second, a recurring topic of public conversation among economists, politicians, sociologists, HR managers, career advisors, bureaucrats, union leaders, technologists, educators and social commentators will be the future of work. From the impact of automation on jobs, to the notion of a universal basic income; from the growth of the gig economy, to finding purpose through the work we do. How we find, engage with and navigate lifelong employment is now as important as, say, choosing high school electives, making specific career choices or updating professional qualifications.

Third, the ongoing focus on digital technology will revolve around the following:

  • The Internet of Things – based on a current exhibit at London’s Design Museum, the main use cases for IoT will continue to be wearable devices (especially for personal health monitoring), agriculture, transport and household connectivity
  • Fintech – if a primary role of the internet has been for content dissemination, search and discovery, then the deployment of Blockchain solutions, the growth in crypto-currencies, the use of P2P platforms and the evolution of robo-advice are giving rise to the Internet of Money
  • Artificial Intelligence – we are seeing a broader range of AI applications, particularly around robotics, predictive analytics and sensory/environmental monitoring. The next phase of AI will learn to anticipate (and in some cases moderate) human behaviour, and provide more efficacious decision-making and support mechanisms for resource planning and management.
  • Virtual Reality/Augmented Reality – despite being increasingly visible in industries like gaming, industrial design, architecture and even tourism, it can feel like VR/AR is still looking for some dedicated use cases. One sector that is expected to benefit from these emerging technologies is education, so I would expect to see some interesting solutions for interactive learning, curriculum delivery and student assessment.

Fourth, and somewhat at odds with the above, the current enthusiasm for the maker culture is also leading to a growing interest in products that represent craft, artisan and hand-made fabrication techniques and traditions. Custom-made, bespoke, personalized and unique goods are in vogue – perhaps as a reaction to the “perfection” of digital replication and mass-production?

Fifth, with the importance of startups in driving innovation and providing sources of new economic growth, equity crowdfunding will certainly need to come of age. Thus far, this method of fund-raising has been more suited (and in many cases, is legally restricted) to physical products, entertainment assets, and creative projects. The delicate balance between retail investor protection and entrepreneurial access to funding means that this method of startup funding is constrained (by volume, amounts and investor participation), and contrary to stated intentions, can involve disproportionate set up costs and administration. But its time will come.

Finally, as shareholder activism and triple bottom line reporting become more prevalent (combined with greater regulatory and compliance obligations), I can see that corporate governance principles are increasingly placing company directors in the role of quasi-custodians of a company’s assets and quasi-trustees of stakeholder interests. It feels like boards are now expected to be the conscience of the company – something that will require directors to have greater regard to the impact of their decisions, not just whether those decisions are permitted, correct or good.

One thing I can predict for 2017, is that Content in Context will continue to comment on these topics, and explore their implications, especially as I encounter them through the projects I work on and the clients I consult to.

Next week: The FF17 Semi Finals in Melbourne