Is crypto finally going mainstream?

Just as my last blog on crypto regulation went to press, news broke that CBA (one of Australia’s “four pillar” banks) will be adding crypto assets to its mobile banking app. Add that to the launch of a crypto equities ETF by BetaShares, and further media coverage of local digital asset fund manager Apollo Capital, and you may start to believe that crypto is finally going mainstream in Australia.

But, before anyone gets too excited, a few caveats are in order.

First, the recent flurry of announcements from the Australian Senate, ASIC and AUSTRAC are simply the latest stages in a long-running debate about how crypto assets should be regulated, serviced and distributed. Despite these positive noises, there is still some way to go before crypto reaches critical mass (even though data for Australia shows we have one of the higher rates of market adoption).

Second, there is a lot of noise out there, and not all of it here in Australia. The SEC, FATF, ISDA, Cboe and SGX are just a few of the institutional voices making announcements on crypto and digital assets in recent weeks. On top of that, of course, there is the President of El Salvador (and the Mayor-Elect of New York) weighing in on behalf of the politicians. Some of this commentary is mere posturing; some is about being seen to be doing something; and a large part is just the legacy markets trying to catch up (and hoping to take control?).

Third, a closer look at CBA, BetaShares and Apollo Capital reveal some significant limitations in terms of what their products actually offer:

The CBA is planning to launch a trial among a small sample of their mobile banking users (although, no doubt, if things go well, it will be rolled out more extensively). But it does not mean the app becomes a fully-fledged crypto wallet: customers will only be able to buy/sell crypto within the app, and they won’t be able to send crypto to third parties. Plus, only a small set of crypto assets will be available.

The BetaShares ETF is not offering direct exposure to Bitcoin or other crypto assets. Instead, the fund is designed to invest in companies (mainly crypto exchanges, miners and technology providers) that are significant or strategic industry players. While that may mitigate the market volatility (and price fluctuation) that crypto experiences, it doesn’t necessarily make for higher returns.

The Apollo Capital fund is only available to wholesale or accredited investors – not retail customers. And while Apollo has done a reasonable job of growing its AUM, I don’t believe there are any major allocations from Industry Super Funds (which manage 27% of Australians’ retirement savings), Retail Funds (21%) or Public Sector Funds (18%). And despite anecdotal evidence that Self-Managed Super Funds (SMSF) are more active in crypto assets (along with Family Offices and HNWIs), recent data from the ATO suggests crypto assets held within SMSF are not much more than $200m.

Having worked in this industry since 2016, it’s always been apparent from an institutional perspective that few want to go first, but nobody wants to be last, when it comes to launching crypto products and services. Of the three Australian stories this week, the most significant is probably the CBA; it certainly got a lot of attention at the recent State of Play presentation by Blockchain Australia, in large part due to the industry implications, and how it will help bring crypto to an even wider audience.

Next week: Summing Up (and Signing Off)

 

 

Startupbootcamp – Melbourne FinTech Demo Day

Taking its cue from some of the economic effects of the current pandemic, the latest Startupbootcamp Melbourne FinTech virtual demo day adopted the theme of  financial health and well-being. When reduced working hours and layoffs revealed that many that people did not have enough savings to last 6 weeks, let alone 6 months, lock-down and furlough have not only put a strain on public finances, they have also revealed the need for better education on personal finance and wealth management. Meanwhile, increased regulation and compliance obligations (especially in the areas of data privacy, cyber security and KYC) are adding huge operational costs for companies and financial institutions. And despite the restrictions and disruptions of lock-down, the latest cohort of startups in the Melbourne FinTech bootcamp managed to deliver some engaging presentations.

Links to each startup are in the names:

Datacy

Datacy allows people to collect, manage and sell their online data easily and transparently, and gives businesses instant access to high quality and bespoke consumer datasets. They stress that the data used in their application is legally and ethically sourced. Their process is also designed to eliminate gaps and risks inherent in many current solutions, which are often manual, fragmented and unethical. At its heart is a Chrome or Firefox browser extension. Individual consumers can generate passive income from data sales, based on user-defined permissions. Businesses can create target data sets using various parameters. Datacy charges companies to access the end-user data, and also takes a 15% commission on every transaction via the plugin – some of which is distributed to end-users, but it wasn’t clear how that works. For example, is it distributed in equal proportions to everyone, or is it weighted by the “value” (however defined or calculated) of an individual’s data?

Harpocrates Solutions

Harpocrates Solutions provides a simplified data privacy via a “compliance compliance as a service” model. Seeing itself as part of the “Trust Economy”, Harpocrates is making privacy implementations easier. It achieves this by monitoring and observing daily regulatory updates, and capturing the relevant changes. It then uses AI to manage a central repository, and to create and maintain tailored rules sets.

Mark Labs

Mark Labs helps asset managers and institutional investors integrate environmental and social considerations into their portfolios. With increased investor interest in sustainability, portfolio managers are adopting ESG criteria in to their decision-making, and Mark Labs helps them in “optimising the impact” of their investments. There are currently an estimated $40 trillion of sustainable assets under management, but ESG portfolio management is data intensive, complex and still emerging both as an analytical skill and as a practical portfolio methodology. Mark Labs helps investors to curate, analyze and communicate data on their portfolio companies, drawing on multiple database sources, and aligning to UN Sustainable Development Goals. The founders estimate that there are $114 trillion of assets under management “at risk” if generational transfer and investor mandates shift towards more ESG criteria.

MassUp

MassUp is a digital white label solution for the property and casualty insurance industry (P&C), designed to sell small item insurance at the consumer point-of-sale (POS).
Describing their platform as a “plug and sell” solution, the founders noted that 70% of portable items are not covered by insurance policies, and many homes and/or contents are either uninsured or under-insured. MassUp is intended to simplify the process (“easy, accessible, online”), and will be launching in Australia under the Sorgenfrey brand in Q2 2021. For example, a product known as “The Flat Insurance” will cover items in and out of your home for a single monthly premium. As MassUp appears to be a tech solution, rather than a policy issuer, underwriter or re-insurer, I couldn’t see how they can achieve competitive policy rates both at scale and with simplicity (especially the claims process). Also, as we know, vendors love to “upsell” insurance on tech appliances, but many such policies have been seen to be redundant when considering existing statutory consumer rights and product warranties. On the other hand, short-term insurance policies (e.g., when I’m traveling, or on holiday, or renting out my home on AirBnB) are increasingly of interest to some consumers.

OnTrack Retirement

Ontrack provides B2B white label digital retirement planning solutions for financial institutions to help their customers in a more personalised way. There is a general consumer reluctance to pay for financial advice, but retirement planning is deemed too complicated. Taking an “holistic” approach, the founders claim to have developed a “best in class simulation engine” – founded on expected retirement spending priorities (rather than trying to predict the cost of living in 20 years’ time). Drawing on their industry experience, the founders stated that a key challenge for many financial planning providers is getting members comfortable with your service. I would also add that reducing complexity with cost-effective products is also key – and financial education forms a big part of the solution.

In Australia, the past 10 years has seen a major exit from the financial planning and wealth management industry – both at the individual adviser level (higher professional qualification requirements, increased compliance costs, and the end of trailing sales commissions in favour of “fee for advice”); and at the institutional level (3 of the big 4 banks have essentially withdrawn from offering financial planning and wealth management services). At the same time, there have been a number of new players – including many non-bank or non-financial institution providers – offering so-called robo-advice and “advice at scale”, mainly designed to reduce costs. In addition, the statutory superannuation regime keeps being tweaked so it is increasingly difficult to plan for the future, with the constant tax and other changes. Superannuation (a key success story of the Keating government) is just one of the “pillars” of personal finance in retirement: the others are the Commonwealth government aged pension (means-tested), personal wealth management (e.g., investments outside of superannuation); and retirement housing (with the expectation of more people opting to remain in their own homes). I would also include earnings from part-time employment while in “retirement”, as people work longer into older age (either from choice or necessity) – how that aligns with the aged pension and/or self-funded retirement is another part of the constantly-shifting tax and social security regime.

Plastiq.it

This product describes itself as a customer data platform that powers stored value, and was described as a “Safe harbour” solution (I’m not quite sure that’s what the founders meant in this context?). According to the pitch, consumers gain a fair and equitable outcome (consumer discounts), while retailers get targeted audiences. The team have created a vertically integrated gift card platform (working with MasterCard, Apple Pay and GooglePay), and launched JamJar, a cashback solution.

RegRadar

Similar to Harpocrates (above), RegRadar is a regulatory screening platform that helps companies “to set routes and avoid crashes”. The tool monitors regulatory changes (initially in the financial, food and healthcare sectors) and uses a pro-active process to developing a regulatory screening strategy, backed by analysis and a decision-support tool.

Having worked in legal, regulatory and compliance publishing for many years myself, I appreciate the challenge companies face when trying to keep up with the latest regulations, especially where they may be subject to multiple regulatory bodies within and across multiple jurisdictions. However, improved technology such as smart decision-support tools for building and maintaining rules-based business systems has helped enormously. In addition, most legislation is now online, so it can be searched more easily and monitored via automated alerts. Plus services such as Westlaw and Lexis-Nexis can also help companies track what is currently “good” or “bad” law by tracking court decisions, law reports and legislative updates. 

Next week: Goodbye 2020

The Finnies

The third annual FinTech Australia awards were celebrated in Melbourne last week, following the organisation’s relocation from Sydney during the past 12 months. Any concerns the organisers and sponsors may have harboured (given the switch in geography) were easily allayed, as the event was sold out, with over 300 guests in attendance.

The overall winners were definitely B2C brands – challenger banks, consumer lenders, payment providers – with Airwallex, Afterpay (which despite some recent negative press was named the FinTech of the year for the third time) and Up Bank taking out more than a third of the awards between them.

Despite the 30 per cent increase in the number of entries (over 230 in all), it did feel like the Fintech community is still something of a village, as several award presenters were themselves presented with awards. Maybe something for the organisers to think about for next time, as it’s not always a good look when winners end up presenting to each other.

On the other hand, the organisers are to be commended for the running order – unlike some industry events, the awards were all presented in a single session, and not dragged out from soup to nuts. It was also a great decision to use the Victorian Innovation Hub as the venue, as well as have grazing-style catering instead of a sit-down dinner. And the choice of live band was excellent, as past, current and future bankers cut a rug.

Next week: Brexit Blues

 

Life After the Royal Commission – Be Careful What You Wish For….

In the wake of the recommendations from the Royal Commission into Misconduct in the Financial Services Industry (aka the Hayne Report), one of the four major banks announced that it would be removing bonus payments for its front line tellers. This was supposedly in line with Hayne’s proposal that performance-linked remuneration, financial incentives and sales commissions in the financial services industry need to be restructured.

Image sourced from Small Caps

This prompted a mixed reaction among the public, based on some of the comments I have read on social media. Some felt that the tellers were being made scapegoats for the banks’ bigger failings – others felt that this was an inevitable outcome from the banking backlash.

Personally, I believe the announcement is potentially just one of the many likely “unforeseen consequences” to come out of the Royal Commission – I’m not saying this particular decision is good or bad, just that we need to be aware of what’s likely to happen based on Hayne’s key recommendations. Be careful what you wish for. And, as an underlying theme to this whole debate, let’s not forget that most Australians are shareholders (directly or indirectly via their Super) of the Four Pillar Banks (one of the greatest government-endorsed and legislatively protected market oligopolies around which also helped steer us through the GFC relatively unscathed….).

So, what else might we see?

First, as with financial advice, residential mortgages will move to a “buyer pays” model. Brokers would not be able to receive commissions from mortgage providers or other intermediaries based on the products they sell, recommend or refer – instead, mortgage applicants will be expected to pay for the services of a broker, who will therefore be under an obligation to find the best product for their client. But removing trailing commissions and other conflicted remuneration may also mean that brokers could seek to earn additional fees from their mortgage clients by re-contacting them a year or so later (with permission, of course) to inform them of a better deal. (Even now, lenders are not explicitly obliged to let existing customers know if they have a newer product that may be better for them). Some estimates suggest that fee-for-service will add about $3,000 to the initial cost of applying for a mortgage. Whether this will also lead to more competition among mortgage providers (who will no longer have to pay broker commissions) is not clear.

Second, the increased focus on acting in the best interests of the customer may result in placing all financial planners, brokers, advisors, insurers, and banks (and their officers, agents and employees) under a fiduciary duty of care to their clients – even if they are not directly managing specific assets, selling a specific product or advising on specific services or financial strategies. In other words, advisors etc. will be deemed to have taken ALL of a client’s needs and circumstances into account. (This is largely the result of the miss-selling of financial products, and the charging of fees for “no service”, by banks and their retail wealth management arms.)

Third, the increased cost of compliance will disproportionately impact smaller financial institutions such as credit unions, member-owned banks and other mutual societies, who came through the Royal Commission pretty much unscathed. Those costs will need to be passed on, to customers and members. Of course, there has also been some political debate around the need for some sort of banking levy – which will ultimately be passed on to shareholders or customers (who are often the same people…).

Fourth, and related to the above, the separation of roles between those superannuation trustees who act as both fund trustees and as responsible entities of managed investment schemes will have a knock-on effect in terms of operating and compliance costs. Such dual-regulated entities will have to decide whether to focus on their trustee role, or appoint a separate and independent responsible entity in respect of the asset management.

Fifth, the higher compliance and regulatory obligations may deter or inhibit more competition – either from new market entrants from overseas, or from local start-ups. The recent restricted ADI model (aimed at enabling challenger or neo-bank brands) has not exactly seen a raft of applications, and off-shore banks tend to come and go in successive waves, largely driven by market conditions. If lending standards are further tightened, it may be less attractive for foreign firms to set up local operations. In fact, there have been calls to force some smaller superannuation funds to merge with larger funds, or exit altogether for reasons of scale and efficiency – potentially taking out some of the competition in that sector. And if mortgage brokers have to move to a fee-for-service model, it will likely force some providers to exit the industry, as happened with the FOFA reforms in financial planning and wealth management.

Sixth, at the level of corporate governance, boards of financial services providers will need to be mindful of their duty to act in the best interests of the company – which has traditionally meant the share holders – and the increased duty of care towards their customers, which may at times be at complete odds. Non-executive directors willing to serve on the boards of banks and insurers may also be harder to find, at a time when there is already a high concentration of directors who sit on multiple boards across Australia’s biggest companies. So, board diversity may be even harder to achieve, especially if non-executive directorships become subject to even greater formal qualification, to ensure board members have appropriate professional experience, industry knowledge and technical expertise, as well as financial competence and risk management skills.

Finally, all this is happening as we face something of a credit squeeze (thanks to increased lending standards and greater provisioning for risk-weighted assets) heightened economic uncertainty (slowing GDP growth, lower productivity, wage stagnation, falling property prices), and an upcoming General Election campaign during which the Hayne Report will be held up as a key reason for why “things have to change”. The irony being that, except in a few areas, the complaints aired and wrong-doing uncovered during the Royal Commission could have been addressed by the regulators and enforcement agencies via existing laws on financial services, prudential standards, and general consumer protection (unfair contract terms, unconscionable conduct, deceptive and misleading behaviour). Plus, the Australian Financial Complaints Authority (which combines the remit of the former Financial Ombudsman Service, the Credit and Investments Ombudsman and the Superannuation Complaints Tribunal) has a wide jurisdiction over consumer complaints relating to Credit, Finance and Loans, Insurance, Banking Deposits and Payments, Investments and Financial Advice, and Superannuation. And as with most External Dispute Resolution agencies, AFCA and its predecessors have an obligation to report on systemic issues within their industry.

Next week: Pitch X