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FILLING THE PAINFUL WHITE SPACE BETWEEN DATA AND REGULATORY REPORTING – THE EXAMPLE OF CCAR

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By Christopher J.A. Messina

Data are overwhelmingly abundant throughout the financial services and capital markets ecosystems. Over time, processes and software have been developed to bite off discrete chunks of that data for use in specific tasks. Due to demand from market participants with deep pockets, the supply of well-crafted and increasingly data-enabled systems has grown robustly over the last 30 years.

But crucially, the ‘white space’ on the financial technology supply-demand curve is for quantitatively-based systems to meet the needs of non-quantitatively inclined professionals who are suddenly highly reliant on the information contained in quantitative information.

That white space has become more glaring following the passage in the US of the Dodd-Frank Act and EMIR in Europe. Sudden legislative fiat means that traditionally ‘non-quantitative’ lawyers and compliance experts are tasked with massive amounts of data digestion along with reporting to a slew of new audiences. The real financial penalties associated with failing to comply with the new reporting requirements are harsh and mandated by statute, with no room for rational compromise between mature, experienced adults in developed markets.

There has always been a tension in the capital markets between the differing comprehension that market professionals and regulators can have of events, markets and rules. That tension most often manifests itself in repetitive anecdotes about the conflicts between regulators and market participants, where each ‘side’ of a regulatory dispute is genuinely astonished that the other side interprets the same event utterly differently. That well-trodden path I leave for someone else to walk down. Besides, as one of my statistics professors was wont to repeat with little to no prodding: The plural of anecdote is not ‘data.’

Christopher Messina

Christopher Messina

Today, the more fundamental issue is the unprecedented amount of data that many financial industry entities now have to gather, maintain, analyze and report on to meet a burgeoning regulatory mandate. This flood of compliance reporting has hit the industry with huge associated costs. But, as many firms are finding, even if you can find a sufficient number of educated, experienced staff to handle these new mandates, it does not assure that you are going to fulfill your obligations properly or in a timely manner.

It is so very challenging to select just one illustrative example from the constellation of data-reliant reports which impassioned, crisis-wrought legislation has brought into being. We can gain some insights by examining the practical impacts of one filing required in the United States which has hit 30 Bank Holding Companies in the US since 2012. The Federal Reserve Board requires that banks file periodic reports of their Comprehensive Capital Analysis and Review (CCAR), which is in large part the result of stress testing of numerous operational data sets.

There can be up to 300 factors examined by the CCAR, which means first off huge new data collection, retention, access and analysis needs by staff throughout the enterprise. This massive data governance problem has attracted a great deal of investment in personnel and systems, with a number of well-thought-out data management solutions offered by a range of capable technology vendors. Most of the reporting requires varying levels of granularity and places varying emphasis on different subject matter experts across the business – from trading to risk management to middle office functions, and including compliance and legal departments.

The white space still exists, however, because the output of all these very powerful data aggregation, governance and analysis tools is still a dashboard or a table or graph. Moving, managing and analyzing vast amounts of data are not trivial tasks, but once all that data manipulation is done, the same bottleneck exists: To wit, a human expert then needs to perform further analyses and write up the results. Given the vast array of new report types that need to be created and the number of times each report needs to be customized for different audiences, that write-up time alone is a massive cost sink for firms struggling to comply.

As well as ‘the doing’ of turning reams of data into meaningful monthly or quarterly reporting, there is ‘the demonstrating’. Under this mandate, banks also need to be able to show in detail how that they are complying with the legislation. This is part of the regulatory reality that must be addressed, and is another layer of costs incurred in report-writing.

Lurking at the back of every executive’s and every risk manager’s mind is also the fear that maybe something crucial was missed. Maybe it happened in the choice of data sampling methodology, perhaps it was further down the chain in the way a certain factor among 300 was (potentially) mischaracterized – the list of possible errors in the translation from machine output through human expert processing is vast, unnerving and something to be driven out of your conscious mind as firmly as possible.

This topic is of huge interest to the data scientists at Arria NLG. The entire suite of IP underlying Arria’s technology happens to fill in significant pieces of that very painful white space. The Arria NLG Engine helps banks deal with exactly this headache. The NLG Engine unlocks the bottleneck of human time constraints by doing with quantitative outputs what a human SME does, including crucially writing the final range of required reports. Arria’s artificial intelligence engine acts as a translation layer between hard data and the wide range of audiences who need to act on that data, many of whom do not have significant quantitative training.

Importantly for real business use, the NLG Engine produces articulate, customized texts that replicate the language required by the firm’s SMEs, keeping a critical sense of brand consistency and tone that can be adapted according to the user’s needs. It’s in no way what one would call ‘robotext’ – quite the contrary: Arria’s systems currently in place write texts which the clients’ in-house owners cannot distinguish from those written by their human colleagues.

Thirty years ago, Ehud Reiter and Robert Dale began a process of exploration that started with a very simple question: Can we build computer systems that will not only perform highly sophisticated analysis of big, complex data sets, but will take that data analysis to its logical conclusion and generate articulate, grammatically-correct written human language summaries out the other end?

Halfway through that journey, in 2000 they co-authored Building Natural Language Generation Systems, which remains the definitive text on the subject. Twenty-seven years into that journey, sufficient market demand had arisen to turn the academic project into a commercial offering.

We have all experienced this in one way or another: Some of the best technology we now use every day was created by tinkerers, creative types and academics – not with a potential application in mind, but as an intellectual exercise, a way to solve a problem that an inventor finds interesting.

Arria’s Computational Linguistics solution was not designed to meet the needs of time-pressed lawyers, risk managers and compliance officers dealing with an unprecedented torrent of regulatory reporting, but it has turned into one of the most powerful tools available to make that compliance effort as efficient and painless as possible.

For more color on how Arria’s NLG Engine is applicable to risk management and compliance, please see a recent interview with Larry Tabb: http://tabbforum.com/videos/finding-risk-before-it’s-a-problem.

About the Author

Christopher Messina is SVP, Business Development for Arria NLG plc. Mr. Messina has 20 years of experience in the global capital markets, private equity and financial technology, including deep understanding of the evolution of financial regulatory regimes. He has worked in the Americas, Africa, Europe, Australia, and the Middle East. A member of Business Executives for National Security, Mr. Messina is a graduate of the University of Chicago and the Australian Graduate School of Management. He is a contributing author to Shari’ah Compliant Private Equity: A Primer for the Executive (Euromoney Books, 2010), and has lectured on derivatives, commodities and Shar’iah finance at law schools and conferences globally.

Finance

The ever-changing representation of value

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The ever-changing representation of value 1

By Vadim Grigoryan, Partner, Lunu Solutions

Ask a selection of people about cryptocurrencies and you’ll likely receive a wide range of answers. Some will wax lyrical about the huge potential of the underlying infrastructure that supports them, while others will dismiss them as nothing more than a worthless speculative bubble.

Cryptocurrencies have often been described in this way, mainly because – according to their opponents – they aren’t backed by tangible value. This is an argument that could easily be dismissed as very short-sighted, particularly if we remind ourselves that our current currencies all rely on trust – not exactly the most tangible of assets.

As Kabir Sehgal, a bestselling author and former JP Morgan vice-president, said: “In order to deal in money, humans must be able to think symbolically”. Financial history teaches us that money, in its first intent, was almost never meant to have intrinsic value – but to be a representation of it. For example, the porcelain-like shell of the cowry circulated around the globe for 4,000 years – longer than any other currency in the history of money. And its value was perceived not on its intrinsic utility, but on its beauty. Indeed, intrinsic value has long stopped be a measure of the real value of money. Let us not forget that each individual banknote costs a fraction of what it’s worth to produce – a $100 bill costs around 12 cents.

Money first appeared from the original evolutionary need to eat and survive by exchanging energy with another. That is why money has become whatever represents that energy: first food commodities – such as barley, cacao beans or salt – and then the tools to cultivate them. The symbolic distancing of money from its real value has developed over the years into coins, paper currency and mobile payments. Since money is fundamentally a mental abstraction of symbolic representation of value, what money is and what it will be can be is limited only by human imagination. Could something as invisible and intangible as cryptocurrencies be the next step?

Building value through trust

Something that has value should check two boxes: scarcity and utility. Scarcity of cryptocurrencies is often guaranteed by their design, in terms of a finite or limited supply (e.g. Bitocoin has a set cap of 21 million coins). Their utility is already embedded in the divisible nature of cryptos (unlike gold, which is very difficult to use transactionally, you can buy a coffee, a ferrari or a house with bitcoins). As such, the potential of cryptos to be a more efficient currency than what we already have would further increase with the wider adoption of digital currencies in retail.

We know that the representation of value has changed over time and is a fast-moving one in our society. That’s one reason why the concept of ‘money’ is much more abstract and complicated than most people realise.

But one thing that has never changed throughout the long evolution of money is the importance of trust. The reason money works is because people trust in its value; this is a key rationale behind most currencies – including cryptos. In fact, one of the key selling points of cryptocurrency is that it is built specifically on trust.

Although they lack the legal and institutional backing of traditional financial services, cryptocurrencies provide trust through technology. Blockchain technology enables the use of a distributed and immutable ledger of records, providing total transparency and making every transaction tamperproof. Data is decentralised and encrypted so that it can’t be interfered with or changed retrospectively. The crypto sphere is also intrinsically democratic. There is no central authority and no individual entity can change the rules of the game, which protects against government interference and makes it almost impossible to lobby private interests.

So, with this in mind, why are cryptocurrencies still largely used as an asset rather than a means of payment? It’s mainly because the real-life economy is still lagging in terms of providing crypto-based payment solutions. Many stores still fear accepting cryptos as a means of payment – whether due to technical limitations or concerns around fees and exchange rates – creating a vicious circle reinforcing the speculative nature of cryptos as assets that are just bought and sold.

We believe it’s time to break this circle and move towards a new financial model that accepts cryptos as a means of payment. It’s time for cryptocurrencies to be appreciated for the value they provide.

Recognising crypto personas

Our research into the ever-growing crypto community has uncovered an ecosystem of global citizens that share a philosophy; one pegged to a thirst for freedom, equality, inclusion and global interaction. For example, they are actively involved in social causes and place a high value on social responsibility for individuals and companies.

We also identified several different persona groups within that ecosystem, all of which have varying degrees of influence in the community.

  • Hamsters: this group is enthusiastic about cryptos, but lacks either the wealth or knowledge to shape the market or effectively navigate it.
  • Geeks: comprised of tech-savvy specialists who expect others to be up to their level of technical expertise
  • Cool cucumbers: a group of wealthier individuals focused on the investment opportunities and less emotionally involved with cryptos as a way of life

But the most powerful and engaged of the various user groups we identified, is the one containing individuals who have the financial capital and technical knowledge to drive and shape the future of the market – the Apostles. They are the community gurus, the public figures and the influencers who aren’t afraid to voice their opinions. Indeed, their minds have the power to drive widespread adoption of cryptos.

Over the coming years, this cohort of individuals will continue to grow and impose its expectations on retailers and stores. They understand the concept of money as a representation of value and recognise the role that secure, decentralised and globally connected cryptocurrencies can play in the existing economy.

If money is a symbol of value, this community appreciates the need for other symbols that represent other values in the world of tomorrow – such as transparency, empowerment and the end of the abuses of power that we have seen in the past.

Ultimately, although cryptocurrencies have been inching their way into the mainstream steadily since their introduction in 2009, the main stumbling block has been how to use them in everyday life. The good news is that we are during a transition. Trust is continuing to build, and the ‘value’ barrier is slowly being overcome. There is light at the end of the tunnel – driving cryptocurrencies and other forms of digital money forwards as the next step in money’s ongoing evolution.

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Finance

Revolut Junior introduces Co-Parent – teach children about money together

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Revolut Junior introduces Co-Parent - teach children about money together 2
  • Premium and Metal customers can invite a team mate to jointly manage their child’s Revolut Junior account
  • Setting Tasks, Goals and topping up up Allowances can also be done by a Co-Parent
  • Lead and Co-Parents both have full visibility and oversight of the child’s account

Revolut has today announced that parents can now add a Co-Parent to supervise their child’s Revolut Junior account and make learning about money easy and fun together, because teamwork makes the dream work.

Those on paid plans (Premium and Metal) will benefit from the new Co-Parent feature at no extra cost. The lead parent can invite a Co-Parent to join Revolut on any plan, including a Standard plan. The Co-Parent can be another family member, carer or  guardian who is responsible for the financial wellbeing of the kids.

Parents and guardians can use Revolut Junior to teach their little ones important lessons about finances and responsibility so they become more informed with each passing day. Both the lead and Co-Parent can use Tasks to teach children the value of money, Goals to help them learn to save and top up Allowances when they deserve a reward or just their weekly pocket money. Both will have full oversight of the child’s Revolut Junior account.

To add a Co-Parent to Revolut Junior, the lead parent can head to the Junior tab to find the Co-Parent invite link at the bottom of the screen.

Revolut Junior’s five top tips for parents/guardians to make learning about money fun 

  1. The power of together: Utilise the power of your joint experience and arrange a time or schedule a regular monthly meeting to sit down as a family to answer any money questions your kids may have.
  2. Set your own Goals: Learning the usefulness of savings is a valuable life lesson that will benefit kids when they hit adulthood. So if your child has been begging for a new game or toy, then encourage them to create Goals to save up faster and more steadily. Parents can add to it or children can choose to fund it from their allowances or by completing tasks, giving them some financial independence, but with full parental oversight!
  3. Sharing is caring: Show your child your app and how you use it to manage money so they see how the ‘grown-ups’ do this. Perhaps take a look at Budgets, and explain your reason for using this.
  4. Cherish your belongings: Get your child to put their top 10 favourite possessions in front of them and ask them to tell you why they picked each one. Explain the importance of selecting items they really like instead of comparing them with what their friends have.
  5. Money matters: Inspire your child to take some time for themselves to go through their purchases and expenditures in-app and use this time to reflect on if they still use all these items or if the buys were a good use of money.

Felix Jamestin, Head of Premium Product at Revolut, said: “We have added the Co-Parent feature to Revolut Junior so parents, guardians and carers alike can come together to teach their kids valuable skills for life. We have made sure that those with unconventional or multigenerational families will also be able to use this, so not only parents but grandparents, carers or members of their wider family can also support their child through their financial education with Revolut Junior.”

Revolut Junior’s Co-Parent feature is currently available to all Revolut Premium and Metal users in the EEA and the UK. It’s designed for kids aged 7-17, providing an account for children to use, controlled by their parents or guardians. So far over 270,000 kids have signed up to Revolut Junior. Revolut Junior has just launched in Australia, and plans to launch the product in Singapore and Japan in the near future.

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Finance

Banking on the Future: Why Payments Transformation is the Key to Success

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Banking on the Future: Why Payments Transformation is the Key to Success 3

By Simon Wilson, Co-Head, Payments at Icon Solutions

Standardisation, regulation and technological innovation means payments are well on the way to becoming instant, invisible and free. This is good news for everybody.

Well, not quite everybody. Banks are now faced with the significant challenge of transforming business models and legacy technology systems to meet the demands of a new era in payments.

Banking is historically a conservative and risk-averse industry where the pace of change varies between sedate and glacial. But now is not the time to ‘wait and see’ and finding the right approach to payments transformation must be the immediate and fundamental priority for banks.

Understanding the need to transform

Firstly, we must ask: Why has payments transformation become an urgent priority?

For one thing, increased competition has seen banks’ market share of the global banking and payments industry reduce from 96% in 2010 to 72% today. Fintechs, challengers, payments companies and big tech have entered the playground and started taking banks’ lunch money, demonstrating a level of innovation and agility that incumbent banks are struggling to keep up with.

And of course, there is Covid-19. We have seen years, if not decades, of change in a matter of months. The crisis has torpedoed traditional and reliable revenue streams such as cross-border payments to accelerate margin pressure, while driving a rapid shift to online banking channels and a massive uplift in digital volumes.

Breaking the shackles

In the context of increased competition and unprecedented digitalisation, the banking industry is waking up to the fact that payments are about adding value, not just processing. There is increasing recognition that capitalising on the potential of emerging payment rails, monetising the standardised datasets unlocked by ISO 20022 and launching new external services are huge opportunities to diversify and retain relevance. The introduction of overlay services such as Request to Pay or the European Payments Initiative are also poised to spur on the move to digital payments.

Decades of inaction on legacy infrastructure, however, is limiting options. Banks across the globe find themselves lumbered with expensive, inflexible and unreliable technology estates. The ability to respond to marketplace innovation, let alone lead it, is constrained by the need to devote massive amounts of cash, time and ever-dwindling internal resource to simply keep the lights on.

It is apparent that doing nothing is no longer an option, but transformation is a nebulous concept. There is no one single way to effectively transform. Different organisations have unique considerations based on their technology, capabilities, resource and culture, and there are various routes to take.

‘Don’t outsource your heart, your soul…and your spinal cord’

One option is to make payments someone else’s problem and outsource them. This can be an appealing proposition to get a seemingly perennial cost centre off the books, particularly in the current climate. But speaking at Sibos, J.P. Morgan CEO Jamie Dimon cautioned against the risk of inadvertently “outsourcing your heart, your soul and your spinal cord.”

Simon Wilson

Simon Wilson

For it is true that payments are the beating heart and soul of an organisation. Payments represent 80% of all interactions, providing critical customer touchpoints, data and service opportunities. As for the spinal cord, not much can happen when mission-critical payment systems go down.

The big problem, as Dimon notes, is that a lot of companies who have outsourced “have no idea what they are doing.”

Banks can find themselves stuck with equally costly, complex and cumbersome alternatives, falling even further behind the innovation curve and losing control in the process. “You end up paying too much money and then you’re beholden to costs that are going up.” But most importantly, “you’re not even doing a better job serving your client.”  Outsourcing a commodity execution service may well be the right strategic approach for some, but you need to ensure you have the other pieces of the payment process running smoothly and that you really are not leaving money on the table or  developing risk longer term by constraining future choice.

Still, the alternative is not necessarily better. Modernisation needs to happen now, so it is not surprising that enthusiasm for years-long, ruinously expensive and inherently risky in-house transformation projects has dimmed somewhat.

Best of both worlds

Yet it is wrong to say that the only choice is buy or build. There is a middle-ground. A collaborative approach to payments transformation that allows banks to move quickly to seize opportunities, while retaining control, significantly reducing costs and adding value.

This begins with banks understanding their starting point, defining a crystal-clear strategic vision for the role that payments play within the organisation and identifying market opportunities. Indeed, as McKinsey notes, “success for banks will depend on thoughtfully assessing capabilities [and] determining the role of payments in market strategies.”

Banks should then consider low-risk and lightweight options for upgrading legacy infrastructure to meet their strategic objectives, while minimising business impact. Payment platforms based on Cloud-native, open source technology promote flexibility, scalability and independence, rather than restrictive and expensive vendor dependencies.

Collaboration also plays a critical role. Finding the right fintech and service provider partners can allow banks to simplify complexity, reduce manual heavy-lifting and lower their cost base, driving efficiencies that enable resource to be focused on delivering for customers. As Dimon explains, “If I can’t build it better than you can, I’m better off just using yours.”

This combination of strategy, enabling technologies and true collaboration provides a foundation for innovation. It can help drive new revenues, further develop existing business lines and, by moving payments from cost to profit centre, help banks thrive rather than survive.

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