Digitalization is leading to a large number of new products and services in the financial services sector. Actors such as fintechs are developing new business models, but IT companies and e-commerce companies are also increasingly offering financial service products.
There are numerous innovative offers for carrying out payments by voice, text message or even wearables. There are also new account information services and payment initiation services. Depending on the type and scope of the business, companies can find themselves active in a regulated sector. This means that, on the one hand, regulatory requirements have to be met, and on the other hand that approval by the supervisory authorities may often be required.
The trend toward automated credit decisions is striking here. This trend includes various services that are easier for customers to access and in particular faster and— whenever possible — free. This trend is reinforced both by the withdrawal of many banks from the nationwide offer of branches and by the decreasing willingness of customers to pay for financial services.
A central challenge here is to comply with the regulatory requirements. This is a basic prerequisite for permission to offer a wide range of services.
Providers of these services are confronted with several challenges: the question of the first approval as a licensed company, as well as a multitude of regulatory requirements during operation. This applies not only to questions of risk management, but also to specific requirements regarding the structure and organization of business operations.
With the development of new business models, the following questions typically have to be answered:
Is a product or service offering subject to licensing and does the application for a corresponding license need to be submitted to the supervisory authority? Then the relevant documents must be submitted, and the supervisory authority reviews them before the license is granted. These documents include the following, among others:
- Description of the business model and business case
- Introduction to the structure and organization of the company, and the distribution of tasks within the company
- Description of measures, for example to manage risks or to prevent fraud and money laundering
- Description of how certain IT issues are implemented, such as access to sensitive data and ensuring operational stability
- Various formal information, for example on the reliability of the management and the reliability of the owners
In addition to licensing topics, young institutions typically face questions regarding ongoing compliance with regulatory requirements, such as those relating to finance, risk management, and controlling or supervisory reporting. These requirements are very individualized, depending on the type of institution, because these requirements at the various European and national levels are sometimes in need of interpretation and/or contradictory.
In addition, questions of supervisory expectations regarding compliance, operations and IT often need to be clarified. These expectations are not always fully transparent, and this creates a need for discussion, particularly in the run-up to supervisory appointments or regular on-site inspections.
There are two main points to consider here: The first point is that supervisory expectations change over time and with the corresponding growth of young companies. The second is that increasing internationalization is creating further challenges due to the cross-border offerings of products and services.
From the preparation, monitoring and follow-up of supervisory audits, we know the expectations of the supervisors with regard to compliance with their specifications.
- Project experience from accompanying examinations (preparation, participation, follow-up)
- Experience from the processing of findings, including successful follow-up examinations
- Comprehensive catalogs of requirements, discussion guides and blueprints from a large number of projects in the field of supervisory audits
- A structured collection of audit findings (EdB audits, annual audits, §44 KWG audits) in the zeb findings database. This is continually updated.
- With the FinTech Hub our own established platform for innovators and decision makers from banks, FinTechs and VC companies
At zeb, we have many years of experience in advising institutions and implementing new regulatory requirements. In more than 300 regulatory projects, we have supported various domestic and foreign clients from conception to implementation in processes. In addition, we have worked directly with the regulatory authorities on numerous IT projects.
zeb has extensive know-how in the further development and conception of bank management at both established and young institutions. Here, too, we have supported the implementation of specific regulatory requirements in various projects—with a view, among other things, to the following:
- Compliance workflows
- Application for licenses
- Introduction of business management software (zeb.control)
- Establishment of young companies, for example in the field of reporting
- Finances from the technical concept through to implementation