The European Association of Co-operative Banks (EACB) welcomes the opportunity to provide the EBA with its comments on the EBA Discussion Paper on its Approach to FinTech.
EACB members appreciate the EBA’s FinTech mapping exercise, which is one of a kind. We also appreciate the fact that the EBA acknowledges that the use of technologies by financial services firms is not new per se. Financial services firms have long implemented internal technological solutions to support the provision of services to their customers and to ensure that they comply with their regulatory obligations.
As a general comment and with regard to the issues and way forward identified by the EBA in its Discussion Paper, we think that they are relevant and comprehensive.
EACB members, in particular, support the EBA’s intention to further analyse national regulatory regimes as differences could potentially lead to level playing field issues and forum shopping. A level playing field is key to assure not only fair competition but also consumer protection. The latter should remain the key priority. A level playing field has the role of ensuring consumers are not put at risk and that financial stability is maintained, irrespective of the service provider. The same regulatory conditions and supervision should apply to all actors who seek to innovate and compete on FinTech: large digital players (big tech firms), financial institution players (incumbent banks) and FinTech start-ups players. The principle of ‘same services, same risks, same rules and same supervision’ in order to ensure consumer protection and market integrity should always apply.