Most of the paper is about the risks to incumbent banks, payment institutions and electronic money institutions from fintech, including the potential impact on credit risks, operational risks, competitive pressures, business models, AML and even resolution. This is a useful checklist for supervisors.
A second part of the paper discusses consumer protection issues arising from new products or new ways of distributing products and services.
A third part of the paper considers the regulation of new fintech firms. As with consumer protection issues, the underlying assumptions here focus on level playing fields, risks of regulatory arbitrage and achieving harmonisation across the EU, all of which skew the discussion towards more regulation.
To discuss this further, please contact a member of the EMA Financial Services Risk & Regulatory Insight Centre.