Time was, Silicon Valley was the place to found a tech startup. British tech entrepreneurs would up sticks, move to Silicon Valley and never look back. Today, things are different. Increased competition for talent and rising real estate costs have reduced the Bay Area’s competitiveness, while the UK has developed its own tech eco-system. Lanyrd and Songkick both returned to London after graduating from Y Combinator, whereas ten years ago, they may well have opted to stay in the Bay Area.
At the same time, the cost of international air travel has declined and new technologies have emerged that make it easier for geographically-distributed teams to work together. The end result is that it’s no longer an “either/or” choice. Startups can have the best of both worlds – access to both the Silicon Valley eco-system and the UK talent pool (which, thanks to the UK’s membership of the EU, extends across 28 countries, with a combined population of over 500m).
Huddle’s senior management team moved to San Francisco but the product and technology team remains in London. David Richards, CEO of WANdisco, opted to establish dual headquarters right from the beginning:
“It’s very difficult to hire lots of java programmers in Silicon Valley,” he explains. “They cost a lot and there are companies like Google and Facebook who have significant presence in the Bay area.”
We’re also seeing US-based players starting to take notice and recognise the importance of the UK. Last year Y Combinator decided to run a Startup School in London, while Techstars expanded into the UK and is now attracting FinTech startups from the US to take part in the Barclays Accelerator.
I believe that what we’re seeing is the growth of a trans-Atlantic startup eco-system. Founders should no longer be thinking about London versus Silicon Valley – they should be thinking about how they can take advantage of the best resources, opportunities and talent in both London and Silicon Valley.
This is one of the reasons I founded LDN2SFO – I think that one of the best ways to help London-based entrepreneurs is to expose them to the Silicon Valley eco-system so they can both learn about the culture that has made it so successful, and make connections with their peers there (and, in doing so, strengthen the links between the London and Silicon Valley eco-systems).
Our next trip takes place from April 27th to May 1st. If you want to join us, apply now.
Yesterday was a significant day for FinTech in the UK. Having previously made it clear that the government wants to make London the leading location for the FinTech and digital currencies sectors, the Chancellor, George Osborne, used the Budget to lay out more details of how the government intends to achieve that.
The Government Office of Science also released its Blackett review into FinTech, and HM Treasury published both their response to the call for information on digital currencies that they launched last November, and a policy paper outlining the government’s strategy for delivering competition and choice banking.
I highlight some of the key announcements from the Budget below.
Promoting competition is one of the FCA’s three objectives (the other two are protecting consumers and protecting financial markets) and, fortunately, its leadership fully recognises both the role that innovation can play in driving competition, and the fact that regulation can be a significant barrier to innovation. Project Innovate is an initiative launched last August to help innovator companies navigate regulatory hurdles and bring new products and services to market.
One of the key challenges is that existing regulations often don’t cover emerging business models. Even when they do, startups often lack the resources to achieve full compliance. Hopefully, the FCA will be able to come up with a sandbox model that allows innovators to pilot new products, services and business models that they would otherwise struggle to bring to market.
Just as technology is transforming the way financial services are delivered to customers, it has the potential to transform the way regulation is delivered and reduce regulatory costs. By taking the lead in this area, the FCA and PRA can make the UK a more attractive regulatory regime and provide a fertile environment for UK companies to develop ‘RegTech’ products and expertise that can be exported overseas.
In Germany, the widespread adoption of the HBCI/FinTS banking API has helped foster a strong FinTech sector, spawning startups like Fidor Bank, Figo, Number26 and Avuba, as well as the Open Bank Project. If the UK banking sector can be persuaded to adopt a similar API, it can only be a positive development for UK FinTech.
The Bank of England has taken a keen interest in digital currencies and blockchain technology, and even raised the question of “Why might central banks issue digital currencies?” in a recent discussion paper. HM Treasury launched a call for information on digital currencies last November, and released a detailed response to the feedback alongside the Budget yesterday. The paragraphs below (with numbers in red) are taken from the latter document.
The government clearly perceives a significant opportunity in this space but the key challenge is to ensure consumer protection and prevent the use of digital currencies for criminal purposes (including money laundering and terrorist financing) without stifling innovation.
There’s little doubt that here in the UK, lack of regulation has hampered the digital currencies sector. Banks, having been hit with punitive fines in the past for failing to do enough to prevent money-laundering, refuse to touch anything Bitcoin-related with a 10-foot bargepole, meaning that UK companies in this space are typically forced to bank overseas (e.g. Bitstamp, Coinfloor and CEX.IO bank in Slovenia, Poland and Latvia, respectively, despite being based in the UK). Applying AML regulation to exchanges should remove this barrier to banking services and help make the UK a more attractive regulatory regime.
The next Parliament will begin in May so, with luck, we will see the result of this consultation by the end of the year.
The new Payment Systems Regulator may also have a role to play in ensuring that that digital currency businesses are not excluded from payments networks by UK banks.
BSI is the UK’s national standards body. As well as safety standards for things like crash helmets and seatbelts, it pioneered the quality assurance and information security standards which formed the basis of the ISO 9000 and ISO/IEC 27000 series, respectively.
The digital currency sector has seen its fair share of fraud, ponzi schemes and fiduciary failures, so it’s interesting to see the UK government opting against prescriptive regulation to protect consumers, in favour of giving the sector the opportunity to self-regulate. It’s very much a pro-innovation stance, and stands in marked contrast to the approach taken by the New York Department of Financial Services – it’s possible that the UK government, having seen the negative reaction to the New York Department of Financial Services first BitLicense draft, saw an opportunity to steal a march on New York (which vies with London for the title of the world’s leading financial capital).
It’s worth bearing in mind that “self-regulation” has a decidedly mixed track record in the UK, so there’s a question-mark over whether this approach will engender enough consumer confidence to support mainstream adoption. Also, the use of the phrase “at this stage” is significant.
The £10m in funding for research is a relatively small but significant indication that the government is willing to put its money where its mouth is. The Research Councils are the primary source of funding for research in the UK. The Alan Turing Institute is a newly-formed organisation intended to support research in Big Data and algorithms. Digital Catapult is an Innovate UK initiative intended to help commercialise data innovation.
Concentration of talent plays a key role in the formation of industry clusters. If the UK can attract talent to conduct research, and provide a fertile environment for commercialising the fruits of that research, it stands a very good chance of establishing a strong digital currency cluster.
FinTech is a significant contributor to the UK economy, and are are a key element of London’s role as a global financial centre. Yesterday’s announcements are a clear sign that the government is not just paying lip service when it says it wants the UK to be the best place in the world to do business in this sector.
The prospect of being formally regulated will likely prove highly attractive to companies focusing on Bitcoin and other digital currencies. It will confer legitimacy, and give both customers and investors greater confidence in the sector. Passporting will also give companies regulated in the UK the ability to offer their services across the rest of the EEA.
We’ve already seen companies like CoinJar move to the UK because of its Bitcoin-friendly tax regime. I wouldn’t be surprised if others follow in its footsteps.
During 2014, nearly 1.6m bitcoins were mined and more than 25m Bitcoin transactions were written to the Blockchain, which doubled in size, ending the year at 26.4GB. The ongoing growth in transaction volumes has led to a renewed focus on Bitcoin’s scalability issues.
During the same period, the price of Bitcoin dropped by more than 50%, causing the growth of the network’s hashrate to slow towards the end of last year, which triggered the first drop in difficulty since early 2013. Last month (coincidentally as the trial of Ross “Dread Pirate Roberts” Ulbricht got underway) the Bitcoin price dipped below $200 for the first time since November 2013, prompting some sizeable mining pools to suspend operations. The implication is that the mining hardware arms race has squeezed profit margins to the point where some miners are unprofitable when the price drops below $200 (i.e. value of the bitcoins generated by the mining hardware is less than the cost of electricity required to power it). The fact that some miners are suspending operations instead of continuing to mine and simply hanging on to the bitcoins mined until the price rises again suggests that they may lack the (fiat currency) funds to keep paying for electricity or that they’re fearful that the price won’t recover and they’ll end up permanently in the red.
For now, the question is moot, as the price has recovered to ~$225 (giving the ~14m bitcoins in circulation a total value of ~$3.15bn), but it will be interesting to see what happens if the price drops again.
In March, Newsweek relaunched their print edition in March with a cover story claiming that that they had unmasked Dorian Nakamoto as the creator of Bitcoin. The man in question denied having anything to do with Bitcoin and the real Satoshi Nakamoto surfaced online to declare: “I am not Dorian Nakamoto.”
The first really big Bitcoin bankruptcy took place in February when MtGox shut down and filed for bankruptcy, claiming that hackers had stolen 850,000 bitcoins (worth around $460m at the time) and that $28m was “missing” from its bank accounts. It later emerged that 200,000 bitcoins were found in a “forgotten” wallet and, nearly a year later, the saga has yet to be fully resolved.
Of course, MtGox wasn’t the only Bitcoin bankruptcy: Flexcoin and Bitcoin Trader shuttered after being hacked, Neo & Bee collapsed amid suspicions of fraud, and London-based MintPay and Moolah closed down after CEO “Alex Green” (subsequently revealed as an alias of Ryan Kennedy) absconded with over $1.4m worth of bitcoins.
Unfazed, VCs invested more than $300m in Bitcoin startups during 2014 and if Coinbase’s $75m round in January is anything to go by, that trend seems set to continue in 2015. It’s clear that some VCs believe that Bitcoin and the Blockchain represent a “New World”-style opportunity (similar in nature to the Internet itself back in the ’90s), and their backing of companies like Coinbase (who have announced the launch of “the first regulated bitcoin exchange based in the U.S.“) is part of a strategy to put in place the infrastructure and services necessary to support mass adoption.
Some believe that even if Bitcoin does not go mainstream, the Blockchain, secured by the Bitcoin mining network, will become the foundation for a multitude of applications and services like Blockstream, Counterparty, Factom, OneName and OpenBazaar. Overstock CEO Patrick Byrne has ambitions to build a distributed stock market on top of the Blockchain. This could result in a self-sustaining “cryptoconomy”, in which users buy bitcoins from miners, to spend on transaction fees (which go to the miners) required to write transactions to the Blockchain. The prospect of receiving those transaction fees would entice enough miners to maintain the security of the Blockchain. In other words, the intrinsic value of a bitcoin would be the ability to write to the Blockchain.
However, I think such a scenario, while possible, is unlikely. As I’ve said in the past, I doubt Bitcoin’s first-mover advantage will translate into long-term success. Webvan pioneered grocery delivery during the dot-com bubble but ultimately went bankrupt. Today, most supermarkets do deliveries, while companies like Ocado, Amazon and Instacart are resurrecting Webvan’s business model. I suspect that something similar will happen to Bitcoin and cryptocurrencies.
But it’s not happening just yet. Ripple, one of the early Bitcoin alternatives, suffered mixed fortunes in 2014. The circumstances surrounding the departure of co-founder Jed McCaleb (who had previously founded MtGox) to found Stellar, resulted in the resignation of Ripple Labs board member Jesse Powell, who highlighted the fact that Ripple’s founders hold significant amounts of the pre-mined currency. On the plus side, Ripple signed up three banks, including Fidor Bank in Germany and CBW in the US.
Other competing alternatives continue to emerge. Ethereum is intended to be a platform for smart contracts. MaidSafe is a platform for distributed storage, designed to support various applications. Storj is another distributed storage service that will compete with cloud storage services like Dropbox.
For me, the most important developments during 2014 were in the regulatory space. In the US, having warned Bitcoin exchange operators last year that they must comply with money-transmission laws, authorities began cracking down on “unlicensed money transmitters” (including BitInstant CEO Charlie Shrem and Robert “BTCKing” Faiella), as well as Bitcoin ponzi schemes and unregistered securities offerings.
In April, the IRS issued a notice indicating that virtual currencies are treated as property (as opposed to currency) for federal tax purposes and, hence, are subject to the rules pertaining to capital gains (and losses). This makes things rather complicated.
In June, New York’s Department of Financial Services (DFS) published a draft of its proposed “BitLicense” regime for regulating virtual currency companies, which attracted thousands of comments. A revised draft is expected imminently. Meanwhile, the Commodity Futures Trading Commission (CFTC) chairman declared that derivatives based on virtual currencies fall within the CFTC’s jurisdiction, and Circle (which launched its hosted Bitcoin wallet in September) was invited to join the Treasury Department’s Bank Secrecy Act Advisory Group.
On this side of the Pond, the UK’s tax authority issued guidance on the tax treatment of Bitcoin and other cryptocurrencies, and the financial regulator issued a Call for Information on Digital Currencies. Offshore, the Isle of Man government announced that it’s planning to create a regulatory regime that covers virtual currencies as part of a strategy to attract Bitcoin companies to the island.
Needless to say, the prospect of increased (or, rather, any) regulation of Bitcoin is not universally welcomed but it’s actually a critical step in laying the foundations for wider adoption of cryptocurrencies and related technologies. For example, there are doubts over Bitstamp’s solvency and security after it was hacked at the beginning of the year. If Bitcoin exchanges become regulated by something like the New York BitLicense (or, in Europe, in a manner similar to payments institutions, with appropriate measures for audit, security and segregation of client funds), it would go a long way to assuaging such concerns (not to mention make it easier for companies dealing in Bitcoin to get access to banking services).
In fact, I wouldn’t be surprised if 2015 is the year that being regulated becomes a competitive advantage for companies operating in the cryptocurrency space.
Last week, New York Attorney General Eric Schneiderman announced a lawsuit against Barclays, alleging that the company had led clients to believe that the Barclays LX dark pool was a safe place to go swimming when, in fact, it was teeming with bloodthirsty, man-eating sharks (or “predatory high-frequency traders”, as A.G. Schneiderman put it).
The bombastic language (the word “toxic” appears in the complaint 24 times, one more than “predatory” but well behind the 41 mentions of “aggressive”) masks the fact that the underlying allegation at the heart of the lawsuit is that Barclays “misrepresented” the extent to which participants in Barclays LX were protected from “aggressive” HFT firms.
“Misrepresented” might not sound particularly bad. A.G. Schneiderman presents no proof that Barclays intended to defraud its clients or that clients suffered any losses as a result of Barclays’ misrepresentation. In fact, he doesn’t even accuse Barclays of lying. However, he doesn’t need to because he’s using the Martin Act, a 93 year old state law that redefines securities fraud using a far wider definition than federal securities laws, removing any need to prove intent to defraud or even that fraud took place. The Act gives the New York attorney general broad powers to investigate potential violations. According to Nicholas Thompson, writing in Legal Affairs:
The purpose of the Martin Act is to arm the New York attorney general to combat financial fraud. It empowers him to subpoena any document he wants from anyone doing business in the state; to keep an investigation totally secret or to make it totally public; and to choose between filing civil or criminal charges whenever he wants. People called in for questioning during Martin Act investigations do not have a right to counsel or a right against self-incrimination. Combined, the act’s powers exceed those given any regulator in any other state.
In the wake of the dot-com crash, Eliot Spitzer used the Martin Act to subpoena Henry Blodget’s emails from Merrill Lynch and went on to extract a total of $1.4bn in settlements from Merrill and nine other Wall Street firms that had over-hyped Internet stocks. Other firms that have fallen foul of the Act include AIG, JP Morgan, Bank of New York Mellon and Ernst & Young.
Barclays is unlikely to put up much of a fight. Schneiderman’s announcement seems to have been timed to coincide with the two-year anniversary of Barclays’ settlements with British and American regulators over its role in the LIBOR scandal (which led to the resignations of both the Chairman and CEO), and comes barely a month after the company was fined by the FCA for failing to adequately manage conflicts of interest in relation to the London Gold Fixing.
Among the evidence presented by Schneiderman is a chart, taken from a Barclays marketing brochure, which claims to show the results of an analysis of the trading behaviours of participants in the Barclays LX pool (see right).
To quote the complaint:
36. Each circle in the chart represents one firm trading in Barclays’ dark pool. The size of the circle corresponds to the level of trading activity conducted in the dark pool by that firm. Different types of traders are assigned different color circles; the pale green circles are “electronic liquidity providers” (“ELP”), which is the term Barclays used for high frequency traders. Within the chart are two color-coded regions, a green rectangle representing “passive” (i.e., safe, non-predatory) trading activity, and a red rectangle representing “aggressive” (i.e., predatory) trading. The x-axis, (“modified take percentage,” which is percentage of a trader’s orders that take liquidity), and the y-axis, (“1-second alpha,” which is the price movement in the one-second following each trader’s trades), are presented here as relevant measures of trading behavior on the dark pool.
37. The chart represents that very little of the trading in Barclays’ dark pool is “aggressive.” As represented by the chart, most of the trading in the dark pool is “passive,” and most of the ELP/high frequency activity is “passive.” In its entirety, the chart represents that Barclays’ dark pool is a safe venue with few aggressive traders.
38. Barclays’ sales staff heavily promoted this analysis to investors as a representation of the trading within the dark pool, and marketed that analysis as “a snapshot of the participants” in order to show clients “an accurate view of our pool.” In addition, certain Barclays marketing materials appended a notation to the chart explaining that it portrays the top 100 clients trading in the dark pool.
39. These representations were false. The chart and accompanying statements misrepresented the trading taking place in Barclays’ dark pool. That is because senior Barclays personnel de-emphasized the presence of high frequency traders in the pool, and removed from the analysis one of the largest and most toxic participants in Barclays’ dark pool.
Later in the complaint, the missing participant is identified as Tradebot Systems, a HFT firm. What’s missing from the complaint, however, is the original chart, showing Tradebot. I got curious, did some digging and turned up what I believe to be the original chart.
The 2012 chart clearly shows a large circle (marked X) representing a market participant whose size and position matches the complaint’s description of Tradebot as “the largest participant in Barclays’ dark pool, with an established history of trading activity that was known to Barclays as toxic.”
In the graph from Schneiderman’s complaint, the circle representing Tradebot appears to have shrunk and migrated to the left. You may also notice that a small purple (Internal) circle on the far right of the right-hand chart has been re-coloured blue (Institutional) on the left-hand chart.
According to emails quoted in the complaint (which appears to be largely based on the testimony of a whistleblower), Barclays justification for altering the chart is that it was intended to be a demonstration of Barclays’ ability to monitor and classify trading activity in the dark pool, rather than an accurate representation of the trading activity. Of course, it may yet emerge that the change reflected a real change in the nature of Tradebot’s trading (perhaps after having been challenged by Barclays) but, if that were the case, I would expect the rest of the chart to be updated as well..
A good rule of thumb when considering whether an action or behaviour is appropriate or not, is to imagine what would happen if it were observed by a tabloid journalist. If the journalist could come up with a headline and story that would be embarrassing to the firm, you need to rethink. With the current press focus on financial services, it’s not just enough to avoid breaking the law – banks must be whiter than white.
The whole incident is a setback to Barclays CEO Antony Jenkins’ mission to rebuild the bank’s reputation in the aftermath of the LIBOR scandal. The independent Salz_Review of Barclays after the LIBOR scandal found that there were “cultural shortcomings” and said that the bank needed to undergo “transformational change”.
Bringing about cultural change within financial services firms isn’t easy. Once a culture is established, it becomes self-reinforcing. Those who don’t conform get forced out. For the CEO, talking the talk – even walking the walk – is unlikely to be enough. Culture derives from people, and the processes and structures they form. Changing an organisation’s culture may well require disrupting the organisation first – replacing people, getting rid of the old ways of doing things, and ripping out old power structures, to make space for new ways of doing things. It’s not the sort of thing a CEO can direct from on high – he needs to roll his sleeves up and get his hands dirty.
It’ll be disruptive, it’s be distracting and it’s be very expensive (both in direct costs and revenue opportunities that are missed during the disruption) but it’s what Antony Jenkins will need to do if he wants to bring about the transformational change Barclays needs.
Jack, it was absolutely thrilling to read your blog. Your blog and the – out of that – resulting discussion I really find unique. I am happy to participate in that particular discussion, because we build a real disruptive bank that corresponds with your criterias. The name of that Bank: FIDOR Bank.
How do I come to that bold opinion? Best proof would be to apply your criterias. So, lets see:
1. We are a real bank. We received banking license from the German banking regulators. That was in May 2009, so exactly in the eye of the crisis-storm and this as an entrepreneurial and independent team. No big banking group supporting (or blocking) us. We started business in Jan 2010 with a very rudimental offer.
2. From the start, our concept was designed exclusively for the digital market. By doing so, we focus on the main driver like Web 2.0, e-commerce, gamification and everything that comes around the mobile internet. We see absolutely no sense in a banking-branch, regardless of which bank. A branch is inferior to the Internet in all respects! For this I have also written a blog – but is currently available only in German. Sorry. Must translate that… Nevertheless, here is the link.
3. We have clearly opted for a banking license, because we had from the beginning on the opinion that one must have this license if you want to come to the core of a product and if you want to offer real innovation. The golden rule is simple: “Who wants to hijack a plane, should better sit in it.” (I am not saying, somebody should hijack a plane!!!! ;-))
4. If you hold no banking license, you only can focus on a (wonderful ) UX. That is it. Financial-Products and services are the ones which are made possible by the back-office bank and its core banking system. Not more.
5. We decided from the beginning to build our own middleware, because there was no suitable offer in the market. This is what we now call “Fidor operating system”. Out of that, Fidor TecS AG (a 100% subsidiary to the bank) as a company emerged. We see this fOS as the central tool to generate customer loyalty and stickyness. Our experience: If you work in the context of a concept that has the digital target customers (retail and SMEs) in its center and is not having its own technological expertise, you are lost.
6. Very Important: fOS is an “open” System. Via standard interfaces we integrate 3rd party offerings into our account. The result is as easy as compelling: A normal account has 3 functions: money in – money stays – money out. Fidor Smart Cash Account (as we call it) has already around 20 functions: In addition to the aforementioned , the customer may purchase foreign currencies and sell them and send them, also buy precious metals and sell and ship digitally, can order a mini credit via mobile app (we call it cash emergency) with an instant pay out even on a Sunday (our answer to wonga), can apply for an overdraft online and open it in seconds, can define saving certificates, may invest and participate in Crowd Finance as well as execute peer to peer lending , can use “social brokerage” offers, manage your card transactions in the same transactions-list like all your other transactions, and much much more. Not to forget, that we can integrate digital currencies into our account. Of course. That’s also the reason, why we are the only bank cooperating with two very active bitcoin exchanges. All that is creating a higher Customer engagement, a higher customer cross selling ratio and by that a higher customer life time value.
7. Yes, all that sounds like a complex account. But – in future – the customer can define his/her own account, like we do it today with our smart phone. That’s why we call it a Smart Cash Account. By defining your own complexity in that account, we integrate again the customer.
8. In addition, we operate a community, in which users can ask each other questions and give answers. Here you can rate products and consultants/advisors of all banks as well as you may wish to create products. Or you want to support other users by giving advice how to cut cost of living. Also you can compare your own financial profiles – of course anonymously. Naturally, we are active on all other social media channels and try to integrate the customer into the product also there. One example is our overdraft interest rate, that is driven by the numbers of Likes we have on Facebook. Easy rule: The more likes we receive, the lower the interest rate on the overdraft.
9. After establishing the first Fidor Hub in Germany, we now roll out internationally. We started in Germany, we now have a Russian franchise and we will come to market in the UK in the near future. 2015 it will go on like this, because Fidor has developed an international franchise concept.
10. In addition, one must see that we will connect these local franchise hubs in order to allow cost-effective real-time transactions between these local hubs then. Thats gonna be really cool and we will publish a press-release regarding a cooperation with a real disruptive partner in that segment in the near future.
And how do we manage all this? Well, we are currently a team of around 70 employees, unified by one mutual and super-important pre-condition: We have the right culture , the right spirit. Culture is therefore in a way more important than maybe the technology itself.
Did I forget something? Certainly …. yes. But, Jack, most important to me: you can tell Marc Andreesen and Chris Dixon that there is a really disruptive bank! That would be my only request… and wish ;-)) If I may be that open and frank.
Rather than reinvent the wheel, I’ve put together some key quotes from – and links to – relevant articles by people who are far more knowledgable and qualified about the topic than I.
A while back, I got into a to-and-fro on Twitter with Marc Andreessen and Chris Dixon about banking, which garnered a fair amount of interest and commentary1234, after Marc declared that he is “dying to fund a disruptive bank“.
So far, finance startups have shied away getting their own banking licence, opting to use an existing bank instead. Movenbank and BankSimple talked up their plans to shake up banking but, in the end, both dropped “bank” from their name and partnered with CBW Bank and Bancorp respectively (Simple was subsequently acquired by BBVA). In effect, they built a presentation layer on top of an existing bank. I don’t think that’s the path to the future of banking. Even if you ignore the downsides of building a business on someone else’s platform, I believe that you can’t be truly disruptive unless you build the full stack.
A bank can be broken down into two distinct businesses. The first is the infrastructure required to offer banking services: the banking licence or charter, branches and call centres (increasingly optional), IT systems, ATMs, AML and KYC procedures, connections to domestic inter-bank networks and SWIFT, the ability to issue credit and debit cards, etc. Some of these are revenue-generating (e.g. fees on SWIFT transfers, payment card interchange fees) but, traditionally, retail banks have offered “free” banking to attract customers so that the second business can offer them financial products like credit, overdrafts, loans, savings, investments, pensions, foreign exchange and insurance. This second business has attracted plenty of competition (including startups like Wonga, FundingCircle and TransferWise), but there appears to be little appetite for investing in the infrastructure required to become an actual bank.
The last company to do so in the UK was Metro Bank, which launched in 2010 (the first new high street bank to do so in 150 years) but has failed to make a make a significant impact on the incumbents’ market share (the top four UK banking groups have 70% of the market for personal current accounts5) and is yet to achieve profitability, having racked up over £150m in cumulative losses. With hindsight, part of the reason for Metro’s slow progress is the fact that, rather than trying to disrupt the market, it challenged the incumbents on their own turf by opening high street branches (26 so far, at a cost of over £2m each) and sought to compete on customer service (e.g. Sunday opening and welcoming customers’ pets into branches). Notably, it did not attempt to differentiate itself through technology, opting instead to outsource its IT to Swiss banking systems provider Temenos.
I believe that the technology platform can provide a strategic competitive advantage. As I’ve written before, the lack of competition in the UK market bred complacency and resulted in a failure to innovate and invest in technology (banks are notoriously reluctant to invest in something that doesn’t generate revenue unless it’s mandated by the regulators). As a result, the incumbents’ core banking systems are monolithic, clunky and ill-suited for supporting the kind of services that are made possible by modern consumer technology and connectivity.
The ability to offer those kind of services would be a key differentiating factor but would require that the new bank build its own platform. I imagine it will look something like this:
A core banking engine, with integrated CRM functionality, wrapped in an API/service layer supporting online banking, and both in-house and 3rd party apps (e.g. personal finance managers, business accounting packages). Building a new engine from scratch, rather than using an off-the-shelf product, will allow the new bank to incorporate new features and functionality, like allowing customers to control which apps have access to their account (in a manner similar to the way Twitter lets you control which apps have access to your Twitter account) and set up IFTTT-style triggers. A modern platform will also make it easy to integrate with new financial networks.
Certain traditional banking services are prerequisites, such as payment cards, access to withdraw cash from ATMs and the ability to send and receive bank transfers both domestically and internationally. However, note the absence of any mention of branches, cheques or accepting cash deposits – all services that are expensive to provide and whose usage is declining precipitously.
Commoditised products like foreign exchange, credit and deposits are a competitive market and it’s easy for customers to access competitors’ product offerings, so it would make sense to create a marketplace where customers can get direct access to 3rd party products as well as those offered by the in-house Treasury product teams. In fact, providing a banking platform-as-a-service and white label services to other financial startups could generate significant revenues.
Efforts by UK regulators to foster competition in the banking market by encouraging more new entrants mean that now is probably the perfect time to launch a bank like this in the UK. In fact, last week brought the news that one of the co-founders of Metro Bank has teamed up with the former chief executive of First Direct (HSBC’s online and phone banking brand) to launch “the UK’s first truly digital bank“, although they appear to be following in Metro Bank’s footsteps by outsourcing the technology platform to Fiserv, a US financial technology provider.
The UK is arguably the best location for a disruptive bank to launch, with a financial technology talent pool that is probably the best in the world, and a sizeable addressable market that’s ripe for disruption. Once established in the UK market, a new bank will be well-positioned to take advantage of the single European market for financial services to expand throughout the EU and, with a tried and tested technology platform, it should be easy to attract the investment required to launch in the US.
The potential rewards are huge but so is the investment needed. Building a new technology platform and putting in place the support structures required is a major undertaking, not to mention the marketing spend that would be required to go mass market. VCs have become used to backing small teams of young technologists who build and launch a business over the course of a three month accelerator programme, or providing growth capital to companies that are scaling a proven business model. Whether they have the risk appetite for a disruptive bank remains to be seen.
- VCs Start Pining to Own a Bank at bankinnovation.net
- To disrupt banking, do you need to own the bank? at qz.com
- Financial interaction: the next generation by Roger Ehrenberg
- If you think ‘rip out and replace our systems’ is naive … think again at thefinanser.co.uk
- Calculated from the 75% quoted by the OFT in their January 2013 Review of the personal current account market less TSB’s 4.3% share after being spun out of Lloyds