Rearranging the banks

In his new book “Digital Human“, Chris Skinner sets out a straightforward vision of the bank of the future. He says (I paraphrase slightly) that the back office is about analytics, the middle office is about APIs and the front office is moving to smart apps on smart devices. I was thinking about this in an open banking context, and it gave me an idea for a useful way to help people think about the impending change in retail financial services in general and retail banking in particular. Let’s start from the traditional manufacturing/distribution model of retail banking that we are all familiar with and remember the broad economics of that model. On a global basis (these are the McKinsey version of the figures, but others are similar), it is distribution that takes the lion’s share of the profits and makes the better return on equity (ROE).

Dynamics of Open Banking

So now let’s rebuild that model for an open banking world using Chris’ back, middle and front office structure and think about the key technologies that will be transforming the businesses. I’ve invented the word “packaging” to describe the additional essential process that is needed to complete what we call the “Amazonisation” of banking, whereby products are manufactured as API services and distributed throughout the consumption of API services. This gives the three part model that Chris describes a practical technological backbone to make it work. 

Front, Middle and Back Office

What we don’t know, of course, is how this model will redistribute ROE. How will banks and “challenger banks” (we prefer the term “niche banks”), non-banks and neo-banks respond to the split of manufacturing and distribution that the new “packaging” layer (again, not sure if that’s the right term, I just couldn’t think of a better one) brings? That’s obviously a key question and one that is pretty important for organisations who are planning any kind of strategy around financial services in general or payments in particular. Since this includes many of our clients, we spend a lot of time thinking about this and the connection between technological choices that are being made now and the long-term strategic options for organisations.

Consult Hyperion took part in a recent American Banker Open Banking “Bootcamp” (a two-part webinar) on the topic. My colleague Tim Richards and I were able to explore some of our ideas and draw on some of our practical experiences with bankers, suppliers and other practitioners. It was fun to take part in it and we really enjoyed it because we were able to learn as well as to share. I mention that webinar here because as part of the bootcamp, Mark Curran from CYBG (The Clydesdale Bank, Yorkshire Bank, “B” Bank Group and now also Virgin Money) set out a very clear high level view of the three strategic options available to retail. We think it’s useful to share them here: the “traditional” bank, the banks as a platform (think Starling) and the bank as an aggregator (think HSBC and Citi).

Basic Bank Responses to Open Banking

If, as many people think, it turns out that ROE will remain higher in distribution then the commoditisation of the manufacturing function (as it turns into a “utility”) may well threaten some of the incumbents, because they will not be able to adjust the economics of their manufacturing operation quickly enough to stay in business! This may sound like a radical prediction, but it really is not.

The reality for many banks will, of course, be more of a mixture of these approaches, but you can see the point. The decoupling of the manufacturing and distribution means that banks will have to make some important decisions about where to play, and soon. We’ve already seen how some banks (eg, HSBC) have moved to exploit the aggregator strategy and how some banks (eg, Starling) have moved to become platforms with rich app stores. But what we think may be under-appreciated is the extent to which the traditional bank can develop the packaging process not to shift to one of these strategies but to make itself more efficient and to improve the time-to-market for new products and services while keeping the costs of IT infrastructure under control.

In other words, it makes sense for banks to amazonise themselves.

Me, Vanessa and crossing the streams

The UK’s Competition and Markets Authority (CMA) has published its report on the retail banking market. It says, that “the timely development and implementation of an open API banking standard has the greatest potential to transform competition in retail banking markets”. I can’t say that I read all 766 pages, but given that I think that account switching is waste of time and money, this did strike me as the most important “remedy” (as they call it) in the report.

One of the CMA’s key measures is to make high-street banks adopt a digital standard called “open banking” by 2018.

From Competition watchdog’s high-street banking probe disappoints —

By 2018? I can hear your jaws hitting the floor from here. That’s 15 months from now, which is a dog decade but a core banking weekend. 2018?? This is correct. I heard the chap from the CMA talk about this on Radio 4. I got to talk about it on Radio 2 because I’m all about the mass market and the man using the Clapham ISP.

Vanessa discusses the Open Banking Programme, witnessing the birth of a sibling, life after the London riots and the man who buried himself underground for three days.

From BBC Radio 2 – Jeremy Vine, Open Banking and London Riots

I was in the first segment, about Open Banking. The second segment, about a celebrity chef’s wife giving birth made me feel sick and so I didn’t listen to the last segment about riots. Anyway, on Radio 4, the head of the CMA was saying (and I’m paraphrasing from memory) that consumers will be able to use a currently non-existent mobile phone app to connect with a currently non-existent interface at their bank according to some currently non-existent standards in order to get recommendations from some currently non-existent big data cloud thingies that will slurp up currently non-existent standard format bank transaction data and analyse it to suggest a more cost-effective current account. By 2018.

I think that in order to understand what might actually happen on the ground in the UK, you need to imagine what will happen at the crossing of three streams.

The first stream is the PSD2 provisions for APIs access to payment accounts. As you may recall, these include a set of proposals that are due to come into force in 2018. A group of those proposals are what we in the business call “XS2A”, the proposals which force banks to open up the aforementioned APIs to permit the initiation of credit transfer (“push payments”) and account information queries. Even at a pure compliance level these PSD2 regulations pose significant questions for the structure of the existing payments industry. Straight off, an open payment API allows a third-party – let’s say a giant internet retailer at a browser near you – to ask consumers if they’d mind permitting direct account access for payment. It won’t be too hard for these organisations to find some incentive for customers to do this and once permission is granted then the third-parties can bypass existing card schemes and push payments directly to their own accounts. Meanwhile the account information API allows third-parties to aggregate consumer financial data and provide consumers with direct money management services. It’s not hard to imagine that these services will be able to disintermediate existing financial services providers to identify consumer requirements and directly offer them additional products such as loans and mortgages.

This, you might think, could be a bit worrying for banks and payment schemes – and you’d be correct. Unless they take action the banks will see their customers intercepted and a great deal of their cross-selling opportunities will disappear. End of the world stuff? No. Generally speaking these changes (which are all about more competition) are good for the banking industry and for end consumers, and it doesn’t have to be carnage among the existing incumbents, if they’re smart enough to embrace the opportunity. One way of thinking about this change is that it breaks up existing payment workflows. No longer is a payment simply a request in and a response out; now bits of the internal payment workflow – authentication, risk management, authorisation, tokenisation, rewards programs, key management, etc, etc – can be externalised through APIs. And one thing we know about APIs is that when they’re made available the generations of smart developers out there can do things we can’t even imagine, let alone build. The roadmap to the PSD2 APIs is in the hands of the European Banking Association (EBA) which has been tasked with developing the Regulatory Technical Standards (RTSs) for that access. They have just published the RTS on strong authentication, which you might see as a prerequisite to practical API use.

As expected, the RTS do not provide us with technical specifications that one can actually implement. Additional work by ‘the industry’ is required

From EBA RTS: Three key business implications for bank decision makers

So, as our good friends at Innopay note here, RTSs are not really technical, and for that matter they’re not really standards in the sense that I would mean either, but suffice to say that there is a framework for open banking coming together at the European level.

DCSI Schematic v2

The second stream is Her Majesty’s Treasury’s push for more competition in retail banking. This led to the creation of the Open Banking Working Group (OBWG), which published its report earlier this year.  Right underneath the heading “Open Banking Standard”, the document says that its goal “in publishing this Framework today is to enable the accelerated building of an Open Banking Standard in the UK”. So it’s not really standard either. I thought the document might set out some actual APIs (preferably in line with the EBA RTS) so that that both banks, fintechs, regulators and entrepreneurs could plan new products and services but the truth is it reflects the political realities of the pending complex “settlement” between banks, the regulators and others.

I’m not that interested in open data (e.g., ATM locations) and not that excited by being able to download my bank account as a spreadsheet that I can upload it to Money Supermarket . What I’m interested in is transactions and transaction data, especially through the more transactional APIs envisaged under PSD2. It would be crazy for banks to have to implement multiple infrastructures, so it’s logical to create an infrastructure for OBWG access to customer transaction data that can also be used for XS2A transaction initiation and account information services. Despite the title, then, the OBWG report is a holding document, setting us on a path to allowing access to the open data held by banks while leaving proprietary data alone. Now, let me stress that I was not party to any of the discussions, and I am not breaking any confidences by saying this, but I imagine the discussions about what data the banks consider “proprietary” and what data the banks consider “open” must have been rather convoluted. But let’s move on and assume that my transactions are considered open data and that I want to share them with third-party service providers. Since the report did contain any APIs or even a framework for APIs, we can’t use it to start planning services right now, but we can focus on the positives and look at what the document did.. What it did set out was a four part framework, comprising:

  • A data model (so that everyone knows what “account”, “amount”, “account holder” etc means);
  • An API standard.
  • A security standard.
  • A governance model.

None of these currently exist, so they need to be created. If we focus on the APIs, the document does say that, as I have noted, that because of PSD2 (and the General Data Protection Regulation, GDPR), many of the APIs will need to be built anyway. Hence co-ordinating the APIs will be a near-term priority. 

The third stream is the CMA report that triggered this blog post. This envisages APIs to improve competition in retail banking by focusing on the use of APIs to obtain access to personal data that can be shared with third-parties to obtain better, more cost-effective services. Hence the comments about the mobile app that will get you a better current account. Now, I identity these APIs as being congruent with, if not actually being the same as, the PSD2 AISPs. So if we gather to together these streams and try to integrate a picture of where we might go next, and we draw the mandatory consultant’s 2×2 matrix to hep us think through the possibilities, I think we end up with a rather interesting and useful way of thinking about the cross of the three streams. I’m particularly drawn to it because it gives me a way to locate the digital identity APIs that I think are so crucial to the future of banking.


I think this is a useful diagram. The Digital Identity APIs will not be mandatory, but they may be the key way for banks to stay in the loop in the new economy as the mandatory APIs allow banking services to be provided by third parties. Interesting, and I’d appreciate your view on this. Anyway, there’s one obvious point to mention here and that’s security. Since banks do not currently offer these APIs and they are going to have to knock them up pronto, the potential for error is vast. Yet banks simply cannot take any risks with these interfaces.

APIs (application protocol interfaces), which are a major cornerstone of the CMA’s plan for banks to share consumer data, can also provide an easy route for attackers if not properly secure.

From Funny story, this.’s ‘open banking app revolution’. Security experts not a fan of it • The Register

Word. But since neither the APIs, nor the security architecture, nor the practices, procedures and audit mechanism have been defined, it is simply impossible to say whether the UK OBWG implementation is secure or not. Hence I suspect that the way forward for most banks will be to expose a limited set of APIs to begin with by focusing on a manageable customer segment (not the general public) and then get working on stress testing and penetration testing. In fact, some banks have already begun to experiment in this area.

Wells’ tiptoeing into open APIs by offering them to commercial customers is typical of banks, which see such clients as the test case. Consumer applications hold the greater opportunity, but also carry more risk given cybersecurity and data issues.

From The Drumbeat for Open APIs Is Getting Louder | American Banker

I can tell you from personal experience (Consult Hyperion runs a very big penetration testing programme for one of the world’s biggest banks) that it takes a fair amount of time and money to get these kind of interfaces to the point where they can be exposed to the public, hence I am somewhat sceptical that they will be ready for action a mere 15 months from now.

Payment competition and banking in a post-PSD2 world

I happened to be talking about access to payment infrastructure (something I blogged yesterday) at a client event yesterday, and got involved in a discussion about how the fintechs might begin to work with banks in the new world of PSD2 and mandatory APIs. This has been subject of great interest to me at the recent Money 2020 Europe (with top, top players like Shamir Karkal from BBVA and Alex Mifsud from Ixaris explaining why the move to APIs will mean a big shift in the delivery of banking services) and other recent events. Generally speaking, and this is a sweeping generalisation, I think there has been a shift in European bank thinking in recent times. They well understand that if they do nothing, then in the instant payments, API-centric, PSD2 world they stand to lose significant income. The outsourcing company Accenture, for example…

estimates that the new new breed of payment initiation service providers will erode 33% of online debit card transaction volumes and 10% of online credit card transaction volumes resulting in a total market share of 16% of online retail payment volume by 2020.

From Banks set to lose 43% of retail payments revenue under PSD2

So the Payment Initiation Service Providers (PISPs) stand to capitalise on the new arrangements (if the banks do nothing, of course). What kind of services might they provide? Well, an obvious example is integration with social media. If you look at the use of instant payment “overlay services” (as they call them down under) in the UK (PingIt and PayM) it is far less than the use of, for example, Venmo in the USA. And Venmo doesn’t deliver immediate settlement (it works through the debit card networks). In the last quarter of 2015, Venmo transferred $2.5 billion. In January 2016 alone it transferred $1 billion. So why is it so popular? It’s the integration with social media. Just over half the users are 18-24 and half the payments relate to food and drink sharing! On a US college campus, “I’ll Venmo you” has entered the lexicon. In the UK, “I’ll PingIt you” has not. Paym is growing steadily, but it is still only transferring about £12 million per month.

Venmo 1Q16

So now imagine, post-PSD2, a combination of the immediate availability of funds like PingIt and Paym with the social media integration of Venmo. It will be a wholly different payment experience. I’ll give you an obvious example. My wife and some of her friends are planning a weekend break in August. They do this through a Facebook chat group. But when it comes to settling up for hotels and air fares, everyone has to log out, e-mail everyone for their bank details and log in to home banking and set them up as payees, then make the payments. Then everyone else has to log in to their bank accounts to see if the money has arrived and that it is the right amount. In 2018, however, it will all be different. Facebook will be integrated with instant payments through APIs so that it can function as a PISP. When my wife gets a message to say that she owes her friend £100 for her air ticket, or £25 for her share of the dinner, or £10 for the tickets to a show, then she will put money into her return message just as she adds emoticons today. Under the hood, Facebook (which of course knows the bank account of the person you are sending a message to) will initiate an instant payment and within a second or so her friend will get a message to tell that the money has arrived. Remember, Facebook already do this is in the US through debit cards (like Venmo).

It’s not all about payments though. The other category of organisation with direct access to the bank account, the Account Initiation Service Providers (AISPs) also stand to benefit from bank inertia. The row about “screen scraping” in the US adumbrates similar pressure for bank strategies in Europe.

JP Morgan Chase CEO Jamie Dimon is incensed about fintech startups like Mint, Acorn and Bloom “scraping” his customers’ data

From Banking App Competition; Why OTT “Skinny Bundles” Fail | AdExchanger

I’m sure his experienced strategists will be quick to reassure him that third-party access to bank accounts (the data is the customers, not the banks, of course) ought to be seen to be an opportunity for JP Morgan Chase to develop some terrific new products and services. The reason why customers of JP Morgan Chase use Mint is because JP Morgan Chase do not provide a suitable, better product for them to use instead. Mr. Dimon, as a champion of free enterprise, would surely object to organisations building walled gardens and using regulatory barriers to defend them. If Facebook or Amazon provide a better financial services app for customers to manage their JP Morgan Chase accounts, then good for them.

In fact, it seems to me, that this is a very likely outcome of rational market evolution. I buy my electricity from whichever supplier offers the best deal for our household. When I change suppliers, I don’t need to change my TV. When I change banks, why should I change my digital wallet if I don’t want to? With a standard API, might personal finance management (PFM) app and my wallet app and my social networks will all access my bank account, whatever my bank. And if I change banks, whatever.

So… what makes sense for banks? Why bother making the wallet or PFM apps? Why not instead provide the best possible API to people who are better at making these apps. Why bother with PingIt and PayM? Why not instead provide the best possible API for PISPs to use. Why bother with fancy applications at all? Why not instead provide identification and authentication services (through APIs of course) that all of these other apps, APIs and services will depend on. After all, if I’m going to give Facebook access to my bank account then Facebook need to be pretty sure that it’s actually me and I need to be pretty sure that it’s actually Facebook. My bank is a rather obvious middleman here.

DCSI Schematic v2

All of which leads me to suspect, as I have mentioned before with tedious regularity, that the banks should focus on what the Euro Banking Association call the “non-mandatory, non-payment APIs”  (as shown above) as a basis for strategic advantage and get together to agree a digital identity infrastructure and a common set of digital identity APIs. Nothing to it, really…


The U.K.’s Faster Payments Service (FPS) has been very successful. The ability to send money from one account to another account instantly is actually quite transformational, but I still think that the full impact has yet to be felt. As we move into 2018 and the world of the newly-published Open Banking Standard, PSD2 and APIs then we will see instant payments built in to the applications that support our everyday lives. This morning when I caught the bus to work the cost of the bus ticket was charged to one of my credit cards, which meant that the bus company had to store my card information and that I had to remember the three digit code on the back of the card to complete the purchase. In the future, I will tell the bus company I want a ticket and put my thumb on the home button of my iPhone and that will be that. The money will be sent from my bank account to the bus company’s bank account with no delays, intermediaries or additional friction. As I said before, there will be a push for push.

Since it is such a big deal, it is of course important who has access to the instant payments networks. The government is very keen to see more competition in the retail payments space and for this reason it wants to facilitate access to core payment systems, such as FPS. The opening up of access has already started. You might remember that last year, access was opened up to a new kind of aggregated access layer under the “New Access Model”.

The New Access Model, first published in December 2014, sets out proposals to enable technology vendors to offer technical access to Payment Service Providers (PSPs) by adding to their existing accounting platform technology, or providing a managed solution to either a single or multiple PSPs.

From New access market for Faster Payments gains traction | Faster Payments

This new model gave technology companies with experience in payments the ability to create systems to connect directly to FPS and then offer this connection to other players. These new offerings, including VocaLink’s PayPort service, are a terrific step forward and they make it very easy for new entrants to get up and running. Earlier this year, in fact, PayPort made access for new entrants even easier through their partnership with Raphael’s Bank.

As a member of the Faster Payments Scheme, Raphaels Bank will be able to provide other payment service providers with access to the UK’s core payments infrastructure through VocaLink’s PayPort service.

From VocaLink Connect – VocaLink partners with Raphaels Bank on Faster Payments

So now, new entrants who sign for agency access with Raphaels can use PayPort to launch their services. But access may well be opened up even further. There are plenty of non-bank players out there who want to have access to the infrastructure and the UK’s Emerging Payments Association recently presented a report to arguing that, under the appropriate licence conditions, non-banks should be allowed access to instant payments infrastructure through the use of a new kind of limited pre-funded settlement account at the Bank of England. In essence, a Facebook or a Google would be allowed accounts that they would load up with a few million quid in the morning and then use throughout the day. Under this kind of option you would be able to send money from your bank account to a friend on Facebook messenger in a jiffy. Facebook and other tech players could use PayPort to connect to FPS, giving them integration and all the services they need at the drop of hat.

Tech firms are in talks with the Bank of England to secure settlement accounts, a privilege only currently on offer the banks. The accounts would help give the finance technology (fintech) firms access to the payments system, the infrastructure which currently underlies much of Britain’s financial services industry.

From Fintech firms want to open accounts at the Bank of England – Telegraph

Why am I highlighting this? Well, the interpersonal services that deliver instant payments at the moment (such as PayM, which has more than three million registered users) are just a toe in the water! Imagine what some of these new tech players will be to do with those services when they integrate them with social media, mobile apps, retail platforms, public services and other organisations and businesses. I’m looking forward to some real innovation in this space and opening up access under the right conditions will energise the whole sector and I’m going to be writing some more about this tomorrow.

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