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Parma Bains
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Nobuyasu Sugimoto
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Christopher Wilson
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VI. Annex 1: Definitions

Activity-based regulation: applied to any person or entity that engages in certain regulated activities, for example, facilitating the buying and selling of investments or operating lending activities.

BigTech: platform-based business model focused on maximizing interactions between a large number of mainly retail users. BigTechs are usually large technology conglomerates with extensive customer networks and core businesses across markets, for example, in social media, internet search, and e-commerce.

Entity-based regulation: applied to licensed entities or groups that engage in regulated activities (such as deposit taking, payment facilitation, lending, and securities issuance). Requirements are imposed at the entity level and may include governance, prudential, and conduct requirements.

Fintech: technologically enabled innovation in financial services that could result in new business models, applications, processes, or products with an associated material effect on financial markets and institutions and the provision of financial services.

Fintech start-up or Fintech-driven entity: firms that are primarily driven by technology-enabled innovation in financial services.

Home authority: the financial regulatory authority that oversees the jurisdiction where a BigTech entity has its headquarters.

Host authority: the financial regulatory authority that oversees the jurisdiction where a BigTech entity offers its services but does not house its headquarters.

Hybrid regulation: combines elements of both activity- and entity-based regulation depending on the nature of each jurisdiction’s regulatory structure and whether the jurisdiction houses the headquarters of a firm or hosts its activities.

VII. References

1

This note was prepared by Parma Bains, Nobuyasu Sugimoto and Christopher Wilson, with inputs from Fabiana Melo and Anastasiia Morozova (all MCM).

2

International Monetary Fund and The World Bank staff developed the agenda in 2018 (International Monetary Fund [IMF] and The World Bank 2018).

3

Promising work on data policy has begun (Carriere-Swallow and Haksar 2019; Haksar and others 2021).

4

The Financial Stability Board defines BigTech as “large companies with established technology platforms” (Financial Stability Board [FSB] 2019). In addition, the Financial Stability Institute has defined BigTech as “large technology companies” (Crisanto, Ehrentaud, and Fabian 2021).

5

For example, the 2021 acquisition of Pring, a Japanese payments processor, is the latest in a line of payments acquisitions, including Softcard, Zetawire, and TxVia, providing Alphabet with a stronger presence in payments networks and payments technology.

6

For further reading regarding BigTech expansion into financial services, see two publications by the FSB: BigTech in Finance: Market Developments and Potential Financial Stability Implications (FSB 2019) and BigTech Firms in Finance in Emerging Market and Developing Economies (FSB 2020).

7

For a comprehensive discussion of cloud employment in financial services, see Cloud Computer: A Vital Enabler in Times of Disruption (Pujazon and Carr 2020).

8

Some regulators are exploring interim measures to overcome the inherent limitations of the activity-based approach. For example, UK Financial Conduct Authority (FCA) conducts market studies across industry price caps, which can be an alternative to enforcement.

9

Financial Action Task Force (FATF) Recommendations, which are the international standards on AML/CFT, apply to institutions that engage in a range of activities, including deposit taking, lending, and money or value transfers. BigTechs will be captured if they carry out the covered activities. In practice, however, many jurisdictions may not yet subject BigTechs that engage in the covered activities to AML/CFT obligations due to the rapid evolvement of the sector and the business model. Such gaps may give rise to regulatory arbitrage.

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BigTech in Financial Services: Regulatory Approaches and Architecture
Author:
Parma Bains
,
Nobuyasu Sugimoto
, and
Christopher Wilson