A new era of Banking has begun

A decade or two from today, we might look back at the 13th January 2018 as a date of historical significance for financial institutions across Europe. Payment Services Directive 2 (PSD2) is in effect from today. Also, the UK Open Banking is in force for the top 9 banks across UK and Ireland. For once, ‘exciting’, ‘innovative’ and ‘financial regulations’ can be used in the same sentence. These regulatory changes will create a transparent and open market to foster innovation, put the end-user/ the account holder in control of how they want to use some of the banking services.

In a nutshell, under the PSD2 provision, a bank account holder can allow a third-party-provider (TPP) to:

  • Access their account information and transactional data (things we see on our bank statement)
  • Authorise and initiate payments from a bank account without using long card numbers or issuing schemes. For example, in an ecommerce transaction, there will be a choice to ‘pay direct’ in addition to credit/ debit card.

Financial institutions are having to open up their core systems of record and platforms to the regulated TPPs (but potentially unknown and untrusted by the institution) and treat them without any discrimination. TPPs do not need to enter any contractual relationship with the bank and they can access these systems – most likely via APIs (application programming interface) at no cost. They do, however, need to be fully authorised by the regulator for the services they want to provide in their respective markets. A bank can also play the role of a TPP as well.

With all the changes happening, I thought it might be fun to explore what a TPP can really do with the data. What the art of the possible might look like and, as a result, how the industry might evolve. In pursuit of this goal, I took my own banking data and performed very rudimentary analysis. I am not a data scientist by any stretch of the imagination but here are the dots I joined and conclusions I drew based on very limited data I had access to.

Types of transactions

  • Scheduled and Regular Payments via standing orders and direct debits
  • Regular but unscheduled payments. For example, meals I might buy at or near work on a weekday
  • Irregular payments. This includes impulse purchases, holidays etc.

Transactional data

Payment Type Metadata Inferred Data
Scheduled and regular Payments · Utility payments

· Mortgage or rent

· Weekly shops in supermarkets

· Transfers into other saving or current bank accounts

· Income and sources

· Number of bank accounts held

· Other Banks and Financial Institutions I have accounts with

· Number of standing orders and direct debits

· Any charges paid on the account either in form of product fees and charges

· Types of savings I have (ISAs, Savings account, pensions etc.)

· Other properties held

· If I am an employee or a business owner

· Employer’s names and locations

· Shopping habits including locations, shops/ brand-affinity, online/ offline

· Utility and service providers and the specific utility plans/ products I have subscribed to

· Size of the house

· Specific products purchased or subscribed to e.g. Amazon Prime, Netflix, BT, Sky, magazine subscriptions, professional memberships

· Charities supported

· Car(s) owned

· Eating habits based on categories of restaurants, frequency, locations, amounts spent

· Hobbies – regular club membership payments or, equipment shops.

· If I have children and potentially determine their age.

· Preference for using banking services. For example, number of transactions conducted in-branch/ online/ mobile, style of payments (Chip-and-Pin, Contactless, Apple Pay)

· If I travel overseas and my spending habits when I am overseas (do I use cash/ preloaded cards, do I buy cash at airports etc.)

· How much cash do I use

· Digital savvyness; do I use disrupters – Uber, Airbnb, robot-advisors etc.

· Long term medical illness

· Branch using habits (payments made in branch)

· Taxes paid

· Loan and mortgage repayments.

Unscheduled but predictable payments · breakfast, lunch, coffee purchased

· Impulse purchases

· Gardening/ window cleaning services used

Unscheduled and unpredictable payments · Holiday purchases

· One-off purchases (DIY stores)

Style of payments · Cheque


· Debit card

· Credit card

· Contactless

· Apple/ Android Pay

· Chip and Pin

· In branch

· P2P payment

· Mobile payments

· In-App payments

· Bank GIRO

This analysis demonstrated that the metadata will reveal personal and sensitive information about individuals and families – and could be argued that it is more valuable than individual transactions. And to do this at scale, using algorithms, can enable a TPP to mine this data and create value for the customers. Also, if a TPP is an aggregator (known as an AISP) and a payment initiator (known as a PISP), they can combine additional data and metadata to enrich information and the confidence in it. For example, a bank may not provide full description of a transaction but it may be available to a PISP as they work with merchants to initiate ‘request to pay’ requests.

A TPP can generate and deliver meaningful value to retail customers and creating offerings for B2B buyers as well. Here are some examples:

Creating value for retail customers

Providing guidance/ nudges to help individuals identify financial and non-financial products that are suitable, affordable and better value for money for an individual or, a family. The end goal here will be to help people be better off over time; help them make better decisions based on facts and data rather than emotion. For example:

  • Current accounts that provide similar feature/ functions, better terms (which end-customers generally do not read) and has no monthly fee.
  • Help avoid overdraft fee and charges by giving early notifications when an algorithm predicts the user to go into overdraft as scheduled payment might push the user into an overdraft. Suggest other accounts where money could be moved from temporarily and make it happen in a click.
  • Find “moments” to provide achievable tips and financial education; for example, how to improve credit ratings, or long-term savings for children, or showing how just saving little amounts can result in large savings in the long-term
  • Build and link key life events with financial events such as going to university, getting married, buying a house, buying a car, having children and so on. Giving nudges to save early and at the right ‘moments’.
  • Financial/ Budget planning tools – showing families how much they would save if they were to use alternative products from the same supplier (e.g. fixed rate rather standard rates for utilities) or, by leaving certain vendors covering utilities, media and entertainment etc.
  • Add loyalty points for every shop where the customer may have forgotten to swipe their points card.
  • Manage purchase receipts digitally and help people do their expenses.
  • Help get refunds from retailers, travel and transport companies
  • Micro-lending at the point-of-sale; this could be particularly useful for individuals with low credit rating and who do not have a credit card (more on this in another blog).

Creating value for business customers:

Here are examples of offerings, products and platforms that a TPP may be able to create for the B2B market:

  • As a PISP, a TPP can build a new payment gateway that can process ‘direct from bank’ payments in ecommerce transactions and in-App purchases. For example, a supermarket could embed the new payment style in their mobile app, shoppers can scan and put items in the basket and checkout directly from their mobile. No need to queue and reduce cost of processing payments at the same time. Retailers, Travel and Transport, Holiday companies are likely to be the biggest beneficiaries of direct payments.
  • Over time, as significant number of users join a TPP, they will be able to derive trend and demographic information at a street, borough, city and national level. Hedge funds and investment managers might be interested in this data to give them insights into how much, where and what people are spending money on so they can take these ‘alternative’ data points as inputs in their investment decision-making engine. Similar systems have been making their way into the industry.
  • A new alternative for credit ratings. Most people do not know how credit ratings work and/ or how to improve them. With visibility to transactional and granular data and the metadata, a different type of credit rating engine could be developed – particularly for the ‘underbanked’ segment of our society and those with poor ratings for no fault of their own. A retailer, for example, may be interested in using this type of credit rating to offer micro-loans to customers.
  • Better fraud detection. Most banks have at least one payment fraud engine; however, these systems generally rely on a user’s past behaviour with the bank or rules set within the boundaries of the bank. With access to user’s activities from across multiple banks, the user profile could be richer and the false positives ratio can be dropped further. Thereby enhancing customer experience.

With all the excitement, we must not forget the challenges that come. TPPs must treat the data and the insights that they can draw with care and attention it deserves. Moral and ethical discussions ought to be held and standards need to be established to ensure that the data is ultimately used for the benefit of the end-user without the creepy factor and product sales agenda. More needs to be done to educate end-users about PSD2 and how new types of services that, we haven’t yet seen, will be created. As without mass adoption, the innovation and value will not be financially rewarding for TPPs.

Despite its imperfections, I am excited about PSD2 and looking forward to what the next iterations of the regulations will enable. Combined with similar initiatives in other industries, I am excited about the possibility when all of us are in complete control of our data and that it cannot be stolen or impersonated. We can choose to share our data with whomever we want – in exchange for value. It becomes a valuable commodity we can trade.

Creating Competitive Differentiation in the Digital Era

Over 60 years the Information Technology (IT) industry has transformed organisations by automating tasks. Starting with simple mathematical operations, IT has now evolved to highly complex algorithms that, for example, can compute and predict national demand for utility consumption every few minutes. One by-product of this automation is the creation of digital data. What we do with this will be the story of the IT industry in the future. This ability to use data to model and ultimately predict any aspect of our work and daily life promises to fuel the next era of innovation.

The internet and its adoption have also changed the world in a way that was not obvious twenty years ago. It didn’t just create a network of computers, it connected people from across the globe. Collaboration became easier and accelerated the development of ideas and new technologies within and across sectors. Just in the last ten years, we have seen a sea-change in how technology is embedded in our everyday lives. It now seems natural and acceptable that your fridge can automatically place orders to replenish the exact groceries you have used and that your running shoes can generate data to give you a real-time view of your performance – and even gamify this experience by competing with a friend who may be living 5,000 miles away.

All of this is possible through data; we are all consuming and generating enormous amount of it. So much so that each of us are creating 2.5 quintillion bytes of data every day (equivalent to 10 million Blu-ray discs). 90% of the data that exists in the world today has been created in just the last two years. Our ability to store and process structured data at scale is becoming commoditised; however, 80% of the data we create is unstructured – coming from a variety of sources such as photos, videos, logs, reports and social media posts. And, whilst our computers can save these as les, they have no idea what’s in them.

Data is fueling new industries too. A developer with a new idea can build a prototype within days – the infrastructure, tools and any data needed to realise the idea are available on the Cloud. Differentiation often comes from how varied data-sets are combined to create value for the consumer. These value-driven experiences are changing customer expectations and their interactions with brands. The most recent best experience from one brand soon becomes the lowest expectation from another brand that may be in a different sector altogether.

To meet these ever-increasing customer demands, corporations are embarking on “digital” journeys. Regardless of the specific project, the purpose is to use digital technologies to provide richer, smoother user experience by moving meaningful data around quickly, reducing inefficiencies and participating in value-driven ecosystems. We see these in digital platforms such as Uber and Airbnb that bring together the consumers and providers of services.

Whilst any two organisations may look the same in their digital capabilities, the real differentiation is in their execution. An organisation with a culture of innovation, collaboration and true customer focus will be able to maintain differentiation and identity in the digital world as they do in the physical world. The winners will use their digital capabilities to draw digital intelligence and transform to become cognitive businesses. To do this, organisations are now able to apply Artificial Intelligence (AI) to draw insights from structured and unstructured data.

AI is a collective term used for capabilities such as natural language processing, deep-learning, neural networks, vision and more. These capabilities support ingestion of structured and unstructured data. A system with these capabilities can learn the meaning of data and add to a constantly evolving corpus of knowledge. It can generate hypotheses and points-of-views. These insights will help organisations truly understand and even predict their customers’ needs and personalise services.

Unlike digital systems that are programmed, cognitive systems are taught. They learn, develop a neural network of knowledge and ultimately become experts in a eld. Imagine the world’s best oncologist teaching a cognitive system how to detect cancer, identify treatment options and have an emotionally intelligent conversation. Cognitive systems have unlimited capacity to learn, remember and recall information and ‘join the dots’ to draw conclusions.

It may appear science-fiction but cognitive capabilities such as the one just described are already becoming an integral part of our lives and the wider society. We are using personal assistants embedded in our smartphones and chatbots to nd information quickly and to perform tasks. Users no longer need to remember commands – they can simply speak or chat with the system as they would to another person – in natural language – and the system can understand the intent behind a question regardless of how  it is phrased. At work, experts in healthcare and advisers in the financial = services sector are receiving evidence-based advice on diagnosis or financial advice, in real-time, that they can use with the clients. These expert systems are augmenting human intelligence by doing the heavy lifting of handling and processing huge amounts of data and drawing insights which humans cannot do at scale.

Organisations can no longer look to their competitors to decide what to do next. Innovation and reinvention are key to existence in this rapidly changing world. Anticipating and delivering customers’ needs with agility and pace is vital. Organisations should start on their journey by exploring how cognitive systems can uncover the value hidden in their data; it will help them disrupt new markets or innovate within.

Digital is a pre-requisite and a journey, it is not the destination. Creating magical experiences that consumers will pay for is the end game.

[originally published by Bharat Bhushan in the BNPP Focus magazine]

3 reasons why PSD2 will not revolutionise financial services

Since its announcement in 2015, European Union’s Payment Services Directive 2 (PSD2) has become the most debated and discussed topic at conferences and board-rooms around the world – well beyond the boundaries of the European Economic Area and the Financial Services Sector.

For an introduction to PSD2, see PSD2 101 but at a high-level, PSD2 enforces financial institutions to deliver the following capabilities:

  • Open access to account information (everything you see on your statement).
  • Allow access to payment services via APIs. This includes receiving, sending and checking status of payments in flight.

Under PSD2, account owners can authorise one or more third parties for either or both capabilities in return for potential value-add-services. For example, allowing a third party to access account information means that, particularly in the scenario of multi-bank/ multi-account individual who currently uses different apps from different banks/ product-type to check balances and transactions can use a single app. Similarly, allowing a third-party to initiate payments directly from the bank account without using long-card numbers has its merits.

PSD2 appears to create a level playing field for all market participants. It is democratising customer data held by banks (with permission) and gives customers choice in how they use some banking services without necessarily using their banks. However, there are some fundamental challenges that will prevent PSD2 to be as ground-breaking as it could have been. These are:

1. Customer Education and Motivation

There is little to no effort being put in to generate awareness about PSD2 that a person on the street can understand. Buyers need to understand the differences between current mechanisms to make payments and the new direct-from-account style payment in the post-PSD2 world. Pro-and-Cons need to be articulated in very simple terms so it is clear to all age groups and backgrounds. PSD2 can benefit the underbanked segment of our society who do not have credit cards and often only have ATM cards that can only be used in certain high-street stores. Being able to pay directly from the bank account will enable them to participate in eCommerce and potentially get better deals.

Similarly, businesses who accept payments from customers need to understand the alternative way to accept payments electronically. They will need to work out how to integrate PSD2 style of payment in their customer journeys. Some retailers with physical stores may also want to offer this style of payment to customers in store via an app for convenience. Currently, other industries appear unaware that these changes are happening in the payments industry. Clearly, incumbents who provide card processing systems to these businesses, may not be motivated to explain the alternative payment option due to the risk of cannibalising their own revenue streams. Fees for processing PSD2 style payments are capped at 2bp (2p for every £1) compared to 1–4% (depending on the scheme) that businesses may be paying today. This can be significant reduction in cost – particularly for those with large volumes of card transactions. In recent years, we have seen several retailers disputing interchange fee and taking legal action. PSD2 may force schemes to lower their fee and increase focus on B2B value-added services and customer loyalty.

As we have seen from the UK’s current account switching service, it takes times for consumers to trust and use a new service even if it benefits them. Launched in 2013, after continuous campaigns across TV, Ratio, Newspaper and online, as of May 2017, at the time of writing this blog, only 3M current accounts were switched using this service. Some people in the industry would regard this as a failure. An estimated £800m have been spent on the scheme so far.

Also, just because there is an alternative way to pay, does not mean that buyers will use it. Using a card issued by a major scheme does have its merits – fraud protection/ loyalty/ concierge to mention a few. Also, to pay direct from your account, the buyer will need to have cleared funds in their account. A credit card issued by a scheme can act as a short-term buffer for many. Whilst retailers would benefit the most from PSD2, they are unlikely to pass on any cost benefits to the buyers – further deter a buyer from paying direct.

2. Universal” APIs and Data Model

Approximately 4,000 financial institutions across EEA are affected by PSD2 and need to expose access to account information or, both account information and payment services via APIs. With no universal standard across EEA (except the UK), all institutions could comply to the regulation in their own way. For example, to comply there are likely to be 6 – 12 APIs. For example – validateTPP, getAccountInfo, getAccountTransactions, getCustomerInfo, initiatePayment, checkPaymentStatus, registerCustomer, checkConsent, unRegister, etc.) there could be at least 4,000 x 6 = 24,000 APIs. And, if we assume that each API will have three versions – current, new and old version for interoperability/ support reasons. This creates at least 24,000 x 3 = 72,000 APIs. Anyone looking to create a universal payment app, or an aggregation app will be consumed by the mammoth task of integration.

Therefore, this may create further fragmentation and oligopoly. In the UK, there is a slightly better environment. UK’s Competition and Markets Authority, is setting those standards and at least 9 UK banks will adopt those standards with a hope that the rest will follow. See these standards here – https://github.com/OpenBankingUK/opendata-api-spec-compiled

Without a consistent, standard API and governance model – this will be a spaghetti mesh of complex integration touch-points and be counter-productive to innovation in the industry and potentially put off new entrants. Several FinTechs in Europe have started a campaign claiming that PSD2 will force them to be dependent on banks. For more details, visit http://www.futureofeuropeanfintech.eu

3. Additional Competing Regulation

Shortly after PSD2 comes into effect, in May 2018, General Data Protection Regulation (GDPR) will be in force. GDPR is a cross-sector regulation that puts more responsibility on data controllers (a retail bank, for example) and processors (an AISP, for example).

GDPR gives customers the right to ask a service provider (bank, retailer, insurer etc.) what data they have about them (data access), request to be forgotten (data erasure) or, port their data to another financial institution.

For a financial institution, it includes physical letters/ emails a customer may have sent to the bank, phone calls that may have been recorded, externally sourced data and interaction/ product/ transactional data. Discovering these data sources, making them accessible in a safe and secure manner is a grand technical challenge.

In context of PSD2, a third-party accessing customer data even with their consent, needs to comply with GDPR. They will need to tell the user what data they are gathering, for what purpose, for how long will the data be kept, who is it shared with and what processing is done on the data. In addition, they must refresh consent every 90 days. Complying with GDPR is onerous and resource intensive. Non-compliance penalties are hefty –   20M Euros or, 4% of annual worldwide turnover.

Onerous nature of GDPR will deter new entrants and new services. Particularly from large financial institutions until they have fully understood the implications of GDPR.



Open Banking and PSD2 has the potential to transform the Financial Services Sector across Europe and beyond. I view this as a once-in-a-lifetime opportunity to shape the future of Finance. The affects are also far reaching. Financial institutions from as far as Japan, Australia, South Africa are already expecting a PSD2-equivallent in their geography. Accepting the inevitable, many organisations have already engaged with their regulators and industry bodies to influence and shape their thinking. However, all eyes are set on Europe for the next few months.

Due to the reasons explained above, I believe that it is very unlikely that PSD2 will have a major impact soon after its implementation deadline for the following reasons:

  • Lack of Europe-wide standards for Security, Data and APIs (in that order) will hinder innovation.
  • Financial institutions will focus on compliance and will not fully embrace the spirit of PSD2. Additional risk and liability requirements only underpins this.
  • Educating the consumers will take much longer than anticipated and much to retailers’ dismay, consumers will not have strong motivations to pay direct.
  • Schemes will enhance their customer protection, fee and loyalty programmes.
  • Lack of understanding of GDPR and its implementation will delay the introduction of value-added services.


T–3…2…1… Robo-Advisor Has a Launch!

Since 2008, we have seen a number of Robo-Advisor launches around the world – disrupting the traditional wealth management industry. More Robos are expected to launch in the UK in 2016. Some are home grown, others arriving from continental Europe and the US. Regardless of the numbers, I believe that there is still plenty of room for innovative and differentiating Robo-Platforms in the market.

In this blog, I am discussing the business and technology architecture needed to build and launch a Robo-Advisor/ Digital Wealth Management service; including a distinction between the bare minimum set of features/ functions and considerations of features for the next wave of Robo-Advisors. But first, a reminder of what makes Robo-Advisors different from most traditional wealth managers:

  • Seamless client experience from modelling and simulation to registration to the ongoing relationship management. Design thinking combined with cutting edge visualisation techniques are used to simplify client facing applications and make them intuitive – even for a 60-something who may not be a “digital native”.
  • There is a higher degree of transparency on fees and costs. You can see how much you would pay based on investments and there are no surprises, no exit fees or, transaction costs. There are 3-4 tiers based on the amount you invest and a flat fee per tier.
  • Investors are in control of your investments. Most start small. Also, at any time, investors can change risk preferences and the platform will rebalance the portfolio within a reasonable time at no additional cost to the investor.
  • Robo platforms employ passive or, at best, smart beta investment strategies and products. These are typically less risky than active management where, managers have to employ strategies to beat the market index to beat a target. Also, Robo platforms are discretionary and generally do not offer {regulated} advice.
  • As almost all Robo platforms are created by FinTech start-ups, they have no technology or infrastructure legacy. In fact, most platforms were “born” on off-premise/ cloud based environments, use devOps for continuous delivery and iterative releases. Ultimately enabling the business to be agile.
  • Robo platforms are not well known brands and therefore it takes them longer to acquire a customer and a sudden, uncontrolled market movements to loose many. Most retail investors tend to experiment with a small proportion of their savings. Also, there is no relationship manager to comfort you during rocky market conditions. You are interacting with a website or, a mobile app. Therefore, relative to a high-street retail bank or, a well-known wealth manager, Robo-Advisors take longer to earn the trust of the investor.
  • Traditional wealth managers are able to handle situations of any complexity such as family offices, trusts and handle matters such as tax, legal and investments that can span multiple generations. Currently, Robo-Advisors can handle simple investment scenarios such as Savings and Pensions.
  • It also appears that the founders of Robo-Advisors believe in bringing good social change too. They want an average person with an average job and savings to have the same level of service and quality of investment {advice} as super-rich without high fees and charges. Plus, they want to engage and educate their clients and bring behaviour change.

Before we get into the nuts and bolts of a Robo-Advisor, let’s also look at the key junctions of an investor’s journey. This will become useful later to highlight how different parts of the system come together to enable these interactions:


Here is a brief analysis of the following four key events in an investor’s journey:

Event How does the investor feel? What action would the investor take?
An individual becomes aware of the need to save. Guilty for not starting sooner, wants help to build a plan and start saving towards the plan. Actively searches for saving options, may visit their bank and choose one or more services or products to invest with.
Registration and goal setting. Energised about the goal and savings, feels good about starting to save and may visualise how they might feel upon reaching the goal. Transfers cash to the provider.
The investor may achieve their investment goal. Delighted to have achieved the financial goals. May feel motivated to do this again. May cash out and use money towards the goal – wedding, car, children’s education etc.
The investor decides to leave the service. May be frustrated that the goals have not been met in a specific timeline or, that the returns on investments have been lower than expected or, finds a better product/ provider.


Requests for the account to be closed, portfolio to be divested and cash to be transferred to his/ her bank account.

May look for an alternative products or providers.

All of the interactions happen electronically. The Business and Technical Architecture below underpins the offering:


Front Office Systems primarily include applications and systems used by prospects, clients and client-facing employees. No change there! However, over the last few years, there has been considerable focus on providing excellent client experience. As a result, Design Thinking concepts have been applied whilst designing business processes and front-end systems. Using simplistic and colourful interfaces, prospects can learn about the offering, do modelling and simulations. Investors can see their portfolio, holdings and current valuations, performance over time and the exact amount of fee they have paid. I mentioned social change earlier and these front-end systems use techniques such as goal-setting, what-if analysis, gamification and visualisation techniques to engage investors and encourage behaviour change by demonstrating the impact of their decisions. Education happens by explaining concepts, market movements, risks and opportunities in simple language through blogs, articles and videos commentaries. Collectively, all of this demonstrates openness and that the manager is working for and on behalf of the investor – keeping investors interests above their own.

Investment Strategies and Risk Systems, I believe, are at the heart of any wealth management organisation; especially critical for Robo-Advisor firms. Getting this part of the business wrong could be catastrophic for the organisation and for its clients as well. The organisation must decide and continuously evaluate the following areas:

  1. Risk management process – including operational, investment and compliance risk.
  2. How to assess risk appetite of prospects and clients?
  3. List of investment instruments, evaluation of their risk ratings and the process of asset allocation and portfolio construction.

Once these decisions are made, the next critical decision is what to automate and the level of automation. Higher degree of automation can help achieve scale and control/ contain costs. Tasks such as asset allocation and portfolio construction should be automated based on rules. These rules, however, should be created by human experts. For example, the Chief Investment Officer and his expert team to determine the rules for asset allocation and portfolio construction, when it is necessary to rebalance portfolio, frequency at which portfolios must be valued and compared to their client risk profiles and how the rebalancing should occur.

Components such as portfolio execution, custody, reporting and legal can be outsourced to some extent – even though the liability will still remain with the Robo-Advisor.

Enablers include skills, tools, technologies and systems that are required to build the operating platform for the organisation. The business and IT functions must make these key decisions together that, in traditional organisations, are usually IT centric. For example, the selection of content management platform or, the design of core APIs. The former may allow the business to curate and publish content independent of IT and the latter may play a vital role in integrating and embedding the Robo-Advisor in third party services. These factors can differentiate Robo-Advisors.

As these could be considered non-core to the business, a number of these components can be outsourced. However, for the reasons explained above, the business needs to maintain a degree of control. I’ve illustrated these in the table below with control levels as ‘obsessive’, ‘Mildly obsessive’ and ‘relaxed’. These labels apply whether these are internal to the organisation or provided by third-party/ cloud-based capabilities.

Component Level of control
API Design Obsessive
Talent Management Obsessive
Design Thinking Obsessive
Systems development and integration Mildly Obsessive
Business Process Management Mildly Obsessive
Data Quality and Governance Mildly Obsessive
Third party services Mildly Obsessive
Systems of record Relaxed
Infrastructure and platforms Relaxed
Content Management Obsessive

All components in the architecture need to be secure and must provide hooks into the Big Data and Analytics engines. Whether you are integrating with a custodian outside of your network, a CRM system on the Cloud or, an order management system within your enterprise, I believe that the same level of security should be applied. At the very least, the ‘CAIN’ principle checklist should be on systems and points of integration – Confidentiality, Authentication, Integrity and Non-Repudiation. These principles apply regardless of the actual mechanisms used on the wire.

Big Data and Analytics can support the business in making informed routine and strategic decisions. Here are some examples of Analytics use cases for Robo-Advisors:

Client Related

  • Prospects visiting your website or downloading your app. Their interaction history and activities – clicks, content consumed, duration spent on content can be combined with customer acquisition models to present bespoke offers and content. For example, first 3 months free or, invitation to come to a face-to-face event they may be interested in. A prospect’s history of interaction with the Robo-Advisor can be tied to customer when they register including any goals, savings and targets they might have entered.
  • Better understand your customer demographics and common trends within each segment of your client-base. For example, most 30-35 year olds start saving for their Children’s University Education. This be used to guide/ influence a new 32 year old investor who has just joined the platform.
  • Lifetime value of clients.
  • Predict customer life-events and suggests goals, savings and life-style choices. For example, a 20-something year old is likely to buy car, pay student loans, get married, have children etc. This timeline of events can be applied to the type of interaction, value-add and products Robo-Advisors can offer to this client.
  • Predict when a customer is likely to leave the Robo-Platform, several weeks in advance. Using proven models, it is possible to combine demographics, behaviour, transaction, personality and social data to predict if a customer is planning to leave the Robo platform.
  • Applied to the KYC process and obtain better confidence that risk questions have been understood by the customer.

Social Media Analytics

  • Robo-Advisors take full advantage of social media platforms to build brand reputation and trust. Analytics can be used to compare engagement, influence and reach. Also, how you compare to your peer group and against your internal targets.
  • With permission, Robo-Advisors can see customer/ prospect posts on social media to determine social network strength, influence factor and propensity to recommend.
  • There are some early prototypes that can use social media to determine risk-appetite and profile of a retail investor.

Product and Offering Analytics

  • Customer usability behaviour can be tracked on websites and applications to enhance customer experience. For example, creating heat-maps of how customers are using the application. This could be useful to isolate and identify points of frustration in the customer journey.
  • Product uptake sentiment – investor’s feelings about new products being offered.
  • Big Data can play a critical role in investment research, should the Robo-Advisor choose to perform any market research themselves. Non-traditional data sources such as weather, social, news and events can be combined with traditional economic and financial data to enrich research and create or invest in better/ more robust products.



The first wave of Robo-Advisors have brought disruption in the industry.  And, as it is probably now obvious to most readers, building a Robo-Advisor is complex but not a difficult task. The underpinning technologies have been generally available and used across all sectors and industries for decades. A fantastic front-end, backed with a sound and robust risk management system and processes is key to the long-term success of a Robo-Advisor.

Current functions and capabilities of Robo-Advisors is now the minimum expectation of investors. And, Robo-Advisors could do better. The next few waves of Robo-Advisors should consider and implement the following exciting set of capabilities:

  • Natural language interface that clients can use in a chat window or over voice. Imagine a digital assistant that you can talk to who understands natural language, can pick up conversations where you left them, can send you reminders and updates.
  • Customisable visualisations, complex modelling and peer-group comparisons.
  • Provide investors with more control on the type of investments they are willing to make.
  • With client’s permission, connect to other savings, investments and liabilities an investor may have. Then, use this information to identify savings potential and better management of assets and liabilities. We may see partnerships between Robo and service providers such as legal and tax providers to handle an investor’s specific needs.
  • Ability to handle advice based scenarios of low to medium complexity. As pensions are already a product most Robo-Advisors offer, perhaps start with advice on Pensions.
  • Active investment strategies.


I am looking forward to the developments in the {digital} wealth management space over the next few years. Excitement ahead…

Transformation of the investment management industry starts with its professionals

In his opening remarks, Paul Smith, CEO, CFA Institute made candid comments about hot topics in the industry – Trust, Code of Conduct, Partnerships, Value to investor etc. He noted “The benefits provided by a Doctor or a Lawyer are crystal clear to the users of their services but this is not the case for investment professionals”. He highlighted the following challenges:

  • Technical competence of investment professionals ultimately affecting trustworthiness in the society. Many professionals in the industry have little to no qualifications.
  • ‘The curse of the short-termism’ that derails professional from delivering clients’ long-term goals.
  • Lack of value delivered to the investors and the society.
  • Digital technologies moving at a much faster pace than the industry’s is able to absorb them. It is not a complete stretch of the imagination that technology could lead to disintermediation unless investors receive highly personalised and sophisticated integrated-channels experience.

So, what needs to be done?

  1. Professionals and organisations need to conduct themselves in a manner that fosters Trustworthiness. Therefore, promote higher professional standards, qualifications and good conduct across the entire organisation and not just the decision makers. Employees in an organisation should use the same vocabulary and understand their fiduciary duties.
  2. Partner with leaders in the industry and sign up to the asset manager code of conduct as well as support investor rights. On the surface, the code of conduct and investor rights appear to be simple and common sense. So why aren’t the professionals signing up for these?
  3. Close the gender gap and bring diversified thinking at all levels in the organisation.
  4. Advocate for policy research, thought leadership to benefit investors and society at large.

It was refreshing to see Paul challenging the status-quo and urging the professionals to take immediate action. Here are some useful links: Asset Managers Code of Conduct – http://www.cfainstitute.org/ethics/Documents/amc_outreach_flyer.pdf 10 Simple Investor Rights – http://investorrights.cfainstitute.org/ Watch the replay of Paul’s session here – http://livestream.com/livecfa/AC2015 My short Finextra video interview on ‘Innovation in Wealth Management’ discussing similar topics – http://www.finextra.com/video/video.aspx?videoid=825

3 Things I Learnt at the CFA Annual Conference (Day 1)

>1. Mr. Regulator, please provide guidance

Joachim Klement delivered a talk titled ‘Identifying Investor Risk Profiles’ and using published facts and a series of examples, he demonstrated that the widely adopted practice of using risk questionnaires to establish risk profile of an investor is highly unreliable. And yet, the foundation of every investment decision made for, or on behalf of an investor is the established risk profile. Whilst the majority of his discussion focused on retail investors, he made an excellent point that in case of institutional investors that use intermediaries, the issue is further magnified by the fact that intermediaries have imperfect knowledge of the end-client risk profile. The lack of complete understanding of client risk profile and goals is a possible reason for mis-selling.

He asked that the regulators could and should provide guidance on how wealth managers should assess the investor risk profile. I see this differently to Mr. Klement. I believe that the collective wisdom of practicing wealth managers ought to lead the way after all wealth managers are paid to act on behalf of their clients.

>2. Onions once ruled the Indian Government

“What is the most important food item in India?” – asked Dr. Pippa Malmgren during her session on Geopolitics. Surely, wheat or rice? Apparently it’s Onions! But this was not a trick question – turns out that the supply and price of onions in India had a big impact on the popularity of the Government. In 2010, the government was forced to introduce export control policies to address the sky-rocketing onion prices.

Dr. Malmgren took several examples of current issues around the world concerning political and economic powers to explain the complex web of interdependencies in a global political landscape. The challenge for the wealth and asset managers therefore, is not “What” but “How” to think about Geopolitics and to recognise the correlation/ its effect on asset prices.

In a nutshell, if you are a politician, you can never please everybody!

>3. Faecal transplant can change your personality

A fantastic keynote session titled “The Biology of Risk Taking” by John Coates in which he began by discussing the role of Brain in our bodies. Apparently, there is no such thing as a pure thought – our brains exist to plan and execute movements from flexing muscles to issuing instructions to pump blood to certain parts of the body when it’s needed the most.

He then went on to discuss various chemicals our bodies produce such as dopamine, cortisol, adrenaline and their direct correlation between how our bodies react to situations. Focusing on cortisol, his controlled experiments on a trading floor showed correlation between levels of cortisol and appetite to take risk. Data collected over two week proved that during a market crash, cortisol levels shot up and the same time traders and investors avoided risk. Whilst the brain chemistry was changing, the traders did not feel stressed or observed any changes in their physiological state.

The interesting thing is that acute stress can be good especially if there is are small stress episodes with recovery periods (just like exercising) can build resilience towards chronic stress.

John highlighted that the Wealth and Asset Management industry is based on theories whereas some other fields such as medicine has no theories. ‘Medics’ consider and evaluate every possible option. An experiment conducted on two mice to observe the effects of faecal transplant. One of the mice was afraid of water and another that was quite fond of it. After the transplant, whilst there was >90% success rate in addressing the CDI disease, the new chemicals in their bodies were also altering their personalities. This transplant had swapped their personalities – the swimmer mice had become afraid of the water and the mice that was afraid of the water became quite a swimmer! So before you opt for one of these, get to know your donor!!!

The point John made was to look beyond your industry to find ways to innovate.

Investment Management 101

One of the best things about working for IBM is the variety of work and the opportunity to take on new challenges without changing employer. In my current role, I am a member of a very specialist unit in IBM – often described by our UK CEO as the tip of an arrow spearheading an industry. Individuals in this team have deep industry expertise. Some colleagues have even spent years working in a specific industry before joining IBM. So, no pressure!

I am tasked to lead our engagements in the Investment Management industry; more specifically the asset and wealth management clients. The only challenge is that I am not an investment guy! So I had to race up the learning curve quickly. I began by searching answers to the following questions:

1. What is the purpose of the industry? Who does it serve and where does it fit in the wider financial sector?

2. What are the front/ middle/ back office functions in a typical organisation?

3. Who are the key actors in the industry?

4. What are the hot topics (innovation/ challenges) in the industry?

My hope is that by finding answers to the above questions, I will, hopefully, have further curious questions (I don’t even know what I don’t know yet) and help me engage with my clients better and have a rounded perspective.

Industry Overview

I define the investment management industry’s purpose as – To understand and realise investment objectives of an asset owner over a defined term”. Interestingly, when I explored academic literature in this field, it is broadly categorised under ‘Behavioural Finance’ which suggests that an asset owner/ investor employ an asset manager because of their psychological belief that they cannot achieve the investment objectives themselves.

Asset Managers, fund managers, wealth managers are specific job functions in the industry; just like a software engineer, software architect and design engineers are in the IT industry. They perform specific functions and provide a range of services to their clients. I see the supply chain as follows:

Figure 1 – Supply chain in the industry

Figure 1 – Supply chain in the industry

An investor/ asset owner is an entity that is ultimately the legal owner of the asset. For example, a University owns an endowment; Richard Branson owns cash in his bank accounts and properties around the world. Types of institutional investors are:

– Pension funds

– Insurance companies

– Sovereign wealth funds

– Charities Foundations

– University Endowments

– Banks

Although this may vary between geography and size of a wealth management organisation, the categorisation of individual customer is as follows:

– Affluent (Assets between $100K – $1M)

– High Net Worth (assets between $1 – $10M)

– Ultra-High Net Worth (assets above $10M)

An asset owner employs one or more asset/ wealth manager for their investment skills. Whilst the role of an asset and wealth manager is broadly the same (i.e. achieve investment goals), they have different scales and cater for different client needs. An asset manager usually has institutional investors such as pension funds, banks, insurance companies whereas a wealth manager typically caters for the retail market i.e. individuals that are affluent, high net worth and ultra-high net worth. A wealth manager provides bespoke personalised services to individuals for all of their wealth that may include cash, properties, art collection, car collection etc.

Finally, a fund manager provides their services to the asset and wealth managers in form of financial instruments that they believe will outperform market volatilities.

Some asset owners (generally institutional investors) also employs an intermediary. The objective of an intermediary is to help an asset owner recruit a suitable asset manager and periodically perform objective assessment of the services provided by the asset manager. They may also provide additional functions such as compliance reporting, reconciliation, asset servicing etc.

Figure 2 - Intermediary

Figure 2 – Role of an intermediary

Fundamental principle

An asset/ wealth manager acts on behalf of an investor (asset owner) and must always act in the interest of the investor with a view to fulfilling the asset owner’s investment objectives. It has a fiduciary duty and its loyalty should lie with the investor. This investment management industry is unique that although it can potentially control the fate of assets of enormous proportions, they are not their assets and therefore are not shown on the balance sheet of an asset/ wealth manager. They must simply act as an agent. This has profound implications around regulation and ethics which I will discuss in future blogs.

The diagram below illustrates how I see the investment management industry fit in the wider picture. I suspect there are numerous other ways this could be drawn. My rationale was that the investment management industry is ultimately creating products for the asset and wealth managers.

Industry fit in the sector

Industry fit in the financial services sector

Figure 3 – Industry fit in the financial services sector

The asset and wealth managers are known as the “buy side” and the investment banking firms are known as the “sell side”.

The diagram below is my mental map of the business functions and external actors. Some functions such as fund administration, custodian services, payment processing, trade execution etc. may be outsourced.

business functions of an asset and wealth manager

Figure 4 – Map of key front/ middle and back office functions

I will most likely refer to this picture in my following blogs when I discuss specific business functions and how to re-imagine their functions to transform your business. In the meantime, please print this on an A4 or A3 sheet and pin it on your wall 🙂


Focusing on the challenges, you can pick up any major publication and these topics are consistently making headlines:

1. “Trust” and when I break this down into sizeable chunks – some are really sensitive topics. Sensitive for the regulator, government and also the investors. Lack of openness and clarity around fee, charges and demonstrating zero conflict of interest. This issue has reached highest levels in Government as well. For example – Lord German’s proposal in the UK to ban NDAs and a couple of weeks ago, the US president Barack Obama said, “It’s a very simple principle: You want to give financial advice, you’ve got to put your client’s interests first. You can’t have a conflict of interest.” And, he has put forward a proposal to protect investors.

2. Gender gap that is also reflected in the pay. Though you could argue that this is an HR/ internal issue, there is some evidence to suggest that female asset managers are better performers than their male counterparts. Although this could be because there so few female asset managers that only the best remain in the industry?

3. Discussion between Active Vs Passive management and that only a fraction of active managers actually meet their performance objectives after fees and charges. This is self-evident as passive fund allocation strategies are on the rise.

4. Linked with the above, is the issue around performance and efficiency of asset managers i.e. determining if they are being successful due to skill or luck?

5. There are other issues that are not high on the visibility radar yet but will become important, especially for institutional investor are

♦ Expectation of responsible investing especially in case of discretionary investments.

♦ Millennials and do wealth managers know how to engage with them? What happens after the millennials?

6. This debate would not be complete if I did not mention regulation. I think there is a triangle of Regulation à customer expectation à Technology innovation. The challenge for the asset and wealth managers is how to maximise innovation through technology so they can meet the growing demands of their clients and cost of meeting regulatory demands. Regulatory changes are retrospective and therefore if you are trying to meet regulatory demands then you are probably in catch up mode.

Call to Action:

♦ Start by truly understanding your customer. Predict their needs before they tell you their needs. Draw a parallel from the retail sector who have had to transform their businesses to remain on the high street. Can you surprise and delight clients? What value can you deliver to your clients beyond just asset selection? Create a culture in your organisation that your team is willing to do the right thing for the client even if it is not the right thing for your business. Perhaps this will be the topic of my next blog and I can share my thoughts on how to put customers at the centre of your universe.

♦ Setup a small innovation team that focuses on solving day-to-day business challenges in a different way – not a cliché – a necessity in my view. Give them the tools, funding and the freedom to be creative. Encourage them to look beyond your own industry to look for inspiration or, perhaps even collaboration. Most thought leaders are arguing that the innovation will come from outside the industry. Form those partnerships.

♦ And finally, if you were to start all over again, what will you do? How will you engage with your clients and empower your employees? What platforms will you create? Can you re-imagine your entire business? Run a small proof of concept over a short period.