XBRL to flatten information asymmetries in the small business lending market

There is simply nothing more frustrating than trying to communicate with someone when neither of you speak the same language. Having just returned from a holiday in Morocco, I found myself in this exact situation on more than one occasion. Luckily, when English wasn’t an option, my schoolgirl French was often able to bridge the gap between residents of the mainly Moroccan Arabic speaking population and myself.

Native English speakers (like me) who grew up in the Southern Hemisphere are generally lazy about languages in part due to our relative isolation. Unlike our European counterparts for whom multilingualism is almost a necessity for trade, English is really all we will ever need. In fact, despite it not even being the most widely spoken language, as the unofficial international language of business, English has become a common standard by which many of us communicate with each other across borders.

Like English is to business, so too in many ways is XBRL to data. It is the common language many governments and startups now hope will become the standard by which organisations share and translate information between each other. Today, without broad take-up of XBRL, many governments, investors and businesses are currently in the dark when it comes to analysing the mountains of unstructured data thrown at them by financial entities.

For small business finance and banking, XBRL has the potential to not only reduce the need for multiple data entry, but to also allow for greater comparability and portability of financial information. This opens the door to significant productivity savings and reduced financing costs to boot.

In 2010 Australia made inroads into encouraging adoption of XBRL through the launch of its Standard Business Reporting (SBR) initiative. Using SBR enabled software, businesses across Australia can now lodge key government forms (tax returns etc) straight from their accounting software to relevant government agencies. According to a report from the Australian Business Register, at the end of June 2014, over 568,000 reports had been lodged using SBR since its implementation in mid-2010.

Of course extending SBR to include sharing financial data between businesses and financial institutions is a natural next step. There is some hope that Australia will be able to follow the Netherland’s lead, where companies can now provide XBRL formatted financial statements to banks for the purposes of loan applications. Not only has this significantly reduced information asymmetry between the two parties, but is reducing the time it takes to receive a credit decision. ING, one of the frontrunners in this space, has indicated 4 day turnarounds and discounts for XBRL enabled paperless applications.

Unsurprisingly, there is evidence that suggests XBRL can play a role in lowering the cost of lending. After being spearheaded by the National Bank of Belgium back in 2005, today more than 95% of Belgian private firms’ annual accounts are voluntarily filed in XBRL. Research published in the Journal of Accounting and Public Policy in April 2016 has also indicated a correlation between XBRL adopters and lower interest rate spreads. This supports the commonsense notion that lower information processing costs have a downward effect on loan costs.

Tech focussed banks are in a unique position to work with governments and accounting software providers to leverage XBRL formatted data. Of course as information asymmetries dry up, larger, incumbent banks which have used this as leverage against their competitors will need to improve their offering quickly. Imagine as a business owner, being able to instantaneously shop your financials around several institutions without impacting your credit score or requiring a long transaction history with a provider. Banks relying on this being ‘too hard’ as their competitive moat today – which by the way many do – will certainly need to sharpen their product line.

There is nothing more satisfying than being understood. Yet for many small business owners seeking credit, this is still far more difficult than it should be. XBRL has the potential to help both sides of the lending equation communicate with each other better, faster and more fluently.

For the XBRL Week Intro and Index please click here.

Daily Fintech Advisers provides strategic consulting to organizations with business and investment interests in Fintech. Jessica Ellerm is a thought leader specializing in Small Business.

XBRL leading to better, cheaper, pay-as-you-consume Data & Metadata

In capital markets (public and private) there is an atmosphere pushing towards Transparency, Real-time access, Low cost & Higher Quality, and Pay-as-you-Consume pricing models; especially in the Data and Metadata space. The Data space encompasses primary financial data and the Metadata space, refers to anything produced through analytics that can be used for evaluation and consideration in an investment decision.

Fintechs are taking the lead in using XBRL to “Democratize the Data and Metadata space” in multiple ways. A great example of this trend is evidenced through the partnership of Intrinio, a US financial app vendor with a heavy focus on financial data, and the new US stock exchange IEX, that just recently got approved by the SEC and is owned by the buy-side.

This partnership came out of the challenges of Intrinio’s journey to develop financial apps for valuing companies that can be easily used in Excel or Google sheets. Real-time data was a big hurdle that Intrnio faced, similar to other vendors and startups, because such data is really expensive.

It was the quest to find a way to access such data for their apps by slashing sustainably real-time data costs and avoiding redistribution fees, that lead them to use the XBRL technology to collect data. Intrinio first started with an algorithm that collects data from company documents for all US publicly traded companies (following the 2009 mandatory filing passed by Congress). The next step is the partnership with IEX pricing, which allows Intrinio to offer real time stock prices without the redistribution fees and offers attractive pricing packages. For example, Intrinio’s new Stock screener on Excel (ISE) can be used for free for up to 500 daily data points and thereafter, plans start as low as $10 per month. Such services, can reduce substantially costs for investment bank boutiques, financial analysts, hedge funds etc. The third front on which Intrinio is working on, is taking advantage of the XBRL technology and their in-house algorithms to read and process data from the US consortium of agencies, Federal Financial Institutions Examination Council FFIEC which has also adopted the XBRL reporting standards. The FFIEC is made up of the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS). XBRL reporting has resulted already in higher quality and accuracy of data reported for all Banking call reports that are widely used int eh industry to evaluate the US Banking sector that encompasses 8,000 banks. The new process that has been a huge collaborative effort amongst the banks that have been gradually adopting these standards is explained here by FFIEC and can be visualized below.

Screen Shot 2016-08-26 at 7.31.52 AM

Intrinio is beta testing this process and is aiming to be able to offer this specific dataset to its subscribers either through the ISE or through its API.

Last but not least, Intrinio announced just last week that one more bridge is going to be built and this one is XBRL with Blockchain. The focus on this collaboration is more on transparency, low cost and high quality also. Factom, a blockchain-based solution to manage data and keep records, will be fed by Intrinio financial data that will be “onboarded” on the blockchain that Factom has developed that has no size limitations.

We are witnessing an XBRL led democratization in financial data that is aiming to be accessible through low cost subscriptions and pay-as-you-consume pricing plans, to anyone. At the same time, this greater quality data and metadata, will be fed through APIs or Blockchains into financial apps that vendors employ or startups are testing. Rachel Carpenter, the CEO of Intrinio, a femtech leader is stressing the fact that there are no redistribution fees in the world that they are envisioning, access is easy through financial APIs and blockchains. Intrinio is also a sponsor of the Fintech Sandbox and StartupBootcamp, supporting the development of Fintech startups along with Xignite, Thomson Reuters, Quovo and others.

For the XBRL Week Intro and Index please click here.

Daily Fintech Advisers provides strategic consulting to organizations with business and investment interests in Fintech & operates the Fintech Genome P2P Knowledge Network.  Efi Pylarinou is a Digital Wealth Management thought leader.

Introducing XBRL Week on Daily Fintech


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Its official – XBRL is boring – just look at Google Trends for XBRL vs Blockchain.

At Daily Fintech, we like to dig below the hype to describe those things that are becoming important, even if the media are ignoring them today.

So, today’s post describes why we have chosen such a boring subject to focus on all week and why we think 2016 is the year that XBRL starts to climb out of the slough of despond to the plateau of productivity, by describing:

1. What got people excited by XBRL about a decade ago.

2. Why XBRL failed to meet those expectations.

3. Why the conditions are now set for XBRL to deliver a lot of value

XBRL 101

▪ XBRL stands for eXtensible Business Reporting Language.

▪ It is an open data standard based on XML, created by an accountant named Charlie Hoffman.

▪ If you tag content consistently, software applications can more easily analyze the data and present more useful information. Think of XBRL like a barcode on financial statements. Yes, that sounds like the Semantic Web, and we all know that the Semantic Web has faced the chicken-and-egg problem (i.e. not enough content is semantically tagged yet and so developers don’t create tools to parse the semantic data). Imagine a Semantic Web standard where governments around the world tell companies that they must tag data that way. That is XBRL.

▪ XBRL gained attention in 2009 when the US SEC mandated that public companies report their financial results in XBRL. Many markets and regulators around  world then also adopted XBRL and more have it under consideration. Although XBRL got famous because SEC mandated it for public equities, there are use cases and mandates in almost every asset class.

▪For more research, go to XBRL.org

What got people excited by XBRL about a decade ago.

It was this superb article in Wired called Radical Transparency in the dark days of February 2009 in the thick of the Global Financial Crisis that first got me excited about XBRL. The usual analogy for the Global Financial Crisis was a heart attack. XBRL is like an MRI machine that lets you see inside to understand what is going on. You can do this at 3 levels:

1. An individual company. XBRL  is good for fundamental analysis (credit or equity). One reason is that “the devil is in the footnotes” (or 10-K or proxy statements) where Investor Relations put the things that they have to report but which they would prefer investors gloss over. XBRL makes it easier for investors to surface this data into their Due Diligence process.

2. A portfolio of companies. XBRL is good for portfolio construction (e.g all companies meeting a thematic goal, global diversification rules and a number of financial filters) and Comparables Analysis (for Investment Banking). This will commodotize (or democratize, depending on your perspective) a lot of the work done on “Wall Street” (more likely  today actually being done in Bangalore).

3. An entire market.  XBRL is a great tool for regulators to spot both individual wrong-doing as well as systemic risk.

Why XBRL failed to meet those expectations.

There was a simple design error in the SEC Mandate. The SEC said, first big companies must comply and small companies can do it a bit later. That was logical. The assumption was that big companies would find the burden easier. However it was a mistake because:

  • Investors had no problem researching a few big companies. What they wanted (and still want) are efficient tools to research a lot of small companies. That is where there is valuation inefficiency and value can be unlocked.
  • Big companies had no problem with Investor Relations. They knew the Analysts and those Analysts took the time to cover them. By contrast, small companies need to be discovered by investors; it’s like a website that wants to be discovered by Google.
  • Big companies had a long-established process for taking ERP data and turning it into HTML for investors and regulators. So they outsourced the work to meet the mandate to turn HTML into XBRL. It was all cost and no reward. If small companies had to comply from day one, they would have told their ERP vendors to output Inline XBRL (see below) i.e Straight Through Processing. That did not happen but – spoiler alert – it is starting to happen now.

While there are many other XBRL initiatives, the SEC Mandate is the bellwether. If this fails, investment in XBRL will decline and if it succeeds it will change the world as hoped for in 2009.

Why the conditions are now set for XBRL to deliver a lot of value

  • InLine XBRL is mature and has recently been allowed by the SEC. The simple explanation of InLine XBRL:

– HTML = human readable

– XBRL = machine-readable

–    InLine XBRL = machine-readable + human readable in the same document.

Note: some machines can read HTML (badly) and some humans can read XBRL (badly) but machines prefer XBRL and humans prefer HTML.

  • Small companies are now reporting in XBRL and tools are appearing for investors. This Landscape Report is already out of date, this an area with a lot of innovation today.
  • Inline XBRL enables ERP vendors to do Straight Through Processing (STP) from Accounting to Investor Relations and Compliance.

XBRL almost died in 2014, overturned by people worried about excess regulation, prompting this and other geeky rescue efforts. Fortunately good sense prevailed and XBRL is ready for the next phase.

During the rest of the week we look at the use cases, at the practical innovation appearing today that uses XBRL. Index to weeks posts:

XBRL leading to better, cheaper, pay-as-you-consume Data & Metadata

XBRL to flatten information asymmetries in the small business lending market

How XBRL is being used for Insurance Solvency 2 regulatory reporting

XBRL usage from Banks and Fintechs

Daily Fintech Advisers provides strategic consulting to organizations with business and investment interests in Fintech & operates the Fintech Genome P2P Knowledge Network. Bernard Lunn is a Fintech thought-leader.

Wrap of Week #34: Data and robo-advisors, SmallBiz, Credit reporting, Insurtech trends, Investment returns


About Daily Fintech Advisers

Alternative data (a broad term), types and quality, is not really used by Robo-advisors. A first look at what data feeds robo-advisors and what potential exists.

Why serving SmallBiz is becoming a smart move after being a dumb one in the past.

From Australia a look at evidence that Fintech players are pushing on Comprehensive Credit Reporting.

A look at what VC funding in the insurtech sector is telling us about the direction of the market, here.

The Millennials (a controversial term in the Fintech community, see Fintech Genome conversation here) aren’t really what is at heart of the unstoppable robo-investing trend. It’s the fees stupid! Fee Adjusted Return On Capital (FAROC)

On the Fintech Genome you can read or engage in many interesting conversations on Chatbots, Mortgage banking, Corporate Lending, P2P lending Transparency, Banking APIs, disruptive insurance products, Yirendai, etc.

Two conversations related to SmallBiz and Robos are: “The US B2B robos are powering ahead” and “Banks and Lending marketplaces in partnership for corporate lending”. A nascent area is MortgageTech, join the conversation here.

You can also read about How to generate great conversations or listen to a podcast version from the moderators of the platform.

If you enjoy reading the Daily Fintech insights by our experts è Subscribe to this newsletter.

If you want to engage and converse with the Fintech community è Register on Fintech Genome. 

It’s the fees stupid! Fee Adjusted Return On Capital (FAROC).


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It’s the fees stupid! is one thing that old and young can agree on

One conference session that I ignore is the one that tells me that Millennials use mobile phones and that explains their adoption of new financial services. The conference session usually starts with a middle aged exec telling a story about his/her teenager(s) and their use of mobile and how we must build a User Experience (UX) that meets what those teenagers want . All the UX talk disguises the harder truth about Millennials which is that they got sideswiped by the Global Financial Crisis and are saddled with student debt and hobbled by a weak job market. In short, its the fees stupid! 

At the other end of the age barbell, pensioners got sideswiped by prolonged ZIRP/NIRP and they don’t buy the idea that they should take on a lot more risk, so they get out their bifocals to look hard at the small print showing the fees. They will adopt the same services as the Millennials if they deliver better Fee Adjusted Return On Capital (FAROC). 

Millennials and Baby Boomers agree on one thing – It’s the Fees Stupid!

UX design and mobile technology is the essential tool that abstracts complexity to make a service easy to use, but ease of use is not the end objective – the objective is lower cost delivery to enable lower fees. 

Whether the fees are for ATMs or Fund AUM or Overdrafts or whatever, we are in the cheap decade (or two). Cheap wins. That is a very uncomfortable fact if you sell expensive products/services. Grasping that fact is tough for both FinServ (incumbent Financial Services firms) and Fintech startups, because the low fees do not support expensive marketing.

In this post, we focus on low fees for asset management. The same low fees trend is also hitting consumer banking, but that is another story.

Low fees leads to a marketing challenge

In ye olden days, marketing a fund was easy. You charged high fees and paid intermediaries a big chunk of those fees to gather assets.

When your fees are a few Basis Points, the intermediaries cannot make enough money. So you look at selling direct using digital technology. After all, Facebook and other free social media services did this and did not spend a dime on advertising. So why do we see so many ads for B2C Fintech startups? The answer is simple – there is a friction chasm between free and cheap (even very, very cheap). Consumers will adopt a new free service easily when the only cost is a bit of their time, but as soon as the service asks for money (even a very, very small sum of money) the consumer hesitates and that leads to much lower conversion and much higher CAC. You need a trusted brand to get people to entrust their hard earned money and creating a trusted brand costs time and money – lots and lots of time and money.

Of course there is a spectrum of solutions for B2C Fintech marketing but the simple reality is – it ain’t easy and it needs deep pockets.

So Fintech looks to partner with FinServ – in short, B2B2C. This can be a good strategy as long as their is realistic thinking on both sides (a subject we explore in this post).

The simple reason you cannot beat Vanguard on fees

The asset management business has been selling expensive for a long time. The pitch has been that Hedge Funds are better than Mutual Funds which are better than Index Funds and Private Equity is better than Public Equity – in short, the more expensive the better.  Given the necessary budget, customers will always prefer the more expensive car because there is kudos as well as utility, but it does not work that way with money. Customers might get kudos in the country club for using Hedge Funds and Private Banks and Private Equity, but Fee Adjusted Return on Capital (FAROC) is what enables customers to keep paying those country club fees.

Millennials with tiny sums to invest are going to low fees. So are middle class Baby Boomer retirees searching for yield.  In between, there are a lot of folks who will retire with much less money because those entrusted to look after their pensions paid a lot of fees to fancy asset management businesses (see this story about Ohio) and those pension managers will get told not to do this by regulators. Even Warren Buffet is advising his heirs to invest via index funds.

Vanguard has been singing this tune for 40 years.

John Bogle established the first Index fund in 1976 and initially raised $11 million. Vanguard now manages approximately $3,400 billion in assets, dwarfing the number two Index player, BlackRock, with about $451 billion in Index assets and making the leading Robo Advisers with $2 billion to $5 billon look like they have an impossible catch up job.

The VC funded model of innovation does not allow for 40 years – VC GPs need to get liquidity within 10 years. One can argue that the startups can move faster now because 40 years of Vanguard singing this tune has got the message across and so consumers are receptive to low fees. Yes, they are and the conjunction with a relatively impoverished Millennial generation and Baby Boomer retirees starved of income by ZIRP/NIRP, makes the message even more attractive.

There is nothing wrong with the low fees message and value proposition. It is delivering on that value proposition and making a profit on that delivery that is the challenge.

Delivering low fees is a volume game and Vanguard is winning that volume game by a big margin. The more volume they get, the lower their fees will become, because they have no shareholders to please and it is almost zero incremental unit cost. I would not want to compete against that. It is worse than competing against Saudi Arabia as an oil producer.

The puck is going to Low Cost Alpha and Absolute Returns

Every trend that crosses to the mainstream leads to opportunity opening up elsewhere. As passive investing goes mainstream, the opportunities for active stock pickers gets better. It is simple supply and demand. Fewer stock pickers leads to more inefficient markets and that means bigger opportunities for few remaining stock pickers.

(I am using the term stock picker loosely, it could be any asset class and could be short as well as long).

It is still a Fee Adjusted Return on Capital (FAROC) game. It is just that the Return is a bit higher and the fees are a bit higher.

Traditionally this has been a game for Hedge Funds i.e. selling a high fees + high returns proposition. This is where the new follower model of Invest Then Gather Assets  is replacing the traditional model of Gather Assets Then Invest and that model allows for lower fees. In this post, we look at how this is impacting the high fees VC business, but it also applies to what we now call Hedge Funds (which invest in every style, the only common factor being the compensation model).

Hedge Funds used to mean hedging i.e. going against the market trend to ensure good absolute returns uncorrelated with the market. Sophisticated investors use these techniques, using quant based risk management. This is now being democratised by what we call Robo Adviser 2.0 startups. The simple mission is to lose less when the market declines so that your absolute return (not tied to an Index) is good. Fees is the focus of the democratisation. The end game is the same – Fee Adjusted Return on Capital (FAROC).

Daily Fintech Advisers provides strategic consulting to organizations with business and investment interests in Fintech & operates the Fintech Genome P2P Knowledge platform.

We look at biggest Fintech VC deals of 2016 to see where the InsurTech puck is going


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We looked at the 30 biggest VC deals in Fintech for 2016 (courtesy of CB Insights Pulse of Fintech Report) to see where the InsurTech puck is going to. The answer is blindingly obvious when you look at the 3 out of 30 that we tagged as primarily Insurance focused:

  • Oscar Health
  • Clover Health
  • Bright Health


Yes, big VC money is being invested to fix Health Insurance

Only 3 out of 30 deals does not sound much (10%), but they are all big deals and the total invested in those 3 is $640m and that is nearly 50% of the total that went into North American deals (the amount going into Asia was nearly 2x that going into America, but that is another story). This amount of VC money is a good indicator of traction, so it is worth looking at what they are doing.

The reasons why VCs love investing in Health Insurance is pretty obvious – it is a massive market and very broken i.e. customers urgently need something better (ask any consumer what they think of Health Insurance or look at Net Promoter Scores). However it is very hard to fix. You can say that curing cancer is a big market and customers want something better but that does not mean it is easy to find a cure for cancer.

You cannot change Health Insurance in any significant way unless you can also change the Provider side. That is where VCs have an advantage. They can see that the innovation in digital health is for real. Funding for digital health is on a tear. So that will make innovation on the Health Insurance side more likely.

We already looked at Oscar Health, which scores as the biggest HealthTech round and fortunately Amy Radin has taken on the challenge of analysing the massive complexity of the US Health Insurance business in two posts (here and here).

Bright Health is interesting because this was an $80m Series A. That is a lot of money for a first institutional round. There are two VCs (NEA and Bessemer) and both are top tier and have deep pockets; one assumes big follow on rounds will be needed for them to have an impact on such a massive market with big entrenched incumbents. This is not a garage startup with some young techies with a Minimum Viable Product. The CEO, Bob Sheehy, is the the former CEO of United Healthcare. The best analysis is in Modern Healthcare magazine. This is a full stack regulated venture aiming to be an alternative to existing insurance companies.

Clover Health is also a full stack regulated insurance startup. Consumers can buy Health insurance today (as long as you are in New Jersey, Health insurance has to grow state by state). Their round was Series C, so they are more developed than Bright Health, but this is a market where a top team with plenty of capital can do well by learning from those who were early in the market – it is not necessarily a game with first mover’s advantage. Clover Health has an interesting focus on the doctor. The idea seems to be that if doctors have an easier time on the paperwork front the best doctors will want to work with Clover, which will benefit consumers.

Another full stack regulated insurance startup is ZoomCare, but there is no evidence of recent funding.

Daily Fintech Advisers provides strategic consulting to organizations with business and investment interests in Fintech & operates the Fintech Genome P2P Knowledge platform.

Fintech players up the ante on Comprehensive Credit Reporting

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In March 2014 the Australian Parliament rubber stamped new Credit reporting & Privacy Laws that enabled Credit Providers (CPs) and Credit Reporting Bureaus (CRBs) to commence voluntary Comprehensive Credit Reporting (CCR).

Australian lenders are well behind on CCR, much to the detriment of Australian borrowers, argue many fintech startups. Compared to the major four banks, fintech CPs suffer from large information asymmetries when it comes to assessing the credit risk of a potential customer. Many new lenders claim that if they were provided with access to repayment histories and a more detailed break down of the lending obligations a customer has outstanding, loan pricing could be more far more discretionary and potentially cheaper for a vast number of Australians.

A recent study by Veda tends to support this claim, showing a borrower’s creditworthiness increases when CCR data is available. Using the CCR data it holds on 24 percent of the retail Australian credit accounts it has on file, Veda’s study found the average score for an individual once CCR data was incorporated was materially higher than without.

So if CCR data is generally positive for both sides of the lending/borrowing equation, why is the Australian financial sector dragging its feet? And why is it so hard to work out what lenders are participating in CCR? Surely this is a competitive advantage for a financial institution and a benefit they can offer their account holders? Most likely because this stranglehold on customer data is one competitive moat incumbent financial institutions are relying heavily on going forward.

And it certainly is a deep and powerful moat at that. For no matter how slick and clever the delivery of your lending product is, if CRB data is a key input into whether or not you on-board a customer, then you’ll always be at the mercy of a competitor with better overall data they can use in conjunction with a credit score. Especially a competitor like a bank who holds the vast proportion of data points that make up the proposed CCR framework and is no doubt already leveraging them to their full advantage.

While many lenders are innovative at the front-end, it’s hard to be truly innovative at the back-end (where credit assessment takes place) when data isn’t readily available.  A few brave players overseas have tried to disrupt this thinking by doing away with traditional CRB scores altogether. SoFi is one such fintech lender. It’s yet to be seen how this will play out in the long term.

Government intervention

Australia’s 2014 Financial System Inquiry concurs with the broader fintech industry view that the benefits of CCR far outweigh the potential negatives often touted by CCR detractors. Recommendation 20 of its comprehensive report stated the Australian Government should:

Support industry efforts to expand credit data sharing under the new voluntary comprehensive credit reporting regime. If, over time, participation is inadequate, Government should consider legislating mandatory participation.

In 2015, the Government’s response to the inquiry’s recommendation was relatively lacklustre, stating:

The Government agrees to support industry efforts to implement the CCR regime, but will not legislate for mandatory participation at this stage. The CCR regime has been in place for a little over a year and authorised deposit-taking institutions are still in the process of working to participate in the regime.

It has now been a solid two years plus since the new legislation came into effect. Given the opaqueness of CCR implementation across the lending sector, it is unclear how effective the call for voluntary participation has been.

Ratesetter is one fintech lender who has put its money where its data is. In December of last year it claimed it was, “the first Australian lender to fully implement Comprehensive Credit Reporting (CCR) data sharing with Veda, Australia’s leading credit bureau.” Obviously if fintech lenders want the industry to take steps towards CCR, then leading the charge is vital.

Consumers are slowly waking up to the fact that creditworthiness can be a powerful negotiating tool with a lender. A consumer led, bottom up approach may indeed help fan the flames for faster CCR implementation by the industry. Pre-election, the Labor Party campaigned on driving mandatory CCR. If it keeps the heat on for a Royal Commission into the banking sector then this byproduct issue may get some national attention.

Daily Fintech Advisers provides strategic consulting to organizations with business and investment interests in Fintech. Jessica Ellerm is a thought leader specializing in Small Business.