Following a post on Linkedin last week, we have been asked about other interviews conducted by USA Today with interviewees. 

Being respectful of USA Today's copyright, we have only included a limited selection of articles, interviews and links below. Click on the images below to read in a larger format. 

The publication was released on Wednesday 28th June 2023.

Full interview by USA Today with Brian Fahey of MyComplianceOffice (MCO) online.  MCO appears on both the Fintech Ireland Map and the RegTech Ireland Map.

• Interview with Aidan Finn, CEO of Binarii Labs, Ireland
• Interview with Eoin Hinchy, Co-Founder and CEO, Tines

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The Minister for Finance, Michael McGrath TD, has today (19 April 2024) published a Mapping Report on the development of a National Financial Literacy Strategy in Ireland.

1. Financial literacy and education is an important part of financial consumer protection. Financial literacy covers people’s awareness, behaviour, knowledge, attitudes and skills in relation to money and is an important skill that everyone should have throughout their lives.
2. This report collates the extent of the current provision, across many organisations, of financial education in Ireland, and provides evidence, analysis and recommendations for the next stage of the design and development of a national strategy.
3. On the basis of extensive stakeholder engagement to date, including responses to a stakeholder survey issued in August 2023, this report describes the various bodies currently involved in delivering financial education in Ireland. It also sets out potential gaps and themes to be addressed in a financial literacy strategy and stakeholder expectations of that strategy.

Where and how is fintech referred to in the Mapping Report? 

Fintech referenced in the National Financial Literacy Strategy Mapping Report?

• "This is in addition to emerging risks with non-bank lending, Fintech, and climate change" (Hmm - Fintech is a risk?)

 

• "In recent years, the banking landscape in Ireland has changed significantly. According to the 2023 Consumer Banking Sentiment Survey15 , published by the Department of Finance in September 2023, while the two pillar banks continue to dominate the market in terms of market share of current accounts held, the survey results show that the use of ‘fintech’ (which includes a growing use of apps on smartphones and contactless payments by customers of traditional banks) has increased as has a rise in the market share of “digital only” banking providers, such as Revolut."

 

• "In terms of FinTech providers, the Survey results show that the top features of such providers for consumers are instant money transfer, free banking and a great/user-friendly mobile app. This is followed by splitting bills, spending information, foreign exchange and saving vault, while investment opportunities are the least important. Switching of banking products is very low in Ireland with many citing a general perception of it being difficult to switch, but general inertia being the most prominent reason."

 

• "The use of ‘fintech’, which includes a growing use of apps on smartphones and contactless payments by customers of traditional banks, has increased, as has a rise in the market share of “digital only” banking providers." 

 

• "One of the priority themes of the strategy is ‘Fintech & Digital Finance’. Under this theme, recent Ireland for Finance Action Plans included actions on financial literacy in order to support the public to adapt to the growth of fintech in retail activity. This involved the development of educational consumer resources by the CCPC in cooperation with the Department of Finance and the Central Bank"

See also https://www.gov.ie/en/press-release/23ccb-minister-mcgrath-publishes-mapping-report-on-the-development-of-a-financial-literacy-strategy-in-ireland/

This blog and others are joint efforts between Fintech Ireland and CompliReg.

First Published Tuesday 9th April 2024

Before we dive into the detail contained in the new (issued 9 April 2024) "Central Bank Expectations for Authorisation as a Payment Institution or Electronic Money Institution, or Registration as an Account Information Service Provider", a couple of things to note:
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1. the format, look and feel of the new webpage on the CBI's website;
2. the links from How We Regulate leading to the Authorisation Page, regardless if you clicked on Payments Institutions, Electronic Money Institutions, Small Electronic Money Institutions or Account Information Service Providers redirect you to the same page. That page ends in payment-authorisation.  Seems that from a pragmatic and practical stance, the CBI is getting ready for the merging of the e-money and payment services regimes under the current PSD3 legislative proposal;
3. although buried away at the bottom of the CBI's webpage, there is this very welcome statement about how long it may take to get authorised. "Experience suggests that it can take over 12 months for firms to provide all of the information necessary to enable a decision to be made" ;
4. each proposed Applicant must meet with the CBI before an Application is filed;
5. currently, there is no fee for submitting an Application (but there is of a course the separate Industry Funding Levy);
6. Dormancy Policy - the CBI's dormancy policy applies when an applicant has not provided an adequate response within 60 working days following the issuance of comments. A “Minded to Deem Withdrawn” letter is sent to the applicant after 50 working days of comments issued, notifying the applicant that it has 10 working days to provide all outstanding documentation or the application will be considered withdrawn. If the applicant does not respond within the 10 working days, a “Deemed Withdrawn” letter is sent and the application is not considered further by the CBI.    

Now that we have covered the burning issues on most applicants' mind, let's turn to what the CBI has set out in its new/updated "Expectations for Authorisation as a Payment Institution or Electronic Money Institution, or Registration as an Account Information Service Provider"

Referred to below is the Pre-Application Key Facts Document (“KFD”). Issued 9 April 2024. The purpose of the KFD is to provide sufficient detail to the CBI on an applicant's proposal for authorisation/registration.  It would normally consist of c.15-20 pages. It should be included in first batch of documents an Applicant reads.

As you will note from the above diagram, the authorisation assessment process consists of the following three stages:

1. Exploratory Stage. This consists of two phases:

• Initial meeting with the applicant firm; and
• Submission of required information (Key Information Check) and initial assessment;

2. Assessment Stage; and

3. Authorisation/Registration Decision Stage.

Phase 2 – Key Information Check and Initial Assessment

In addition to ensuring that all required documentation has been provided, this phase encompasses an initial assessment of the submission.

At the end of this phase, the Central Bank will notify the firm of the outcome which is either:

• Progression

The Central Bank considers that the application can progress to the Assessment Stage.  A specific case manager is assigned who will lead the assessment, and will be the primary point of contact for the applicant firm during the assessment process.

• Issues have been Identified Precluding Progression

The Central Bank considers that the application cannot progress to the Assessment Stage.  The applicant will be advised as to the rationale for not progressing and will be provided with an opportunity to address the issues identified (through written submissions and/or meetings).

During this stage the Central Bank conducts its assessment of the application. The Central Bank may request additional information, and detailed assessment meetings in relation to one or more areas of the application will be undertaken with the applicant. High quality applications with comprehensive and complete information and explanations reduce the need for additional information requests. Individuals proposed for certain key roles (Pre-Approval Controlled Function roles) may be invited for interview as part of the assessment of their Fitness and Probity for the role for which they are applying.

At the end of the assessment process, the Central Bank will notify the firm of the outcome of its assessment. There are two possible outcomes:
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• Positive Outcome (“Minded To Authorise/Register” letter)

Where the applicant firm has positively demonstrated that it will meet all authorisation/ registration requirements and expectations, the Central Bank will issue a “Minded to Authorise/Register” letter which will include, inter alia, requirements to be addressed prior to authorisation/registration, conditions to be addressed post-authorisation, and the proposed level of capital to be held (neither conditions nor capital are applicable to Account Information Service Providers).

or

• Negative Outcome (“Minded to Refuse” letter)

In the event that the Central Bank is not satisfied following the conclusion of its assessment phase that it can authorise/register the firm, a “Minded to Refuse” letter will be issued. This will include the reason(s) for the Central Bank’s proposed decision. The letter will specify the period within which the applicant firm may make submissions in writing in relation to the proposed refusal. Any submissions made will be considered by the Central Bank before making a decision on the matter.

This is the stage in which the final decision as to authorisation/registration is made. There are two possible outcomes:

• Positive Outcome (Letter Granting Authorisation/Registration)

Subject to the pre-authorisation/registration requirements in the “Minded to Authorise” letter having been addressed, no new adverse information coming to the Central Bank’s attention in the interim, and agreement from the applicant firm as to the proposed conditions and capital (not applicable to Account Information Service Providers), a letter granting authorisation/registration will be issued, and the applicant firm will then be able to commence its regulated activities.

or
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• Negative Outcome (Letter of Refusal)

Where a “Minded to Refuse” letter has issued, the Central Bank will review any submissions made by the applicant firm. If the Central Bank is still not satisfied to approve an application following the review of any submissions to a ‘Minded to Refuse’ letter, it will issue a letter of refusal.

​The 90 day Service Standard clock for the Assessment Stage will be paused where an information request has been issued to the applicant until such time as a satisfactory response has been provided. In addition, the clock can be switched off entirely where any of the following arise:
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• Another regulatory authority has to be contacted;
• Persons are subject to interview;
• Significant legal issues arise;
• Significant fitness and probity issues arise;
• The business model is complex or novel in nature;
• Significant changes to the business model, the applicant’s shareholder structure or other key aspects of an application arise during the review process, or where the application becomes dormant; or
• The CBI is minded to refuse an application.  

The CBI has Dormancy Policy.

This means that when an applicant has not provided an adequate response within 60 working days following the issuance of comments. A “Minded to Deem Withdrawn” letter is sent to the applicant after 50 working days of comments issued, notifying the applicant that it has 10 working days to provide all outstanding documentation or the application will be considered withdrawn. If the applicant does not respond within the 10 working days, a “Deemed Withdrawn” letter is sent and the application is not considered further by the Central Bank.

A) You need to read the following before you put pen to paper on the actual application documents:

Thereafter read through the relevant Application Form from the list below:

B) Then you will need to get to grips with:

• the Irish Anti-Money Laundering, Counter-Terrorist Financing and Financial Sanction regime
• the Qualifying Shareholders of Payment Institutions and Electronic Money Institutions requirements
• Pre-Approval Controlled Function Roles regime

The following forms should be completed:

1) Legal Persons/Entities

• Application for a Legal Person
  

2) Natural Persons

• Application for a Natural Person 

3) Executive Directors of Legal Persons/Entities

• Application for a Director of a Legal Person or Entity with a Qualifying Holding

​While the above forms are not required to be completed for Account Information Service Providers, the Central Bank will assess the suitability of all legal and natural persons with a qualifying holding.

For all Pre-Approval Controlled Function roles (typically board members, senior management, key function holders), the following should be completed:

• Fitness and Probity Individual Questionnaires

These should be submitted electronically via the Central Bank of Ireland Portal. Please note access to the Portal is only provided once an application has progressed to Stage 2 - Assessment Phase.

In addition to the foregoing documents accessible above, it would make sense for Applicants to read and become familiar with:

Service Standards

• ​Service Standards issued by the CBI

Is there a fee?
There is currently no fee for submitting an application. Once authorised, a firm is subject to an annual Industry Funding levy. For further information on the levy see here.

How do I submit the application?
Applications must be submitted via Kiteworks. Please contact applications@centralbank.ie to obtain access.

How long is the process expected to take?
The time taken to receive an authorisation decision is primarily dependent on the preparedness of an applicant firm to undertake the assessment process, and on the quality and timeliness of submissions. The Central Bank will, in accordance with relevant legislation complete its assessment within 3 months of the receipt of the application, or if the information is incomplete, within three months of receiving all of the information required for the Central Bank to make a decision on the application. Experience suggests that it can take over 12 months for firms to provide all of the information necessary to enable a decision to be made. See above for further information on Service Standards.

Is a Pre-Application meeting required before an Application can be submitted?
Yes, see above for details of the Initial Meeting which forms part of the Exploratory Stage.

What to do if I need more help?
For any authorisation related queries, you contact the Payments Authorisation Team (applications@centralbank.ie). If you have a query in relation to new technologies, email fintech@centralbank.ie.

If you need help and support too file your Application, talk to Peter Oakes at CompliReg via office@complireg.com.

If you are:

• a regulatory adviser in Ireland, including a consultant, a law firm, an accounting firm,
• an aspiring CEO/CFO/CCO etc looking to join a fintech seeking authorisation,
• especially a founder looking to get his/her fintech (#emoney institution, #payments institution or #crypto asset institution),
• company formation firms (i.e. TCSPs), or
• a recruiter in the fintech arena,

be very careful with what can only be described as middle-men sharks / charlatans operating in the industry claiming that they are based in Eastern Europe (inside and outside of the EU depending upon your questioning), that they have clients requiring authorisations in Ireland and that they need assistance from you with the business set-up and authorisation paperwork.

These sharks/charlatans mislead and lie about their credentials and their experience. It seems that Ireland has become the go to jurisdiction for firms wanting credible supervision and regulation and the sharks are trying to exploit this. However these middle-men/sharks have no idea of the regulatory regime in Europe, let alone Ireland, and a few pointed questions catch them out. Then the fun begins as you watch them squirm in their seats.

It is clear that these are the "fintech advisers" which have and continue to fail to get their clients authorised elsewhere (or are perhaps just a scam from the outset). With Ireland's reputation riding high, these sharks are bombarding me (and others) with poorly thought-out offers/plans. I think I receive at least four approaches a week from these bad actors.

Unusually, I took a call from one of these firms today. It was an advisory firm with a name I did not recognise. When the video feed went live it was the same person who approached me last year under a different corporate name. When he saw my face, the stuttering began. His lead generators had clearly let him down.

These firms try to hire/appoint people in Ireland and increase the amount of any fees guided upon and add a margin to 'their clients'. I asked if they disclose this margin to the underlying client? Together with that question, and a few other due diligence questions, they quickly got the message that Ireland doesn't welcome their type of business nor that of their clients.

I am pretty sure that no one in Ireland wants dodgy companies and UBOs accesses and thereby diminishing the value of Ireland's hard fought high levels of regulatory reputation, prudential soundness, conduct risk, consumer protection and anti-financial crime standards.

I am pretty sure that my peers in other EU Member States feel the same way.

​Sign up to our Newsletter here.​

• Need assistance with an emoney or payments authorisation or an account information service provider or virtual asset services provider registration application, check out Fintech Ireland and CompliReg's handy authorisation guides at https://fintechireland.com/fintech-authorisations.html.  

​Welcome Intuit Ireland Software Limited to the regulated fintech ecosytem in Ireland!  Its authorisation brings the pool of regulated fintech in Ireland to 69, comprised of:
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• 27 authorised electronic money institutions
• 21 payments institutions,
• 5 standalone open banking firms
• 11 virtual asset services providers and
• 5 crowdfunding services providers. 

​Intuit Ireland Software Limited registration is the 1st standalone open banking firm to be registered in Ireland since July 2022. 

The company was incorporated in Ireland just under one year ago on 6 April 2023. and was registered by the Central Bank of Ireland on 2 April 2024.

Ireland now has 16 entities which are authorised or registered to provide open banking services.  These include 5 standalone entities and a mix of 11 emoney and payment firms which can provide such services. 

As we said back on 20 February 2024, we are pretty sure that these numbers will continue to grow in 2024.

In what must have felt as extended St Patrick Day's long weekend for the Irish Decta Team, the company was authorised by the Central Bank of Ireland on Tuesday 19 March 2024 as an emoney institution. 

Intuit Ireland Software Limited  has been registered by the Central Bank of Ireland to provide payment services #8 (Account information services) ​

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• Sign up to our Newsletter here.
• Need assistance with an emoney or payments authorisation or an account information service provider or virtual asset services provider registration application, check out Fintech Ireland and CompliReg's handy authorisation guides at https://fintechireland.com/fintech-authorisations.html.