ICC Fintech Collaboration Guidelines
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As the digitalisation of trade gains traction, the initial concept of FinTech being a disruptor in the trade finance space has progressively matured into more of a partnership approach.
It is now widely recognized that working with and alongside technology providers will be paramount to any financial institution: global, regional, domestic or niche. Digital solutions have not only grown exponentially in the corporate to bank (or “C2B”) space but are as prevalent, if not more so, in the digital transformation of any bank’s operational processes delivering automated workflows, cost reductions whilst ensuring an optimal client experience.
FinTechs may come in many different shapes and sizes which can lead to several potential challenges. One of the challenges voiced by many technology providers operating in this space revolves around the different degrees of vendor management policies and practices implemented within each financial institution. The due diligence, or questionnaire, required by each individual financial institution can take up a considerable amount of resource to complete. Many FinTechs, especially new market entrants, may not have sufficient capacity to navigate these onboarding processes.
ICC’s consultations in this area have identified a lack of clearly defined standards in how financial institutions approach their vendor management practices – and, more importantly, the lengthy time it typically takes banks and FinTechs to be in a position to start a pilot, proof of concept, parallel run, let alone integrate any solution into production.
In this context, the paper sets out the common considerations and standards used under each of the three themes: (i) information security standards; (ii) commercial standards; and (iii) technology standards. The recommended standards come with either the explanation or the rationale behind them.
It is important to note that these standards are for reference purposes only, and may not be considered as legal recommendations or advice, nor should they be seen as necessarily all-inclusive. Recipients of such third-party services should have regard for their particular circumstances and seek their own independent financial, legal, tax and other relevant advice. The paper also includes a glossary as well as an annex detailing further the information security (“infosec”) standards.
The paper is intended as a living document and it is envisaged that the Commercialisation of eRules Working Group of the ICC Global Banking Commission will work with fellow industry partners to bring the necessary revisions in the future.
ICC expresses its thanks to Merlin Dowse (JP Morgan Chase), Jacco de Jong (Bolero) and Hariramchakraborthy Janakiraman (ANZ) for their leadership of this project.