The Disruption of the Prudential Regulatory Framework

Abstract

This article first explores how the prudential regulatory framework may be drastically changed as a result of the adoption of regtech and suptech innovations. The adoption of a shared data architecture, whereby the regulator is provided with seamless access to the accounts of regulated firms, may result in the development of a centralized approach to regulatory modelling, thus bypassing the existing partition between internal models and standardized approaches. Secondly, this article discusses how, thanks to the adoption of advanced predictive analytics, non-bank fintech lenders can gain insights into borrowers’ creditworthiness irrespective of banks’ control over traditional sources of information for credit scoring. This, though, may give rise to a new type of strategic gaming, this time by borrowers keen to maximize their chances of being granted a loan. In any case, preventing banks from adopting these new methods for the purpose of regulatory modelling might weaken their competitiveness. Thirdly, this article explores whether the transition to a centralized approach for credit risk management would conflate the distinction between microprudential and macroprudential interventions, in particular with respect to the countercyclical macroprudential policy. Finally, the article argues that non-bank (fintech) firms could be persuaded to coalesce behind endorsement of the new regulatory shared data platform in return for the support from the central bank. In this way, the regulatory perimeter could be extended in order to steer the adoption of financial innovations in a manner that benefits society overall.