Innovate Finance Industry Sandbox Report

A DEVELOPMENT IN OPEN INNOVATION
INDUSTRY SANDBOX CONSULTATION REPORT

Industry Sandboxes offer new opportunities for the financial
services sector to accelerate the use of shared knowledge, data
and technology in the process of developing innovative solutions
for customers. They can provide a forum for both engagement
and observation for startups, institutions, regulators, and wider
ecosystem players, in a safe ‘off-market’ environment.
The demand for Industry Sandboxes in the FinTech startup
community is strong, and institutions have signalled a recognition
of the benefits of open collaboration and digital marketplaces. There
is a broad range of applications for Industry Sandboxes across all
segments of the financial services ecosystem from catalogues of
existing open data resources, to virtual technology environments,
extending to forums for meetings and collaboration.
The adoption of open innovation principles, along with the use of
financial services reference architectures, accredited certification
standards, and the participation of regulators through Sandbox
Observer Forums, may likely be key factors in driving the widespread
use of Industry Sandboxes. This, in turn, can help accelerate taking
innovative solutions to customers, addressing industry-wide pain
points, and ultimately gain greater market adoption of FinTech.
The idea of using sandboxes in financial services in the UK was first
covered in the Government Office for Science 2015 report on FinTech
Futures. Since then, the Financial Conduct Authority (FCA) launched
a Regulatory Sandbox and invited the industry to collaborate in
consultation on Industry Sandboxes.
As at May 2017, over 16 jurisdictions have developed or are
developing a Regulatory Sandbox, putting regulators in the somewhat
unprecedented role of driving the adoption of innovative technologies
that deliver better consumer outcomes.
Industry Sandboxes give an opportunity to supplement regulatory
support of innovation and market competition by enabling industry
to self-organise and support regulatory efficiency in providing
a knowledge-sharing channel, a communication forum, and a
certification facility as part of the regulatory process.
It has been a privilege for Innovate Finance to Chair the Industry
Consultation. We worked with a Core Team to adopt an open and
collaborative approach, inviting the global financial services sector
to participate in surveys, design sprints, roundtables, and a formal
written consultation process.
FOREWORD
We have been overwhelmed by both the interest and response to
the Consultation – there are currently many open financial services
sandboxes in various stages of development, a sample of which has
been included in the Consultation findings. The findings offer the
reader the various ingredients required to create different variants of
Industry Sandboxes for the different jobs at hand.
We would like to thank the over 25 Consultation contributors and
acknowledge the over 160 participants in the consultation process
and the Consultation Core Team: the Steering Committee, the
Industry Advisory Board, the Technical Advisory Board, and the
Delivery Partners.
We would also like to thank the Financial Conduct Authority for
their support, and for supporting the use of innovative tools and
open collaboration in problem solving and design in arriving at the
Consultation findings.
We are confident that industry-led sandboxes will become a
significant platform for the acceleration of FinTech, by enabling more
and better open collaboration of market participants, and enabling
the earlier and more transparent identification of opportunities and
risks for all sandbox participants.
Lawrence Wintermeyer,
Chair,
Industry Sandbox Consultation
3

The UK FCA invited Innovate Finance to chair an industry
consultation on an industry-led sandbox for financial innovation.
The consultation was conducted between July 2016 and April 2017.
The Consultation found that Industry Sandboxes can be an
advancement in open innovation which develop, accelerate and
promote collaboration in the FinTech ecosystem.
Further, the consultation identified options for the design,
governance, funding, and regulatory treatment of Industry Sandbox
which would generate industry demand and meet feasibility
requirements.
Key Consultation Findings
In this consultation, an Industry Sandbox was defined as a shared
off-market development environment where developers of FinTech
solutions can access data, technologies, and services from different
providers in order to validate innovative ideas or address common
industry challenges.
Industry Sandboxes can be useful as a means to accelerate:
• Solution development by providing the whole of the FinTech
ecosystem with access to resources such as data, APIs, or
reference architectures which enable entrepreneurs to create
solutions that are additive and more readily integrated with the
existing technology stack;
• Complex problem solving by facilitating industry collaboration
on identifying and addressing complex shared consumer,
technological and regulatory challenges. Case studies of
such shared challenges include RegTech, digital identity, and
opening access to bank data;
• Regulatory efficiency by encouraging regulators to engage as
observers where industry can share knowledge early in the life
cycle of solution development.
Industry Sandbox Implementation Options
High level Industry Sandbox design principles and components
were developed by reviewing global practices and community
requirements.
• OPEN to the whole of the ecosystem on a voluntary
participation basis;
EXECUTIVE SUMMARY
• CONNECTED to shared testing environments and different
proprietary sandboxes;
• ACCESSIBLE via clear eligibility requirements and as low
barriers for participation as are economically feasible.
Industry Sandboxes participation ranges from:
• USERS of the sandbox resources;
• CONTRIBUTORS of the sandbox resources;
• SPONSORS of the sandbox;
• OBSERVERS of the sandbox outputs.
FinTech startups, financial institutions, technology and data
vendors, professional services firms, and venture capital funds
can all be users, contributors or sponsors of Industry Sandboxes
(or a combination of these roles). Regulators, academia and
professional membership bodies can participate as observers
or, where relevant, enablers in secretariat or research functions.
Industry Sandboxes could have the following components:
• Application assessment mechanism allowing users to self-
certify their eligibility for access, supported by case worker
review where necessary;
• Data sets of as wide and varied nature as feasible, including
market, product and consumer transactional data provided
data privacy standards are met. Such data can be synthetic,
historic, delayed or live market data, or anonymised
transactional data. Data architecture should allow for both
structured and unstructured data, with the ability to layer
analytics. Enabling access to sample sizes live data from
volunteer consumers was left to further review;
• Permissions for data access should be managed by the data
provider, while the Industry Sandbox develops a registry of
available data assets and collects meta-data on their usage;
• Reference architectures providing users with a set of domain-
specific artefacts, design patterns and terminology that
describe successful operational architectures, thus facilitating
multiple parties coming together to interoperate and solve new
problems at a business and technical level;
4

• Product Certification providing industry-level assurance that
solutions tested in the sandbox confirm to existing national
or international industry standards, best practices defined by
competent bodies; or emerging standards agreed at sandbox
level. Certification should be voluntary, time-bound, transparent,
and reflective of the product maturity;
• Showcase space allowing solutions tested in the sandbox to be
easily and digitally accessible by observers anywhere;
• Advisory space connecting sandbox users with interested
providers of professional service advice, particularly with regard
to regulatory compliance and readiness to integrate with legacy
systems;
• Analytics and audit tools allowing understanding and
transparency of how sandbox assets are being used;
• Participants’ Forums providing a dedicated communication,
collaboration and feedback channel for each participant type.
Forums can be both digital platforms and physical meetings.
Industry Sandboxes could engage with regulators in order to:
• ENGAGE in curated dialogue with sandbox participants;
• REVIEW Industry Sandbox tests in applications to
regulatory sandboxes;
• TEST RegTech solutions for regulators;
• FEEDBACK into policy development.
Industry Sandbox could have simple and flexible governance
structure providing for neutrality, robust management of the rights
and obligations of participants, and compliance. They would be set
up as non-for-profit structures.
Industry Sandboxes could be funded through a combination
of subscriptions, sponsorship and benevolent funding. Their
cost would vary significantly based on the sophistication of the
environment constructed.
Implementation Choices
Based on the identified design and governance requirements,
an Industry Sandbox can be as simple as a catalogue of existing
open datasets or APIs or as complex as a fully fledged digital
platform for managing access to market and institutional data and
conducting collaborative research and development. An Industry
Sandbox could also be generic or dedicated to a specific industry
challenge.
Implementation Choices would vary between organisations taking
an Industry Sandbox forward.
CONSULTATION
CONSULTATION OVERVIEW
STAGE 1
CONSULTATION
SCOPE
APRIL - MAY ‘16 • The UK FCA invites Innovate Finance
to chair an Industry Sandbox Consultation
• Consultation Steering Committee formed
STAGE 2
INDUSTRY
INPUT
JULY ‘16 - MARCH ’17 • Industry - wide survey
• 2 Design sessions
• Stakeholder mapping
• Global best practices review
• Formal Call for Input issued
STAGE 3
CONSULTATION
REPORT
MAY ‘17
CONSULTATION FINDINGS
INDUSTRY SANDBOXES...
...CAN ACCELERATE
SOLUTION
DEVELOPMENT
INDUSTRY - WIDE
PROBLEM SOLVING
REGULATORY
EFFICIENCY
...SHOULD BE
OPEN CONNECTED ACCESSIBLE
...CAN ENGAGE REGULATORS TO
SHARE KNOWLEDGE OBSERVE
OUTPUT
TEST
REGTECH
INFORM
POLICY
DESIGN
COMPONENTS
APPLICATION
ASSESMENT
DATA
PERMISSIONS
REFERENCE
ARCHITECTURES
CERTIFICATION
SHOWCASE
SPACE
ADVISORY
SPACE
ANALYTICS
AND AUDIT
PARTICIPANTS’
FORUMS
ROLES & STAKEHOLDERS
USER CONTRIBUTOR SPONSOR OBSERVER
FINANCIAL
INSTITUTIONS
TECH &
DATA VENDORS
STARTUPS
VCs
PROFESSIONAL
SERVICES
REGULATORS
32
Contributors
170+
Participants
Use Cases
15
Scribes by:
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TABLE OF
CONTENTS
1 THE INDUSTRY SANDBOX CONSULTATION: ORIGIN AND CONTEXT 7
1.1 Government Office for Science Report on FinTech Futures 8
1.2 FCA Regulatory Sandbox Consultation 8
1.3 Innovate Finance Member Input 8
1.4 Industry Sandbox Consultation Process 8
1.5 Building on Lessons from Open Source and Open Innovation 9
1.6 Landscape: Financial Services Sandboxes and API Marketplaces 10
2. KEY FINDINGS ON THE ROLE OF AN INDUSTRY SANDBOX 11
2.1 Addressing Cost and Inefficiency in Validating Innovative Solutions 12
2.2 Addressing Cost and Inefficiency in Developing Collaborations 12
2.3 Supporting Efficiency in Compliance and Regulatory Engagement 13
3. INDUSTRY USE CASES 14
3.1 Use Cases: Stakeholding Groups 15
3.2 Use Cases: Wicked Industry Problems 20
4. IMPLEMENTATION OPTIONS 25
4.1 Design Principles 26
4.2 Participant Types 26
4.3 Eligibility Requirements 27
4.4 Design Components 28
4.5 Legal and Governance Framework 33
4.6 Funding Model 36
4.7 Sandbox Participant Roles 37
5 IMPLEMENTATION CHOICES 40
5.1 Industry Sandbox Catalogue 41
5.2 Industry Sandbox for Wicked Industry Problems 41
5.3 Fully Fledged Industry Sandbox 41
6 NEXT STEPS 42
6.1 Umbrella Sandbox 42
6.2 Access to Live Customer Data 42
6.3 Developing an Industry Sandbox 42
ANNEXES 43
ACKNOWLEDGEMENTS 64
CONSULTATION TEAM 67
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Software developers have relied on sandboxes (an isolated testing environment) to test solutions
for many years. Most financial services institutions or technology providers already have their own
proprietary sandboxes.
Much rarer in financial services are shared sandboxes, or similarly collaborative research and
development environments. Learnings in open innovation are mostly derived from the industry’s
experience with accelerators and other forms of innovation labs.
Over the past two years, development of sandboxes available to all FinTech players has been largely
focused on Regulatory Sandboxes, which are being established by regulators across 16 jurisdictions,
led by the FCA's first-of-a-kind Regulatory Sandbox.
Unlike a Regulatory Sandbox, an Industry Sandbox would be developed, operated and owned by
industry. It would support the testing of solutions before they reach a market, regardless of whether
these solutions need to be regulated. It would not give access to any form of regulatory relief.
CONSULTATION
ORIGIN AND CONTEXT
7

1.3 INNOVATE FINANCE MEMBER INPUT
Separately, in end-2015 / early-2016 Innovate Finance received
feedback from its members (predominantly from the start up
membership segment) that a shared sandbox would support their
innovation journeys.
The feedback was sufficiently consistent for Innovate Finance to
develop the proposal that a membership sandbox environment would
need to address these four objectives:
a. Product development- by giving access to infrastructure,
such as payments systems or core banking platforms, using
a development environment and institutional partnerships e.g.
preferred supplier lists;
b. Product showcase- by providing a curated marketing space for
proofs of concept ("POC") which could support with attracting
funding or customers;
c. Product regulation– by assessing compliance and readiness
for FCA authorisation and, if possible, streamlining progression
towards applying for authorisation; and
d. Industry interoperability- by providing an environment where
developers could explore industry challenges and use cases for
emerging technologies, standards and best practices linked to
driving adoption and interoperability of new solutions across the
industry.
The Innovate Finance Member Sandboxes Proposal is Available in
Annex 2.
1.4 INDUSTRY SANDBOX CONSULTATION PROCESS
Innovate Finance responded to the FCA's Regulatory Sandbox Report
with feedback from its own members, and was subsequently invited to
chair the Industry Sandbox Consultation.
The scope of the Industry Sandbox Consultation is to:
a. ascertain the demand for industry-led sandbox initiatives and
develop a clearer idea of the solution(s) desired;
b. consider the feasibility of the identified sandbox solution(s),
taking into account governance, funding, commercial viability,
legality, provision of data, access to the sandbox, etc.;
c. in collaboration with the regulators, consider what (if any) role the
regulators could have in the implementation and operation of an
industry-led sandbox; and
d. if the working group establishes that there is a need and it is
feasible, develop one or more industry-led sandboxes.
1.1 GOVERNMENT OFFICE FOR SCIENCE REPORT ON
FINTECH FUTURES
The concept of an Industry Sandbox was first put forward in the UK by
the 2015 Government Office for Science report on FinTech Futures:
In fostering close collaboration between regulators,
institutions and FinTech companies, much might be learnt
from clinical trials (i.e. Phase III) structures. Specifically,
regulator monitored ‘sandboxes’ for innovators to
experiment with virtual environments or real people…a UK
project could be a vehicle for bringing together regulators,
key financial institutions, FinTech companies and the
large number of world-class UK academics working
on risk, software engineering and high-performance
computing (HPC). Such a project may take years and may
not succeed, however the spin-off in risk, analytics and
software research results are likely to be significant. 1
1.2 FCA REGULATORY SANDBOX CONSULTATION
In late 2015, the FCA took this concept a step further in its Regulatory
Sandbox Report, which introduced the launch of the FCA Regulatory
Sandbox, and included the concept of an “industry-led virtual
sandbox” as a recommendation to industry.
The Regulatory Sandbox Report text states:
A number of suggestions from that report have been taken forward
as sandbox design principles and components in the Industry
Sandbox Consultation, for example that a successful Industry
Sandbox should be an inclusive collaborative space open to all types
of FinTech ecosystem participants, and that regulators might have a
role as observers, in an Industry Sandbox.
A virtual sandbox could be introduced by industry. This would
be an environment to enable firms to test their solutions virtually
without entering the real market. A number of large firms already
have similar solutions for testing technologies but we understand
these operate separately from each other and with data only
from the owners of these sandboxes … we do not think it is
necessary for the FCA to set up the virtual sandbox; the industry
is well placed to set up a useful virtual testing environment
itself. However, we propose to facilitate collaboration between
interested parties and provide support when the virtual sandbox
is being developed. We will look into providing access to our
various systems and to some data sets (provided this does not
breach requirements from the Data Protection Act 1998 or section
348 of FSMA). We would be interested in having access to the
results of the virtual sandboxing activity.2
1 "FinTech futures: the UK as a world leader in financial technologies", Government Office for Science, published 18 March 2015.
2 Regulatory Sandbox Report, November 2015, FCA
8

1.5 BUILDING ON LESSONS FROM OPEN SOURCE AND
OPEN INNOVATION
The concept of an Industry Sandbox, or any other form of
collaborative prototyping environment, builds on the tradition of open
source software development, the use of open standards and the
practice of open innovation.
Lessons from Open Source
Open source development dates back to the 1980s with landmark
projects such as the GNU Project, followed by Linux and Netscape
among others. The open source community formed around the aim of
providing an operating system free from the constraints on usage or
issues on source code interoperability which can be the case with paid
software.
A more recent example of open source is software for creating private
and public clouds, such as OpenStack - open source software for
creating private and public clouds.
Open source projects have gained traction due to their ability to deliver
mass-scale security testing; quality analysis from a vast participatory
community; customisability in that developers can tailor software to
their own needs freely; and interoperability as open source software
is typically better at adhering to open standards than proprietary
software.
Being able to access core banking or payment platforms through
APIs is the de-facto open sourcing of banking services. Anyone
in the near future would be able to build their own bank through
apps, APIs and analytics.
2017 will be the year of open marketplaces and platforms.
Platforms support the rapid cycle deployment of microservices
into a financial marketplace. Those include apps, APIs, and
analytics that transform the back, middle, and front office
respectively. As the financial world is rapidly moving to open,
loosely coupled marketplaces, using old legacy technology could
impact on the agility needed by incumbents to compete.
- Chris Skinner, CEO, The Finanser Ltd
Acting as a secretariat, the Industry Sandbox Consultation Team
conducted the Industry Sandbox Consultation between July 2016 and
April 2017.
The FCA Invitation Letter to Innovate Finance is available in Annex 1.
The Consultation timeline, governance and inputs are detailed in
Annexes 3 to 7.
This process is underway in a number of FinTech markets, supported
by the opening up of bank data in the UK and EU or other seminal
open API projects such as India Stack.
Sandbox environments should be able to reflect this industry trend
by providing an open interoperable development environment where
innovators can pick and mix from a large suite of APIs in testing their
solutions.
Lessons from the open source and open standards community is
that while resources might be openly sharable, it is critical to have a
governance model which binds these processes together, prevents
abuse and (where necessary) identifies the common denominators
which form best practice.
Lessons from Open Innovation
In the footsteps of open source, open innovation is the idea that, in
a world of widely distributed knowledge, companies cannot afford
to rely entirely on their own research but should instead be open to
sourcing inventions from other companies or collaborating with them
to develop solutions.
The rise of FinTech incubators, accelerators, innovation labs,
hackathons and other similar innovation programmes demonstrates
the adoption of open innovation in financial services. Many well-
capitalised FinTech startups, particularly in the retail space, can trace
their origin to one of these programmes.
9

1.6 LANDSCAPE: FINANCIAL SERVICES SANDBOXES AND API MARKETPLACES
Boston FinTech Sandbox
Industry
NESTA Open up Challenge Sandbox
Industry
TISA Exchange
Industry
Level One Project
Industry
Industry
Open Stack India
Industry
Proprietary
Capital One DEVEXCHANGE
Sandbox
Proprietary
Salesforce Sandbox
Proprietary
Cisco DevNet Sandbox
Proprietary
Proprietary
RBS Bank of APIs
Proprietary
Starling Bank Sandbox
BBVA API Market
and Sandbox
Proprietary
Fidor Banking API
Proprietary
API Market Place
programmableweb
API Market Place
MashApe
API Market Place
Akana API Economy
Plaform
API Market Place
For Profit
Alphapack Sandbox
For Profit
TESOBE Open Bank Project
For ProfitGOV.UK Verify
Sandbox
Other
Other
We should be asking ourselves if the available open innovation
vehicles are sufficient to address how the FinTech industry is
evolving? What role could an Industry Sandbox play, alongside
the other sandboxes currently operating or which are planned?
The Financial Services industry is made up of a series of complex
and connected ecosystems, and in the last few years we have
seen significant changes, largely driven by regulatory imperatives
and technology advancement. We can see innovation occurring in
virtually every corner of the industry, with FinTech at the forefront
of this change, but at the same time FinTech is also maturing.
Initially FinTech's startups threatened to disintermediate and
replace some established services and traditional players in the
market, and whilst this is still a possibility there is increasingly a
mood of collaboration, not competition. Accelerating innovation
and the adoption of FinTech capabilities to the benefit of all
parties is important to drive digital transformation of the financial
system, providing greater safety, transparency, and efficiency.
- Keith Saxton, Chair of Financial Services and Payments
Programme, TechUK
Whilst individual innovation hubs and FinTech Accelerators
will continue to be of high value it is becoming obvious that
industry, regulators, and technology firms are looking for
ways to collaborate to drive even more rapid and meaningful
change to create value for the economy and society.
Advancement and adoption of new technologies is ultimately
dependent on shared, open standards, and perceived best
practice. The financial services industry could benefit
from a similar approach to address some of their most
pressing challenges, namely inefficient and costly middle
and back office processes, and high cost income ratios.
This is an area of significant opportunity for FinTechs and
existing financial firms to collaborate, and an Industry
Sandbox can be a catalyst and driver of this approach.
Detailed summary of reviewed sandboxes and API marketplaces is available in Annex 5.
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The Industry Sandbox Consultation's key objectives were: first, to establish if there is demand for one or
more Industry Sandboxes to support innovation in financial services and secondly, to provide insights
on the design, governance and funding components which could be adopted in meeting that demand.
While there are a range of views in the FinTech community of what sandboxes are understood to be
(Industry Sandboxes in particular), the feedback received converged on three key aspects of innovation
which an Industry Sandbox can contribute to:
i. addressing cost and inefficiency in validating innovative solutions;
ii. addressing cost and inefficiency in developing collaborations to solve shared industry problems;
and
iii. supporting efficiency in compliance and regulatory engagement.
KEY FINDINGS ON THE
ROLE OF AN INDUSTRY
SANDBOX
11

Industry Sandboxes Understanding
The Industry Sandbox Consultation aims to address all aspects of
an Industry Sandbox including the use of the term “sandbox” itself.
A sandbox is a testing environment that isolates new code or
experimentation from a production environment. Since an Industry
Sandbox is a shared environment where innovation can be tested in
isolation from live customers, then the term indeed resonates with
the policy objectives of undertaking the consultation.
The degree of familiarity with sandboxes and pre-production
testing, however, varied significantly between consultation
stakeholder groups and, in some instances, within stakeholder
groups. In particular, while the term is very familiar to the software
developer community, its adoption among strategy, marketing or
regulatory teams is relatively recent.
Survey results show that while nearly all respondents from tech
vendors either have used or have developed a sandbox environment,
this drops to a third of respondents from financial institutions and
a quarter of respondents from startups. The latter figures could
also be a signal of the availability of readily accessible sandboxes in
financial services at the time of the survey (Q4 2016).
Experience in relying on sandbox testing could be one factor which
drives higher demand for an Industry Sandbox within the tech
vendor community, as all tech vendors who considered that their
company could benefit from an Industry Sandbox had experience
with proprietary sandboxes.
However, survey data showed the reverse correlation within the
banking sector – respondents that have access to a proprietary
sandbox (although this sample size was small) were less convinced
that there is value to be gained from establishing an Industry
Sandbox.
The differing levels of understanding of the nature of Industry
Sandboxes had an impact on the ability of the consultation process
to assess how stakeholder views compare on the core consultation
questions. On a positive note, the consultation process itself has
increased understanding of the role which sandboxes can play.
2.1 ADDRESSING COST AND INEFFICIENCY IN
VALIDATING INNOVATIVE SOLUTIONS
Consultation responses have indicated that there is significant
friction, both in terms of resources required and length of process,
for startups and institutions in developing multiple POCs bilaterally.
Some respondents noted that while an increasing amount of POCs
are being developed in financial services, a disproportionately small
number of these are being taken into production – lower than might
be expected in a process of survival of the "fit-for-purpose".
Beyond the POC stage, both startups and buyers of innovative solutions
indicated that multiple and repetitive due diligence processes add
a significant amount of cost and friction to adopting solutions from
startup vendors.
In survey responses, both technology vendors and their target
institutional clients also pointed to friction in these processes.
The consultation feedback from the startup community indicated that
the journey from POC to live deployment could be fast tracked in three
ways:
• facilitating access to test assets;
• improving understanding of live production operating requirements
and developing common industry standards; and
• making vendor assessment more efficient.
Facilitating access to data, in particular, has been widely recognised
as expediting product development for FinTech solutions.
In addition to data, access to APIs and tools were the top assets
identified as in demand by the FinTech startup community.
In terms of vendor assessment, the Industry Sandbox Consultation
identified a market need for a form of transferable validation or
certification which might enable FinTech solution providers to expedite
current due diligence processes which are largely seen by the startup
community as prohibitively lengthy, cumbersome and not fit-for-
purpose.
2.2 ADDRESSING COST AND INEFFICIENCY IN
DEVELOPING COLLABORATIONS
Industry feedback, particularly through Design Sessions, has been that
an Industry Sandbox could be helpful in bringing participants together in
the resolution of shared challenges.
A collaborative research laboratory could enable the FinTech community
to more efficiently identify the shared industry-wide issues which
multiple actors are seeking to resolve. Subsequently, some of these
issues could be resolved through pooling resources to the benefit of all
participants.
An Industry Sandbox could serve as a test-bed for, at the very least,
identifying and collaborating on understanding such industry issues in
a lean and inclusive way whilst allowing flexibility for responses to those
issues to be developed independently or collaboratively.
All Design Sessions conducted as part of this Consultation indicated
that identifying several such industry-wide issues would be a solid
foundation on which to develop an Industry Sandbox. We have termed
these "Wicked Industry Problems".
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Wicked Industry Problems are issues that a critical mass of industry
participants identify as significant or which could have implications
for the systemic resilience of an industry, transparency and/or
consumer outcomes.
Best practices from other industries, such as the pharmaceutical
industry, suggest that a "working group" structure can reduce costs
while advancing solutions by developing a consensus on what the
Wicked Industry Problems actually are, combined with pooling
resources to seek their resolution.
Wicked Industry Problems in the financial services industry most
commonly relate to regulatory or technology interoperability issues.
Ongoing regulatory changes in the post-2008 regulatory
environment have generated an unprecedented level of new
compliance requirements for the financial services industry.
According to industry research, global risk management and risk-
related regulatory compliance technology spending is to hit $72
billion in 2019, a 10% annual growth rate.
Technological advancements themselves can generate a need
for regulatory change, or at a minimum, a change in supervisory
approach. Compliance requirements could be efficiently managed
via innovative solutions. This is the premise of the increased
interest in RegTech, innovation in risk assessment and compliance
technology solutions, from industry and supervisory authorities
globally.
However, innovation to address regulatory change is facing a
set of adoption barriers.
The risk of adopting innovative solutions for compliance purposes
can be high as compliance is not an area which lends itself to
experimentation. Consequently, the level of due diligence and
scrutiny required to adopt a RegTech solution can be prohibitively
high for startups.
An Industry Sandbox environment could address these barriers.
Pooling resources in determining the use cases, technical asks,
implementation requirements and solution due diligence could
expedite product development and adoption.
An early view from the regulator on general interpretation of how
regulation may interact with a proposed approach as RegTech
solutions are being developed could give potential clients and
investors a degree of confidence necessary to solidify the UK as a
leader in taking RegTech solutions into production.
From a regulators’ perspective, ensuring transfer of knowledge and
early sight of products might be beneficial. If a RegTech solution
is going to be relied on across the industry then it increases the
potential for systemic risk and so it is important regulators have
early sight and can shape concerns.
WICKED INDUSTRY
PROBLEMS
2.3 SUPPORTING EFFICIENCY IN COMPLIANCE
AND REGULATORY ENGAGEMENT
In addition to validation at a business model and technology level,
FinTech innovation requires clear understanding of compliance
requirements and supervisory expectations. In FinTech, both a lack
of awareness of compliance requirements and a lack of clarity in
supervisory expectations have manifested themselves as barriers
to innovative solutions going into production.
The consultation process revealed that within the startup
community, understanding of the need for authorisation and
compliance requirements in local and foreign markets could
benefit from being accelerated. The professional services and, in
particular legal community are well positioned to play a part in this
process.
Where there is scope for differing interpretation of regulatory
requirements, early indication of a view from the relevant
regulators can be instrumental in product development as well as
in providing the level of certainty necessary for fundraising and
commercial partnerships.
A number of market and conduct regulators address this dynamic
by providing direct support to startups. An Industry Sandbox
could support regulators managing the volumes of direct support
requests by highlighting regulatory queries multiple firms face
while prototyping and providing forums to share such feedback.
A point raised repeatedly was the need for continuity between
regulatory teams – from those providing direct support to startups,
such as the FCA Innovation Hub, through authorisation and
supervision teams, to the relevant policy teams.
While many regulatory innovation teams are being set up as
hubs precisely with the view to share information more efficiently,
feedback from momentum FinTech startups is that both access
and continuity can be improved.
An Industry Sandbox could seek to support this process by
bringing relevant departments of a regulator in front of tangible
proofs of concept of innovative solutions.
13

INDUSTRY
USE CASES
In order to explore the potential roles for an Industry Sandbox, input was sought from representatives
from across the FinTech ecosystem. Their views are captured below to provide insights on the range
of perspectives to be accommodated. One part of the FinTech ecosystem may be reliant on sandbox
"benefits" which are readily available from other parts of the ecosystem – it is the very nature of this
exchange of contributions which could help an Industry Sandbox to create a fulcrum for innovation.
For some industry participants, the benefit of an Industry Sandbox may be direct, such as access
to data. For others, benefits may derive less directly but may be of material value, such as increased
engagement with innovations which could deliver business benefit or strengthening a country's position
as a leading global financial services hub, attracting talent and capital.
The success of an Industry Sandbox will depend on attracting a critical mass of participants offering a
range of positive contributions. Greater understanding of the factors which may motivate participation
is key. This consultation exercise has gathered views from across the industry on use cases for an
Industry Sandbox, (both in terms of their needs and potential industry-wide issues to solve) in order to
enhance that understanding, as outlined below.
14

3.1.1 A STARTUP VIEW: ONFIDO
Access to reliable, fast identity verification services and KYC/
AML checks is key in the FinTech space, from big bank players
to start up innovators. For Onfido-a startup that provides these
services – an Industry Sandbox has the potential to speed up
innovation and market access in a big way. To date, there has
been inertia around FinTech innovation and a reluctance to
invest in new solutions.
An Industry Sandbox will give impetus to collaborative problem-
solving in what has previously been a disjointed field, and do
so without exposing any parties to external risk. An Industry
Sandbox will provide an arena to share technical knowledge, the
freedom to innovate and the social buy-in that is required to see
FinTech more widely accepted and trusted. We are most excited
to envisage enhanced access to data sets, including identity
verification documents with which to train AI models.
We are keen to play a part in defining what data is of most
use to the FinTech startup community. Regulator input
will be key in establishing how data can be handled in an
Industry Sandbox. One important outcome for us would be
the recognition that new solutions can perform as well, if not
better than existing solutions. That an Industry Sandbox will
comprise representatives from several different market sectors
is therefore particularly valuable, as mutually agreed upon
outcomes will have industry-wide validation before “go live”.
An Industry Sandbox “certification capability” could alleviate
the current due diligence burden that accompanies any
engagement with regulated entities such as banks. Certification
could take away the current stark choice that startups can often
have: use resources to innovate, or to project manage extensive
due diligence on a customer by customer basis. For example,
it is currently not uncommon for a single trial to be preceded
by pages of client-specific RFI questions, and followed by
hundreds of audit questions. It will be exciting to work with
Industry Sandbox Consultation stakeholders to define exactly
what form that certification could take.
3.1.2 A SCALEUP VIEW: BRUCE DAVIES, DIRECTOR, UK CROWDFUNDING ASSOCIATION
In the UK, the alternative finance industry paved the way
for FinTech in a number of ways-most notably in attracting
investment capital, rapidly raising a user base, securing
supportive legislative change and proactively engaging with the
regulator to secure a dedicated regime.
As peer-to-peer and crowdfunding platforms scale and,
invariably, make pivots in their business models and product
suites, the need to test innovations and secure new regulatory
permissions remains prominent. In this context, the need
for a coordinated regulatory approach - across innovation
departments, authorisation and supervision teams as well as
those responsible for policy changes is clear.
In particular, the alternative finance industry can benefit from a
neutral space where business model or product changes can
be discussed with the regulator in a curated manner before any
formal submissions are made. The focus of such discussion
should be the most effective regulatory approach to secure
a demonstrable consumer benefit, with a focus on outcome
analysis.
A sandbox environment can support such dialogue as well as
facilitate outcome projections in a prototyping stage.
3.1. USE CASES:
STAKEHOLDER GROUPS
15

The BBA is the leading trade association for the UK banking
sector with 200 member banks headquartered in over 50
countries with operations in 180 jurisdictions worldwide.
The BBA’s members participated, both individually and at
industry level, throughout the Industry Sandbox Consultation
process to determine the feasibility of an Industry Sandbox. The
BBA welcomes the opportunity to support the growth of the
UK’s FinTech sector and note that any models which encourage
increased competition and technology innovation ultimately
benefit our customers.
The BBA focused on four key points in their response to the
Industry Sandbox Call for Input:
1. Importance of voluntary participation: in order to be
successful in the long term an Industry Sandbox would need to
be a market-led solution with participation and funding achieved
on a strictly voluntary basis. The appetite of firms varies based
on internal factors including the status of their existing work on
innovation, the location of their research facilities and the funding
allocated to testing activities. The BBA anticipates a varying level
of participation amongst its member banks.
2. Avoidance of duplication with ongoing data-related
initiatives: an Industry Sandbox is likely to achieve the highest
level of participation if it focuses on adding value beyond what
can be achieved by in-house or existing industry-led accelerators
and regulatory sandboxes. The involvement of the regulator,
subject to the specific details, could be a key differentiator in this
area, as could the focus on industry wide (‘wicked’) problems.
Where necessary, the BBA encourages the use of synthetic and
publically available market data as an initial case for an Industry
Sandbox. The use of customer data, even in an anonymised
format would be prohibitively difficult and costly to include in an
early form of an Industry Sandbox.
Where BBA members do see potential is in the role of an Industry
Sandbox as a facilitator of experimentation between large
institutions and startups or between multiple firms addressing
a shared problem. Such collaboration can be frustrated by the
contractual and legal questions surrounding shared work such as
IP or, often, data protection/sharing concerns. The establishment
of a forum to address these issues, or even the establishment of
a venue for engaging in such questions, could benefit innovation
in the industry overall.
3. The need for further clarity of funding requirements and
other requirements: The view of the BBA’s members is that in the
short term, a low-cost, low-impact model is the most appropriate
starting point. One important consideration is the source of this
funding within the industry. In the case of the BBA’s members,
funding for participation will come from existing innovation
budgets. This means that resources for an Industry Sandbox
are only justifiable to the extent that they add value beyond
what could be achieved through increased funding to existing
accelerators/incubators or through in-house testing.
4. The role of the regulator: The Call for Input correctly identified
the potential for an Industry Sandbox to serve as a place
for an exchange of information related to new technologies
under development or consideration and as a way to provide
engagement early in a product lifecycle. These would be helpful
developments in the effort to industrialise the process of
technology adoption in financial services. BBA members are also
clear that this should not be the sole source of education and
information exchange between the regulator and industry.
The full BBA response to the Industry Sandbox Call for Input is
available in Annex 6.
3.1.3 A UK BANKING SECTOR VIEW: BRITISH BANKERS'
ASSOCIATION (BBA) MEMBERS FEEDBACK
16

3.1.4 A CHALLENGER BANK VIEW: FIDOR
3.1.5 A PROFESSIONAL ADVISOR VIEW: RACHEL KENT,
GLOBAL HEAD OF FINANCIAL INSTITUTIONS SECTOR, HOGAN LOVELLS
Fidor is known as a FinTech friendly digital bank. We did bet
on API from our origin with the aim to make FinTech and bank
collaboration more effective. The ultimate objective is to create
an ecosystem that makes it easy for customers to manage
their money and engage with multiple FinTech from one single
place. As of March 2017, 45 FinTechs have successfully joined
the Fidor Finance Bay app store which helps FinTechs provide
their own services to Fidor Bank’s customers (currently in the
German and the UK markets with plans to expand globally).
Our API sandbox was made public and available to partners,
clients, developers and students from the early days. Key
objectives were to testify to the quality of the fidorOS platform
and most importantly to make collaboration with FinTechs
In a highly-regulated industry such as financial services,
understanding the regulatory context, and the optimum legal
structures for securing funding, is vital to enable innovation
to deliver viable and valuable solutions. This is an area where
an Industry Sandbox could have a very useful role to play and
benefit could derive from professional advisors' engagement.
For many FinTech startups, their inhouse resources are often
limited and focussed on proving the technical and commercial
imperatives of their solution so greater support is needed in
navigating regulation. Our experience from advising on a range
of FinTech solutions across the ecosystem and developing our
Regulatory Accelerator has shown that, whilst some solutions
will have unique characteristics which will need individual
analysis, there are ways to streamline the delivery of advice
needed on preliminary questions commonly raised by startups.
For incumbents, even with large legal teams, there could be
benefits from shared industry and regulatory insights on how
FinTech innovations could fit into the regulatory landscape.
By participating in an Industry Sandbox, professional services
firms can gain understanding of the commercial and technical
objectives which helps hone advice as well as increase their
engagement with the FinTech community.
through our sandbox much easier. The fidorOS API sandbox is
the perfect place for FinTechs to develop and test solutions in a
place that mimics a real live production environment. FinTechs
can freely test their solutions at their own pace, increase the
quality of their delivery using quality data and really know which
components can be integrated and licenced to Fidor.
Our API Sandbox plays an essential role in ensuring end-to-end
integration for seamless customer journeys. We strive to share
knowledge and co-innovate with industry peers, API sandbox
makes it possible to collaborate on a larger scale and truly
accelerate the advent of innovation.
Observations by regulators shared in an Industry Sandbox
could potentially reduce strain on their direct support functions,
as well as support professional services firms in guiding their
clients on areas reliant on interpretation of how guidelines
would apply to new developments. Early engagement with
potential FinTech solutions by professional services firms could
also help to highlight where a solution may fit with regulatory
policy objectives but would conflict with current regulatory
guidelines and encourage dialogue with regulators to evaluate
potential for removing technical obstacles.
Constructing a successful Industry Sandbox would be
underpinned by designing a legal and governance framework
which enables participants to collaborate to deliver agreed
objectives, establishing a robust matrix of carefully balanced
rights designed to allow it to evolve. In doing that we would
be following a path well-trodden in today's financial services
environment in which consortia play an increasing role, but
by introducing Industry Sandboxes the industry itself will be
innovating in collaboration by creating a new mechanism to
foster its success.
17

As longstanding providers of leading edge solutions to financial
institutions technology vendors we would look at the Industry
Sandbox initiative as a collaboration model with the FinTech
ecosystem where the use cases would fall into one of the
following 3 categories:
1. Stack Completion. A FinTech solution while solving a
specific set of industry use cases might also help fill
the missing piece in a vendor’s services stack thereby
accelerating their time-to-market. The Salesforce
ecosystem has proven that such partnerships can exist
and an Industry Sandbox would be able to extend that to
non-platform based modular solutions offered by other
technology vendors. An open industry platform would
enable both the entities to test and validate their fitment
without the concern of any breach of intellectual property.
2. Validation Services. A technology vendor might also
participate as a validator on behalf of its customer to
assess the state of readiness or fitment of a FinTech
solution. Besides fitment the technology vendor would
also review the provisioning of safeguards to contain any
consequences of failure and check overall security and
soundness of the solution. The vendor would bring in
knowledge of the customer’s legacy state of infrastructure
and help bring to light execution challenges in the
FinTech’s solution.
3. Wicked Industry Problems. Can an existing industry
problem be addressed by new or emerging technologies?
An Industry Sandbox could be a cost-effective way of
undertaking hypothesis testing towards industry problems
like KYC. Based on design and execution it could lead to
emergence of early stage consensus on standards and
protocols in the industry thereby fostering competition in
the industry. An area like regulatory reporting would greatly
benefit from early stage consensus on the data standards
and data sets required by regulators across jurisdictions.
As a data vendor, exposing sample content sets within
an externally available data sandbox would help facilitate
partnerships and other collaboration opportunities. If we
were also able to combine our content with additional 3rd
party data sets, through predicating these content sets on
Thomson Reuters entity masters (PermID’s), users of the
sandbox would be able to navigate an ocean of connected
data, increasing the value and quality of all content sets
hosted or accessible from within the system. This would
greatly accelerate the assessment of viable commercial
partnerships, help individuals and businesses identify the
exact content sets they need to license and potentially
provide data vendors an early access environment for
product testing purposes.
Although the Industry Sandbox is not proposing a Hosting
Environment, providing an ecosystem of content providers
and facilitating relationships (to enable e.g. the co-
mingling of content sets) between them is a highly valuable
proposition for both data vendors and their respective
customers.
At Augmentum, we like to get to build a relationship with
entrepreneurs as early as possible, often before they are
ready to raise finance, and where possible provide ongoing
feedback as we look to build a long-term relationship. The
businesses we invest in must stand out from the crowd
whether that be due to a unique or disruptive business
model, first mover advantage or by being best of breed.
A sandbox can help us make a better evaluation early in our
relationship with a company. It also can support our portfolio
companies in engaging with potential institutional clients
more effectively.
An Industry Sandbox, as an open collaboration platform for
product prototyping and pre-production testing, allows us
greater visibility to assess and access innovative ideas. In
many cases, this will reduce the uncertainty and risk that
can deter investors. One of the biggest barriers holding
back many innovative FinTech businesses is regulatory
complexity, anything that can appropriately reduce those
barriers will be welcomed.
3.1.6 A TECH VENDOR VIEW: INFOSYS
3.1.7 A DATA VENDOR VIEW:
THOMSON REUTERS
3.1.8 AN INVESTOR VIEW: TIM LEVENE,
MANAGING PARTNER, AUGMENTUM CAPITAL
18

As a philanthropic investment firm, Omidyar Network supports
entrepreneurs and their innovative ideas through impact
investing and philanthropic grants. Our hybrid model allows us
to partner with the most innovative changemakers, regardless
of whether they lead for–profit or nonprofit organisations.
We deploy patient capital to scale innovative solutions in
the marketplace, while our grants checkbook lets us expand
understanding and positively influence the environment around
it.
We advocate for a regulatory environment that supports
sustainable and responsible financial inclusion and work to
advance the financial sector as a whole. We believe that actors
in the financial ecosystem are interdependent. The work of
regulators can ease the path to market for new technologies,
and new technologies can advance the financial inclusion goals
of governments.
From this perspective, we believe that an Industry Sandbox can
add value by:
a. Facilitating better product assessment by innovators:
An Industry Sandbox can enable easier and cheaper
validation of product features and benefits in a live test
bed before going to market or entering a regulatory
sandbox. As more companies access testing resources,
their pipeline for FinTech investors can increase and
attract more investors.
b. Encouraging portfolio companies to test new ideas
faster: Having a designated testing platform can move
product development to pre-production testing faster. For
investors, this means economies of scale can be created
by opening up a testing environment to multiple portfolio
companies at once.
c. Gauging regulatory implications of a product: An
environment with coaching startups on their authorisation
requirements, screening for product compliance, and
curated early-stage conversations between entrepreneurs
and regulators could be a RegTech solution in itself, which
can drive efficiency in regulating FinTech and confidence
from an investor’s perspective.
Enabling ideas cross-pollination: An Industry Sandbox should
be a place to interact and share ideas with a wide variety of
stakeholders, which can spark a demonstration effect and
significantly accelerate market learning curve for participants.
With over 200 fintech/insurtech investments in
26 countries, including Credit Karma, Stripe, Grab,
RealtyShares and Simple (acquired by BBVA), CBInsights
recognises 500 Startups as the world’s most active early-
stage investor in the transformation of financial services
since 2012.
Our unique high-volume approach investing in, and
accelerating, both new financial services and enabling
technologies may substantially benefit from the creation of
an Industry Sandbox as proposed:
• Faster investment decisions and more investment:
Cost of compliance and regulatory uncertainty is a
key concern when we consider making investments in
early stage financial services companies. A program
that makes those costs/risks more transparent earlier
in startups’ lifecycle makes it easier for us to assess
a company and teams’ potential, possibly leading to
faster and more investment decisions.
• More collaborations between startups and incumbents: A
properly organised sandbox program can reduce the cost of
exploring collaborations, thereby increasing the likelihood
that startups we invest in can accelerate their growth by
partnering with incumbents. This can be achieved by both
giving startups access to institutional data or reference
architectures and by reducing regulatory uncertainty for
both startups and incumbents.
• Potential of alignment with other global sandboxes: As
an investor, we are not generally interested in investing in
companies that may have a relatively transparent go-to-
market in one country (UK) and a far less certain go-to-
market in other markets. A virtual platform giving our
portfolio companies access to global sandbox assets will
assist access to foreign markets, and a forum providing
transparency in regulatory approaches of other regulatory
bodies/sandboxes will help reduce the uncertainly around
regulatory impediments to global growth opportunities.
3.1.9 AN INVESTOR VIEW: KABIR KUMAR, HEAD OF POLICY
AND ECOSYSTEM BUILDING, OMIDYAR NETWORK
3.1.10 AN INVESTOR VIEW: MIKE SIGAL, PARTNER, 500 STARTUPS
19

Open Banking and Industry Sandboxes
PSD2 and the CMA Remedies open the door for a new cohort
of FinTech solutions which deliver customer services based on
transactional data previously only accessible by the account
provider. Whether these emerge as stand-alone FinTech products or
collaborations between third parties and retail banks, testing, viability
assessments and adjustments will be an integral part of the evolving
payments landscape. With a number of government and proprietary
initiatives already underway, an industry utility function could be
beneficial to ensure visibility and interoperability of the various testing
environments.
Industry could also consider making an anonymised set of
transactional data available for testing purposes on an on-going
basis, pooling resources in ensuring that access to this data is
appropriately managed and secured, and usage analysed.
An Example of Open Banking Sandbox in Spain
The Germany-based Open Bank Project (TESOBE) together with
Atmira, a Spanish Solution Integrator, organised the first PSD2
hackathon event in Madrid on June 11th - 12th 2016 as a way to bring
banks together, collaborate and engage with the Spanish FinTech
community and seek innovative ideas for a post-PSD2 world.
About 80 developers attended the event and developed seven
applications over the weekend. A panel of judges composed of
representative of the six largest banks including BBVA, Santander,
Banco Sabadell, Bankia, Banco Popular and Bankinter, chose three
winning teams - an account balancing service, an NFC payment
aggregator and a QR-code-based payment solution.
TESOBE provided its Open Bank Project sandbox. Importantly, all
data uploaded to the sandbox was test data, which was further
anonymised. TESOBE worked together with the banks and Atmira
to gather, anonymise and upload “localised” data. Data elements
developers had access to included: bank details; Customer Profiles &
Messages; Account information, balance and transaction history of
multiple bank accounts; Counterparties information.
Alongside data, the Sandbox technology includes tools to help
developers work faster.
The Open Bank Project sandbox, fed with Spanish test data, provided
the stepping stone on which the ideas transformed into concrete
prototypes. Its usage has sped-up development and provided a level-
playing field for participants to build their applications on.
The hackathon was a great opportunity to connect disparate parts of
the Spanish tech community in a new way.
Alignment with Open Banking Initiatives in the UK
In the UK, the Competitions Markets Authority (CMA) imposed remedies
on the nine largest financial institutions which it required to also be
in compliance with PSD2 following its review of competition in retail
banking.
The CME ordered the nine largest retail banks in the UK, to create the
Open Banking Implementation Entity and collaborate with it to deliver:
(1) Open Data APIs to enable access to bank products and reference
data, making available information on ATMs, Branches, Personal
Current Accounts, Business Current Accounts for SMEs & SME
Unsecured Lending and Commercial Credit Cards, by 31 March 2017 in
a standardised way; and (2) Read/Write API’s that were compliant with
PSD2, making available to authorised third parties the ability to initiate
payments and/or obtain transactional data from consumer & SME
accounts by January 2018.
As part of this mandate, the Implementation Entity is creating a
developer toolkit to assist FinTechs and ASPSPs in accessing the API’s
it has worked with the community in defining.
Also following a CMA remedy , NESTA launched a £5m Open Up
Challenge to encourage development of new banking services for small
and medium enterprises.
As part of the challenge, a screened and selected pool of 20
participants will have early-stage access to “Open Up Sandbox”,
containing anonymised UK banking transaction dataset and APIs
aligned with the open banking standard. The use of the sandbox will
help startups securely build and test innovation products to hit the
ground running in 2018 alongside the implementation of PSD2 and
Open Banking APIs.
3.2.1 OPEN BANKING
On 16 November 2015, the EU passed the Revised Directive on Payment
Services (PSD2), and gave member states two years to incorporate the
directive into laws and regulations.
In the post PSD2 payment ecosystem, there will be three new actors,
third-party providers (TPP), added to existing payment schemes between
payers and beneficiaries:
1. Account Servicing Payment Service Providers (ASPSPs)
2. Payment Initiation Service Providers
3. Account Information Service Providers.
Under PSD2, third parties authorised as any one of these types
of providers will have access to customer account, payment and
transaction data generated by account providers.
The new rules aim to promote pan-European competition in traditional
banking and digital innovations that maximise consumer benefits.
Amazing weekend seeing so much talent ready to invest their
free time in working hand in hand with random developers to
create new value to our customers in a Post-PSD2 ecosystem.
Open Bank Project Sandbox was just the perfect toolbox to make
it possible to develop end-to-end applications in less than 36
hours of work.
- Raul Lucas Alcaraz, BBVA Open APIs, Spain Country Manager
3.2 USE CASES:
WICKED INDUSTRY
PROBLEMS
20

Our Two Cents on an Industry Sandbox:
A view from Eric Mouilleron, Founder and CEO, Bankable
Bankable promotes “Banking as a Service” experimentations and
pilots with large financial institutions and global industry players.
We have been actively involved in promoting Industry Sandboxes in
the preparation of the PSD2. By providing banking and settlement
access into the Industry Sandbox, incumbent and challenger
banks can emulate relevant business cases in an industrial
experimentation with various FinTechs. An Industry Sandbox
provides an opportunity to test break-through innovation in a
controlled, nurturing environment where financial institutions and
startups can come together to discuss, develop, deliver, and share
experience – to provide the best financial products and services to
the end consumers.
We believe that an Industry Sandbox is complementary to a
financial institution’s in-house FinTech Lab. The Industry Sandbox
encourages financial institutions to be involved with relevant
FinTech(s) outside of their own innovation programmes enabling
them to vet startups that may have not been on their radar.
An Industry Sandbox could provide information on the global
industry happenings and brings together relevant players and
thought leaders in the ecosystem in one big space. This could also
enable financial institutions to maximise their capacity to anticipate
the impact of PSD2 on every industry player.
Thus, Bankable looks forward to welcoming incumbent and
challenger banks and other financial institutions in this initiative
which is much needed to drive innovation in financial services
today.
A view from Starling Bank
Starling bank is a licensed bank that has developed a feature rich
mobile current account. Concurrently, we have been building out
the Starling Marketplace, which enables users to easily search and
access the best financial products from across the ecosystem, all
from within their Starling account.
An Industry Sandbox essentially provides an off-market
development environment that mirrors the logic of the Startling
Marketplace by allowing innovators to build integrated solutions
which will eventually populate such marketplaces. This is an
essential part of finding and solving problems for customers using
FinTech. Such collaboration is essential for addressing the shared
challenges that face our ecosystem, with the vision of providing
users with access to the best products from across the market for
their specific needs, as well as the transparency necessary around
these options to make better financial decisions.
Part of the impetus for Open Banking regulation was the fact that
current banking products have complex fees and pricing models,
and as a result users are not able to easily compare services
and understand where they can get a better offer. The Starling
Marketplace strips away that complexity and enables users to
easily compare products from across the market so that they can
make better financial decisions about which products are right
for them. As a result, this gives customers the greatest amount
of choice in providers - so they are not just limited to traditional
rates and products, but can explore and compare options from
innovative new FinTech startups too.
This is a true marketplace model, and drives a network effects
platform - ie. the more consumers are on the platform, the
more the producers benefit, and the more producers are on the
platform, the more consumers benefit.
In conjunction with building out this Starling Marketplace, we
have launched our Developer Platform. The developer platform
enables third party developers and FinTech companies to easily
access and build on top of the Starling Bank APIs. As a result,
users can easily access these products and securely share their
data with them should they choose to do so. Integrating with the
Starling APIs is also the first step to making a product available in
the Starling Marketplace, if the FinTech company wants to do so.
We have been advocating PSD2 and the UK’s Open Banking
initiative as we believe this approach will transform the
competitive landscape and foster innovation in financial services.
In mid-April Starling Bank held its first Hackathon, making Starling
the first UK licensed bank to launch a public API in keeping
with the ambitions of PSD2 and the Open Banking initiative. At
this event, 25 developer teams created social and commercial
solutions to various different financial problems. We were able
to provide an environment where developers, supported by the
Starling engineers, could work with and test our public APIs, using
a small amount of their own data along with some synthesized
data sets. In the future, of course, apps will be able to use Starling
customer data (as long as the customer gives their permission).
We see the benefit of an Industry Sandbox as a place where both
banks and FinTech solution providers can come together. An
Industry Sandbox provides an environment and opportunity for
third parties to prototype before accessing a Regulatory Sandbox
or seeking authorisation.
The provision of an Industry Sandbox provides the opportunity
for collaboration in order to create, test and drive innovation in
financial services. This in turn supports increasing competition
with improved services and products for both commercial and
social good.
21

3.2.3 DIGITAL IDENTIFY:
A view from Jim Purves, GOV.UK Verify
GOV.UK Verify enables a UK citizen to verify their Identity to high
government standards for access to government services. These
standards align with the Joint Money Laundering Steering Group
requirements for identity verification. This will enable a citizen
to assert their digital identify to a regulated organisation which
can then be consumed as trustworthy. In Summer 2017, Verify is
planning to go into Beta with private sector organisations that have
identity assurance needs. In order to enable organisations to test
and learn about Verify prior to going into Beta, the Verify Sandbox
Environment was created. The key design principles were as follows:
• The sandbox will be provided by private sector organisations.
• GOV.UK Verify will define the standards which the sandbox
providers need to follow at a technical, operational and
governance level.
3.2.4 PRUDENTIAL RISK:
A view from Keith Saxton, Chair Financial
Services and Payments Programmes, techUK
FinTech innovations can have a significant impact on approaches
taken by the prudential regulators and central banks. The goal
to make the financial system more stable, resilient, efficient and
inclusive clearly depends on both understanding the impact
that FinTech innovations will deliver, as well as the dangers of
unintended consequences if not fully controlled. The ability to
improve their own capabilities from the use of these technologies
would also appear attractive.
Understanding the interconnectedness, concentrations and
‘health’ of the financial system from the significant amount of data
now collected can only be achieved with innovative and powerful
technologies. New approaches to data analytics, data cleaning,
security and behavioural analysis can all benefit from work
with FinTechs, preferably in close collaboration with all industry
participants.
Systemic risk analysis can be greatly improved by using a
powerful suite of technologies to assess the system at large.
The approach to stress testing can be enhanced by application of
new technologies such as simulation and visualisation. Developing
market segments such as peer to peer lending and other so called
shadow banking activities can also be assessed from data that
may well be unstructured and sitting outside the normal reporting
regimes. Resilience, recovery and resolvability of systemically
important banks and institutions such as central clearing
counterparties can be better assessed by using agent based
modelling and the development of ‘real time’ dashboards which
can inform policy and market intervention actions.
Assessing and understanding emerging technologies in
collaboration with the industry can avoid costly initiatives which
can increase the cost of compliance for the industry, and equally
the prudential regulator can promote more active adoption of
important regulation where banks legacy technology is impeding
progress.
Prudential authorities could also benefit from taking a systems
engineering approach to assessing the financial services
ecosystem and models. Collaboration with industry, technology
firms and academia could well be positively stimulated by the
engagement in an Industry Sandbox.
• Sandbox providers will self-certify against the defined standards
and their documents will be available on the listing page.
• Communication to market will be done initially via the GOV.UK
Verify blog.
• The sandbox providers can decide their own commercial models
in engaging with the market.
• Aggregated analytics and status reporting is made available to
GOV.UK Verify.
• All IP must be protected.
3.2.2 DIGITAL IDENTITY:
A view from Dave Birch, Director of Innovation,
Hyperion Consulting
A generation ago we had the famous cartoon “on the Internet, no
one knows you're dog". A generation on, not only does no-one know
whether you're dog or not, no one knows whether you’re a fridge or
not. What’s more, no one knows whether you're a fridge pretending to
be a dog. Or, more likely, a bot pretending to be a fridge pretending to
be a bot. Whichever way you look at it, things have got worse.
There are real limits to how far we can go with the reinvention of
digital financial services (as opposed to the mere digitisation of
financial services, which to a large extent is all we have achieved so
far) unless we can do something about the fundamental problems of
virtual identities and their links with "real” identities. To paraphrase Bill
Gates only very slightly, if you know who everyone is, transactions are
easy. Identity is the most fundamental challenge facing the financial
sector is facing right now and we need to bring some vision and
leadership to this space to break the log jam and move forward.
I don't think it is an exaggeration to say that in Europe at least the
financial services industry is very close to handing over the identity
crown jewels to third parties. If banks do not work together to
provide an efficient, interoperable identity infrastructure then it will
be provided by someone else. Government? Maybe. But more likely
it will be the internet giants that the vast majority of the people use
on a daily, hourly, minute-by-minute basis: Facebook, Google, Apple,
Amazon, Microsoft. In which case, the banks’ only function will be the
heavily-regulated utility provision of basic services via API to those
who control the customer relationship.
We as an industry already have most of the infrastructure we need to
deliver digital identity, better customer experience, more security and
real privacy. We have mobile phones and SIMs, we have smartphones
with trusted hardware, we have biometrics for convenient
authentication and we have institutions that already do know-your-
customer checks. Let’s start putting it together.
22

3.2.5 REGTECH: A view from, Richard Maton, Chief
Marketing and Strategy Office, Sybenetix
The framework being developed by the industry for MiFIDII data
management and reporting provides the catalyst for innovative
technologies such as AI and new collaborative models enabled
through the Cloud to transform risk and compliance effectiveness for
both firms and regulators.
For example, Sybenetix’s Behavioural Analytics Model applies
algorithms to individual decision making to provide a holistic
behavioural analysis of market abuse, conduct risk and investment
performance. Supervised machine learning is used to eliminate false
positives for market abuse surveillance, provide instant insight based
on individual behavioural profiles, and an evidence-based conduct
risk system for senior managers and accountable individuals.
Developed for firms and regulators, the Behavioural Analytics
Model is validated by a community of leading financial institutions
and through the traditional processes and timetables of regulatory
scrutiny. Sybenetix is currently working with partners to scale
its Behavioural Analytics Model using cloud infrastructure being
developed for the granular data reporting required by MiFIDII. The
company is also solving new regulatory challenges associated with
the use of AI in financial services.
The Industry Sandbox could help accelerate Sybenetix’s development
process through a faster, more efficient digital collaboration
framework that creates new standards for proactive conduct risk
management while further reducing costs and risk for both firms and
regulators.
Ultimately, the value proposition of the Sandbox for RegTech firms,
financial institutions and regulators is its capacity to accelerate off-
market testing to on-market use and scaling. The key is designing
the right process and testing mechanisms within the Sandbox that
all stakeholders can align around to validate new RegTech solutions.
For example, defining a standardised set of KPIs for more effective
regulatory outcomes of new solutions that link directly to the
application of core technologies and business models. This should
include an assessment of how new solutions and models reduce
operational risk compared with legacy systems and models. For
example, how systems scale with the speed, breadth, accuracy and
transparency required under new regulations.
The application of this RegTech acceleration framework could
extend beyond conduct risk to the broader set of risk and regulatory
challenges that RegTech solutions are solving. For example,
the development of KYC/AML monitoring, regulation scanning,
interpretation, change management, reporting and risk management
solutions.
Such a framework would enable faster validation of new systems
for use by both participants and supervisors. This framework could
also help facilitate new collaborative designs of more effective and
efficient regulation, such as real-time supervision, and even new
models of self-regulation.
Consequently, the Sandbox could also enable regulators to
accelerate how they become more ‘digital’ through a collaborative
framework that fits into broader, global policies and mechanisms
being developed. For example, integrating an Industry Sandbox
with other testing mechanisms such as sprints and sandbox
initiatives in other jurisdictions would also benefit Sybenetix, its
partners and its global financial institution clients."
3.2.6 DISTRIBUTED LEDGER TECHNOLOGIES:
As the adoption of Distributed Ledger Technologies (including
blockchain) in financial services matures and it moves from a
proof-of-concept technology into production, for example in
cross-border payments, trade finance or capital markets, the
importance of interoperability and standardisation between use
cases and protocols increases. Given its cross-border nature, it is
also an area where international collaboration could be beneficial
in developing common international standards and a co-ordinated
regulatory response.
There are many consortia and collaboration projects emerging
in the Distributed Ledger space due to the the nature of the
technology itself. An Industry Sandbox can support development of
this emerging space if it provides a neutral ground for efficient early
engagement with regulators as different use cases are identified by
industry. As the technology matures, an Industry Sandbox can be a
space to test interoperability between protocols as well as support
standards development where appropriate. In these instances, the
need for an Industry Sandbox is clear - and any solution should be
constructed as a global platform.
- Oliver Bussmann, Founder and Managing Partner,
Bussmann Advisory
23

3.2.7 FINANCIAL INCLUSION
An Industry Sandbox could be useful in developing and testing new
products and business models that are specifically designed to
foster financial access and improve financial health and wellness.
It could be a venue for collaboration between industry participants,
regulators and consumer organisations to explore insights on the
potential of new products and business models to address market
failures with pressing social dimensions.
In particular, a Sandbox can make it easier to share and analyse
data on what consumer issues with access and inclusion are.
Such data would be collected either through companies’ complaint
procedures (on an anonymised basis) or via public services such
as an ombudsman. Thin data about the prevalence of an issue
is sometimes used as a reason for rejecting or deferring action
to resolve it. An Industry Sandbox can improve the transparency
of such data in aggregate and thus highlight pain points which
innovative solutions can seek to resolve.
Furthermore, alternative or difficult to access data, for example
on credit scores, can be made more widely available through
an Industry Sandbox, fuelling new business models powered by
such data. An Industry Sandbox for financial inclusion would be
well positioned to support data philanthropy initiatives, providing
an operating and governance model for private sector data to be
shared for the delivery of a public benefit.
Additionally, such a Sandbox could include measurable indicators
of delivering financial inclusion as part of its Certification Capability,
giving industry validation for the social benefit of an innovation.
Finally, as an Industry Sandbox could improve access to best
practices, at operational and business level, in the delivery of
financial inclusion products, which might be especially helpful
where solutions are to be integrated in the legacy infrastructure in
less accessible or remote markets. Accessing regulators across
regions via a dedicated Forum could more efficiently pinpoint where
policy change is required to facilitate financial inclusion.
Overall, lowering product development cost, reducing time to
market, and encouraging consumer-friendly innovation are trends
that can positively impact financial access.
An Industry Sandbox like this would be incredibly useful for
gathering insight as we develop products for financially excluded
communities. Financial exclusion is a huge problem, blocking three
billion bankless people from access to basic financial services.
Azimo exists to solve these problems. We would relish having
access to data that helps us build the tools and services that
people desperately need, not to mention pinpoint the areas where
regulatory action is necessary to enable change.
- Marta Krupinska, Founder and General Manager, Azimo.
24

IMPLEMENTATION
OPTIONS
This chapter outlines implementation options for the design, governance, funding and
regulatory and academic engagement in an Industry Sandbox.
The options reflect Consultation feedback, best practices from industry and proprietary
sandboxes globally, and learnings from other collaborative development environments
within and outside financial services.
Together, these options would support industry actors in making the necessary choices
when building one or more specific Industry Sandboxes. The stepping stones are set out.
The choice of direction would lie with industry.
Three sample types of Industry Sandbox are discussed in Chapter 5.
25

4.1 DESIGN PRINCIPLES
With Contributions by Aman Kohli, CTO,
Financial Services and Insurance Practice, Microsoft
A design principle is the set of fundamental objectives,
parameters or rules which would underpin any specific
components of an Industry Sandbox. For example, if the
design principle of an Industry Sandbox is that it should be multi-
stakeholder, its access criteria need to allow different types of
FinTech players to engage in a feasible way.
In the consultation process, a set of design principles were taken
as fundamental and indispensable for understanding what is
meant by an Industry Sandbox. That is, any Industry Sandbox
would by definition comply with them.
ANY INDUSTRY SANDBOX WOULD:
• Validate Innovative Ideas: make it easier and cheaper to
validate new ideas in an off-market environment.
• Be Open: accessible based on transparent, predictable, non-
discriminatory eligibility criteria that do not preclude from
access any organisation or groups of organisations within
the FinTech ecosystem.
• Be Neutral: offer a space for experimentation and
collaboration unaffiliated with any one organisation.
From a regulatory perspective, the Sandbox should be an
experimental ‘safe space’.
• Be Self-sustainable: be resourced and operated by industry
and, where relevant, foundation sponsors.
Some design principles were added as optionalities in the
consultation process based on industry needs and demands
identified in design sessions. That is, an open, neutral and self-
sustainable Industry Sandbox can be designed to abide by one
or all of these principles in order to effectively attract industry
participation.
AN INDUSTRY SANDBOX MIGHT BE:
• Scalable: An Industry Sandbox could accommodate
increasing frequency, complexity and speed of testing. The
sandbox could be vertically expandable so that experiments
can be run by an increasing magnitude of users.
To ensure scalability in an Industry Sandbox, engagement in a
sandbox would be as frictionless as possible, from a governance
and technological perspective. The entry point to a sandbox
would be automated. Users would be able to run and alter their
testing, deploy new versions of their product without interference
to sandbox services or other users.
• Modular: An Industry Sandbox would enable users to
compile testing environments, e.g. combinations of hosting
environment, reference architecture, data feeds and APIs,
specific to their testing purposes. Users and user-generated
tests would run independently of each other.
• Interoperable: An Industry Sandbox would acknowledge
and leverage the existence of other sandbox or similar
prototyping environments, and be set up in a way that enables
interoperability with them through; (1) self-certification
mechanism in experiments; (2) secure authorisation such as
VPNs to access proprietary and shared sandboxes; (3) secure
connectivity, entry, and exit point to the sandbox and the
services the sandbox has access to; and (4) industry standard
APIs to communicate compatibly between systems and
sandboxes.
• Additive: An Industry Sandbox would take into account
industry dynamics and regulatory changes, with their
respective timelines, and offer a space for identifying
and resolving challenges which will support ongoing
developments.
4.2 PARTICIPANT TYPES
An Industry Sandbox is open to the whole FinTech ecosystem,
which includes startups to momentum growth plays, financial
institutions, technology and data providers, and (where relevant)
investors and academia.
Based on best practices from professional membership bodies,
other shared sandboxes or industry research bodies, there could
be four types of engagement models:
• Users: entities conducting testing via the Industry Sandbox
would participate as users, provided they satisfy the
user eligibility listed below. Users would subscribe to the
Industry Sandbox at a cost proportional to the size of their
organisation, as proposed under the funding models in this
report
• Contributors: entities providing assets, including data,
technologies or services to the Industry Sandbox, could
engage as contributors, provided they satisfy the contributor
eligibility criteria listed below. Professional services firms
could engage as contributors by providing access to advice.
• Sponsors: entities can sponsor the Industry Sandbox
should they be interested in setting up issue-specific testing
environments as well as exercise appropriate decision-
making power in the development of the Industry Sandbox.
Sponsors can also create an environment where visibility of
outputs is restricted to the sponsor/group of sponsors.
• Observers: regulators, investors such as venture capital
funds, or membership bodies can join as observers in order
to have access to outputs from the sandbox and engage with
other participants as appropriate. Regulators could engage via
a dedicated forum for curated exchange of information.
26

4.3 ELIGIBILITY REQUIREMENTS
Users Eligibility Criteria
The eligibility criteria for users participating in the Industry Sandbox
should be clear, predictable and non-discriminatory – and, if
possible, support the development of streamlined processes for
demonstrating eligibility for participation in other sandboxes,
accelerators etc.
The criteria should be based on the following elements:
• Need: does the business have a demonstrable need to test
using assets available on the Industry Sandbox?
• Readiness: is the business ready to test their innovation in
an off-market environment? Is the solution mature enough
to require validation or certification? Will the business reach
a meaningful milestone during its residency in the Industry
Sandbox?
• Non-commercial use: can the business demonstrate that
sandbox assets will be used in a non-revenue generating
environment for testing purposes only and any use of
sandbox assets will cease prior to any commercial use being
undertaken?
• Geographical scope: there is no requirement that users of
the Industry Sandbox be locally-domiciled, but they need to
demonstrably commit a dedicated resource to the testing
process.
• Partnerships: startups can collaborate with firms of any size
for the purposes of an Industry Sandbox test.
Contributors or Sponsors might have additional eligibility criteria for
accessing the asset they provide into the Sandbox or the Sandbox
environment they sponsor. These can be managed through a
permissions system.
Access to regulators, in their role as observers, will need to consider
the criteria on which regulatory resources are being deployed.
Typically, conduct regulators only support firms where there is
direct consumer benefit and genuine innovation, which means that
issues raised to an Observer Forum might need to match these
criteria.
Contributor Eligibility Criteria:
When setting the eligibility criteria for contributors, consideration
should be given for potential alignment with the eligibility criteria for
other similar endeavours. This can reduce the effort for contributors
to become involved or make support available. Criteria could
include:
• Availability of asset: is the contributor prepared to commit an
asset (dataset, element of reference architecture, service) to
the Industry Sandbox on a pro-bono basis for a minimum of
twelve months?
• Availability of support: is the contributor prepared to commit
any requisite dedicated support for its testing asset to the
Industry Sandbox on a pro-bono basis for a minimum of twelve
months?
• Auditability: does the contributor agree to the usage of its
testing asset to be monitored and reported on throughout its
residency in the Industry Sandbox?
Contributors that provide access to sensitive testing assets, for
example live or sensitive data, will be able to set up additional
eligibility requirements upon agreement with the governance of
the Industry Sandbox.
27

4.4 DESIGN COMPONENTS
Design Components are tangible technical elements an Industry
Sandbox, which in aggregate constitute the sandbox solution.
For example, if the design principle of an Industry Sandbox is that
it should validate innovative ideas, an associated component is the
Sandbox having Certification Capability.
APPLICATION ASSESSMENT
A self-certification process for accessing an Industry Sandbox
based on established eligibility criteria. Self-certification should be
supplemented by a process for case-by-case assessment of user
applications.
DATA SETS
A key component of an Industry Sandbox is access to the data
required to demonstrate how an innovative solution would work
in practice. Data could be synthetic, historic anonymised data,
delayed, reference or live market data. It can be provided via APIs
or data feeds.
Whether an Industry Sandbox hosts third-party data would depend
on the third party itself. For example, market data is usually readily
available via a data feed or an API from the data owner. Institutional
data, for example synthetic or anonymised transaction data, might
need to be hosted in a specifically created and secure hosting
environment.
Both structured and unstructured data can be available in an
Industry Sandbox. To translate unstructured data to structured data
for business logic, 'lakes' of structured data can be build on top of
'rivers' of unstructured data, for example by leveraging artificial
intelligence and machine learning algorithms.
An Industry Sandbox should provide a view on the quality and type
of providers’ data as well as a streamlined legal process governing
the relationship between the data user and data provider. An
Industry Sandbox should seek to automate as much as possible
the process of matching data users to data providers, as well as the
process of assessing users’ eligibility.
Data providers (whether a data vendor or an institution) will join
an Industry Sandbox as a contributor, and will have the option to
specify additional eligibility criteria for access to all or a subset of
its datasets.
According to the surveyed startup population, the following datasets
would be of most interest:
• AML data;
• KYC data;
• credit data;
• anonymised customer transaction data; and
• global market data.
Transactional data whether it is synthetic, anonymised or live
should be made available on a timeline consistent with other
regulatory changes in the UK, namely the implementation of the
CMA remedies and the implementation of PSD2.
Content sets made available via the Industry Sandbox
environment(s) need to be highly secure and tightly
controlled. Even after a user has authenticated, authorisation
and entitlements to specific content sets will be provisioned
by the content set owner. This access should be entirely the
data-owner's responsibility. Where content is connected
or merged, permission from the owner of each respective
content set needs to have been obtained. Although the
Industry Sandbox will not be storing any third party data, if it
provides test environments for analysing extracted content,
clearly defined roles and responsibilities in respect to use of
these environments should be considered (e.g. co-mingled
content sourced from a different/multiple legal jurisdiction
need to be considerate of data residency, privacy and
confidentiality).
To help aid in content visibility, a content catalogue &
meta-data registry should be maintained – in addition to
‘standard’ meta-data descriptors, data provenance should
be a high priority, especially when co-mingled or otherwise
highly curated content sets are involved. Lack of visibility into
content ownership and usage is a highly prohibitive factor
when considering content collaboration. Sitting ‘on top’ of the
meta-data registry should be a data catalogue, a ‘store-front’
of searchable content sets to enable rapid discoverability.
The store-front should be a publicly available service; the
meta-data registry however should be a service reserved for
signed-up users or participants in the sandbox.
PERMISSIONS:
A view from Chris Blatchford, Head of Enterprise
Technology and Software, Thomson Reuters
28

REFERENCE ARCHITECTURES:
A view from Andrew Graham, Distinguished Engineer,
Financial Markets, IBM and Winston Yong, Chief Architect,
Industry Platforms, IBM
Reference architectures are a set of domain-specific artefacts,
design patterns and terminology that describe successful
operational architectures. The artefacts can span business to
operational domains, with emphasis on interoperability within
complex systems.
The primary role of Reference Architectures in an Industry
Sandbox would be to provide Interoperability and best practices
for the advancement of FinTech solutions.
The use of Reference Architectures would facilitate multiple
parties coming together to interoperate and solve new problems
at a business and technical level. The architectures would be
grounded with key principles and assumptions. For example,
services should be highly componentised, loosely coupled and
have clear separation of concerns. Furthermore, concepts such
as systems of engagement, integration, insight and record are a
useful means to separate functions.
Common vocabulary could provide a quickstart for industry
collaboration
Each business domain would have agreed functional component
descriptions with a clear vocabulary. Context diagrams to define
scope boundaries to a problem domain e.g. Wicked Industry
Problems, component/business service models and interaction/
sequence diagrams to describe business and technical flows
would ensure best practices are utilised and understood in
common.
Strategy &
Planning
Customer
insight &
Mgmt
Compliance
financial &
risk mgmt
Banking Channels
Banking prod. operations
Banking back office
Fin. Mkt. front Office
Fin. Mkt. middle office
Fin. Mkt. back office
Fin. Mkt. front Office
Fin. Mkt. middle office
Fin. Mkt. back office
Operations
Information technology
Systems of Engagment
Systems of insight Systems of Integration
System of Record
Governence
Model
Service (IT)
Container / VM
Service (IT) Service (IT)
Container / VM Container / VM
Operating Platform
Logging
Services
DevOps
Services
Container
Catalogue
Data
Stores
Integration
services
Inc. API
Gateways
(Test)
Data Services
(Test)
Industry
Services
FINANCIAL
SERVICES
(FUNCTIONAL)
DOMAIN
ENTERPRISE
DOMAIN
DIGITAL
DOMAIN
The use of pertinent industry and technical standards would
provide clear guidance on preferred middleware, service and
data standards. The encouragement of certain technologies,
such as containers, RESTful APIs, JSON documents and DevOps
techniques should be included as foundational enablers within
the reference architectures. Consideration of non-functional
requirements, including security and service level constraints
is an important aspect of ensuring stability and resilience in the
financial services industry.
Consistent service patterns and test data, leading to
development of industry standards.
An important area of focus for a sandbox is the quality and
availability of test data and test services to simulate a real
environment. The sandbox reference architectures should layout
where data providers (e.g. reference data and market data)
and industry service providers (e.g. SWIFT gateways, payment
gateways, credit checking services, KYC and AML services) fit in
the overall architecture, as these services are often prerequisites
to testing new services.
Ultimately, reference architectures are sets of domain specific
architectural views. They do not constrain innovation by
reinforcing prior approaches but instead provide FinTechs with
base templates to articulate their innovation with. Financial
institutions likewise are able to standardise their technology
for interoperability, internally as well as with external FinTechs.
Reference architecture are tools and patterns for common ways
of working and as a precursor to establishing industry standards.
Source: IBM
29

CERTIFICATIONS: A VIEW FROM WINSTON YONG, IBM
Certification, which has been effectively used in many industries
as a benchmark of quality, has the potential to bridge the disruptive
nature of innovation with the need for stability in a financial
services industry. The value of certification in technology is the
assurance of adoption and conformance to standards which have
been defined as best practice. Certification affirms a level of quality
that does not need to be reassessed by individual customers.
The most common type of certification is professional certification,
where a person or entity is certified as being able to competently
complete a job or task. The second and relevant certification
type to the Industry Sandbox is product certification, in which the
product (or operations) i.e. the FinTech solution, is certified as
meeting a set of minimum standards, particularly with respect to
quality and performance; and meets qualification criteria stipulated
in contracts, regulations, or specifications.
There are four main factors that would shape a FinTech solution
certification programme:
1. Certification is voluntary: unlike regulatory compliance,
certification is voluntary and therefore requires a particular
implementation approach based around communicating
stakeholder benefits that attract community members. For
example, achieving Certification may become a prerequisite
for solution inclusion in Request for Information/Proposals
responses whilst granting an accelerated procurement
process. Positioning these privileges and the value they
carry will be a critical success factor for the Certification
programme.
2. Existing standards are relevant: the existence of many
specialised technology standards provide a rich and diverse
portfolio for FinTechs to develop their solutions against. It
would be more efficient and flexible to certify that a FinTech
solution has rigorously adhered to the standard(s) of its
choosing. Whilst a catalogue of relevant technology and
industry standards may be provided, the FinTech may choose
the standards most relevant to build their innovation upon.
3. Certification has a shelf life: the continued evolution and
maturity of the standards involved, together with the rapid
pace of FinTech changes necessitates active management
and re-certification to ensure currency.
4. Transparency provides credibility: to optimise the value
of certification to stakeholders, and promote industry
acceptance, the Certification process should be governed in
a transparent way by an independent Certification body. The
independent body would provide direction, governance, design
authority and arbitration.
A FinTech certification programme would help FinTech achieve
scale and adoption in the financial services industry
A potential FinTech certification framework for adoption in an
Industry Sandbox would span seven areas of competencies,
providing coverage across Business, Operations and Technology.
It would be established across 3 tiers of certification – Formative,
Diagnostic and Benchmark; reflecting a FinTech’s progression
through maturity and increasing capabilities.
A FinTech certification programme based on existing standards
will help FinTechs achieve scale and adoption in the financial
services industry; but the need for transparency and neutrality in its
governance is crucial to its implementation success.
Business Segment
Competency of the solution’s grounding in the business
model and intrinsic valueit is providing to the industry;
across market clarity, enterprise architecture, roadmap,
continued innovation and research
Technical Segment
Competency of the solution design
and build; across abilities such as
quality, consistency, performance,
integrity, resilience and interoperability
Operational Segment
Competency of the solution usability;
across abilities to introduce deployment
with minimal disruption and support
Buisness Technical Operational
Technology Mgmt
...ability to have
sound approach
management of
technology…
Demand Mgmt
...focus on clear
understanding of
consumers, requirement
and use …
Service/Sol.
Deveopment
...qaulity, disipline
and consistency
of its development
and roadmap …
Information Mgmt
...treating information
as an asset, managed
purposefully and
rigorously …
Resilience
... capacity to adapt
and respond to
unanticipated
negative events …
Service/Sol.
Deployment
... Ability to introduce
change into operations
with minimal disruption …
S/S Delivery
and Support
... ability for continued
delivery, meeting
standards and
customer satisfaction …
Source: IBM
30

VOLUNTARY STANDARDISATION WITHIN AN
INDUSTRY SANDBOX:
A view from Ben Helps, CEO, Factern
Standards are seen as a signal of market efficiency. But
standardisation itself (i.e. the process through which standards
are developed and agreed) is invariably arduous and time-
consuming. Convergence has a cost.
An Industry Sandbox provides a forum in which the relative costs
and benefits of standardisation can by explored carefully, through
mutual collaboration, whether that collaboration is bilateral or
multilateral. Financial institutions with different starting points to
set, evolve or converse standards can move at their own pace,
based on business cases that make sense to them.
Standardisation could occur in any area of due diligence: a
common contract, billing and payment platform that provides
FinTech startups and institutions with an easy way to engage with
each other; default security protocols that depend on the nature
of the data assets being exchanged; operational standards that
offer economies of scale; policy standards that increase
interoperability; etc. The trade-off between the costs and benefits
of standardisation will not only differ in each case, but also for
each participant.
An Industry Sandbox would not force its participants to adopt a
common set of standards, although widespread convergence
may be required to solve some of the industry’s “wicked problems”.
However, it would require transparency: the onus must be on the
financial institutions acting as Contributor to identify their own
business cases for change, to specify their service needs, and
to make clear their due diligence requirements. The Industry
Sandbox would help to manage that demand, aggregating and
communicating those requirements to the market provided by
the Users.
Therefore transparency is the most important access criteria for
contributors. With transparency comes rational standardisation,
and with standards comes efficiency and innovation.
It is this transparency that sets the Industry Sandbox apart
from other initiatives, as it opens up potential of voluntary
standardisation: that is, standardisation that takes place step
by step over time, as and when it makes sense.
NATIONAL ACCREDITATION:
A VIEW FROM LORD JAMIE LINDSAY, CHAIRMAN, UKAS
As the Government appointed National Accreditation Body, the
United Kingdom Accreditation Service welcomes this important
project/report and the recognition that the use of standards in
the FinTech arena can benefit from being underpinned by the
establishment of a robust verification and certification system.
For a certification scheme to offer assurance to users and increase
market, consumer and regulatory confidence, it needs to be
operated by a body which can demonstrate its own competence,
impartiality and integrity. This can be achieved through UKAS
accreditation which assesses, against internationally agreed
standards, organisations that provide certification and broader
conformity assessment services. UKAS stands ready to support
this exciting new area.
Cast Study 1: European Marine Energy Centre
UKAS has accredited the European Marine Energy Centre (EMEC) for
the testing of wave and tidal energy conversion systems since 2005.
EMEC was established in 2003 and is the first and only centre of its
kind in the world to provide developers of both wave and tidal energy
converters – technologies that generate electricity by harnessing the
power of waves and tidal streams – with purpose-built, accredited
open-sea testing.
EMEC is accredited to operate to relevant test laboratory standards
(ISO17025) enabling the Centre to provide independently-verified
performance assessments, and is accredited to ISO/IEC 17020
offering independent Environmental Technology Verification
(EMEC-ETV) to help innovative technologies reach the market.
Like an Industry Sandbox it is in effect a sandbox for innovative new
ideas and technology for equipment for producing renewable marine
energy sources. Companies can take their new technologies to EMEC
to be tested and the credibility of EMEC’s test results for technologies
that have been trialled there is subsequently underpinned (or badged)
by UKAS accreditation, which gives assurance to potential users and
increases market, consumer and regulatory confidence.
Case Study 2: Fair Banking Foundation
UKAS accreditation of the Fair Banking Foundation’s scheme is an
example of how an accredited certification scheme that formally
evidences and makes public the extent to which a banking product
helps customers manage their money can give greater confidence
to purchasers, regulators and customers in the end-product.
The Fairbanking Mark scheme grants those products submitted
that are successful with a 3, 4 or 5 star rating , indicating the level
to which they have been independently assessed to help improve
the customer’s financial well-being. Each financial product is tested
against a range of relevant criteria which have been derived from
extensive customer research and the application of academic
behavioural theory as being critical to the improvement of financial
well-being. A crucial part of the testing is independent research
carried out with a significant number of existing holders of the
product to ensure that the product’s relevant features have been
sufficiently effective.
31

SHOWCASE SPACE
A key role of an Industry Sandbox could be to showcase new
products to potential customers, collaborators or investors. By
bringing together interested parties, in an environment where the
product can be demonstrated, an Industry Sandbox could facilitate
the discovery of innovative solutions whose validity has been tested
by developing dedicated virtual showcase space, as well as off-line
demo days.
ADVISORY SERVICES
The Industry Sandbox could create mechanisms for participants to
access advisory services, including from lawyers, accountants or
other professional advisers. This may involve offering 'day surgeries',
training for participants, online directories, creation
of model documents to streamline advice requirements and
tailored advice packages.
It could also involve the creation of online tools to support
participants with particular needs in order to deliver advice
in a cost-effective manner. One example of this would be the
Regulatory Accelerator tool3
developed by Hogan Lovells in the
context of its strategic partnership with Innovate Finance to
provide guidance on when companies need to be regulated.
Analytics & Audit tools
An Industry Sandbox can provide both users and partners with
analytics of the frequency and user base of different testing assets.
Such tools would ensure that usage of an Industry Sandbox is
auditable.
Examples of analytical solutions developed by startups:
Qumram, a potential partner as technology vendor, provides analytics
tools for cross-channel intelligence and compliance. Qumram can
record and replay (in movie-like form) all digital interactions, allowing
an Industry Sandbox to see exactly what users did within any
browser-based application. The Industry Sandbox could benefit from
Qumram through: (1) user experience playback and analysis; (2) audit
trail recording and archiving; (3) and specific errors and exceptions
catching. Qumram is developing next generation of analytics tool
for not only real-time monitor, audit, and archive, but also predictive
intelligence to prevent errors and wrongdoings.
Participation Forums
An Industry Sandbox can be equipped with discussion forums,
online communication channels as well as regular offline
meetings, where participants share experiences during their
residency in the sandbox. Dedicated Forums could be set
up for each participant type as well as to achieve seamless
communication between the users, contributors, sponsors and
observers. Existing digital communication channels, e.g. Slack or
Github, could be utilised in the setting up of various forums.
Types of Industry Sandbox Forums:
• User Forum: allows users to share experiences and
feedback into the development of the sandbox, enables
sharing of open code (e.g. via a GitHub page), and allows
users to transparently rank sandbox assets such as
datasets and APIs. Via a user forum, users can contribute
to the development of an Industry Sandbox by, for example,
cataloguing assets, thereby creating a self-sustainable
sandbox ecosystem.
• Contributor Forum: allows contributors to share experiences
and feedback into the development of the sandbox in order
to ensure their participation returns value.
• Sponsor Forum: allows sponsors to set challenges and
specific environments, and ensure interoperability between
these; ensures transparency on how sponsors prioritise
allocation of sandbox resources.
• Regulatory Forum: allows regulators to join curated
conversations on issues raised through sandbox testing.
• Observer Forum: allows observers to view outputs of an
Industry Sandbox, for example via an “app store”.
Boston-based startup Sandbox (sandboxbanking.com) is building
an app-store for banks and credit unions. The solution’s integration
layer creates standardised APIs against legacy systems and their
deployment layer allows third party fintech products to be tested
without sharing sensitive financial institution data. To satisfy
information security and audit needs, Sandbox created built-in
authentication, encryption and immutable audit log modules. The
Industry Sandbox could benefit from Sandbox through (1) their
standardised API design across various legacy systems (2) their ability
to separate fintech applications from underlying sensitive data (3)
their approach to built-in audit trails to track information security.
3 accessible at http://www.hoganlovellsregulatoryaccelerator.com/
32

4.5 LEGAL AND GOVERNANCE FRAMEWORK:
A view from Hogan Lovells
The core function of a legal and governance framework for
an Industry Sandbox is to create a legally compliant operating
environment which appropriately regulates the relationships
involved (both amongst the participants and in relation to any
relevant third parties, such as regulators) so as to support delivery
of its agreed objectives and to enable it to evolve to meet changing
needs.
Choosing the appropriate legal and governance framework for any
Industry Sandbox will depend on the nature of the activities to be
undertaken and of the participants involved.
There will be detailed and technical decisions to be made on the
intricacies of any structure but there are common characteristics
which can be outlined.
If the function of an Industry Sandbox is essentially to act as an
aggregator or access point for other sandboxes then the framework
could be relatively light-touch and could potentially be operated
from within the organisation setting it up.
However, if it is to operate independently, its objectives go beyond
providing information or its function evolve over time, then more
formal structures will be required and, most likely, a separate legal
entity should be created rather than relying purely on a matrix of
contractual relationships. Contractual relationships will also, likely,
need to be created between participants directly as well as with the
legal entity and should facilitate the inclusion of new participants.
In this era of positive collaboration, these are familiar choices for
those engaged in delivering joint projects or operating shared
development environments.
The overview of potential characteristics for legal and governance
frameworks below focuses on the key elements to be considered in
developing an independently operated Industry Sandbox structure.
There are a number of core principles that this framework could
reflect:
• Simple and flexible: the legal and governance structures for
an Industry Sandbox should be designed to be as simple as is
possible. The nature of the structure put in place will depend
on the complexity of the activities to be undertaken and the
profile of the proposed participants. The model may change
over time. Therefore, the framework should also be flexible
and able to evolve as the Industry Sandbox develops. The
scalability of an Industry Sandbox itself should be built into
and accommodated by the legal and governance structure with
clear mechanisms for decision-making, including on funding
requirements. Mechanisms for participants joining and leaving
should be clear.
• Neutral: the governance of an Industry Sandbox should
be neutral and should not favour the interests of any one
potential participant or category of participant. This means
that the framework will need to include checks and balances
to ensure that the interests of all participants and potential
participants (regardless of their position in the market)
are appropriately represented. It will also be important to
ensure that the environment establishes fair and objective,
and non-discriminatory, access criteria and a level playing
field, remaining consistent at all times with competition law
requirements.
• Not-for-profit: an Industry Sandbox can be set up as a
separate not-for-profit entity, for example, a company limited
by guarantee where participants are members rather than
shareholders. By establishing an Industry Sandbox as a
not-for-profit entity, it enhances the neutrality of the Industry
Sandbox and gives confidence that it will be run in a way which
is consistent with its function as a forum for collaboration,
rather than to further profitability for one or more investors.
• Compliant: fundamentally, an Industry Sandbox needs to
create an environment which ensures that all participants
can engage without being in breach of any compliance
requirements simply by virtue of choosing participation in
the Industry Sandbox, including compliance with financial
regulation, data protection or competition laws. This will
drive the structure and core operational parameters of the
sandbox, as well as the policies, such as on competition and
on privacy, and agreements which need to be put in place.
The nature of the activities which the participants choose to
undertake within an Industry Sandbox may require a separate
assessment of whether those activities are compliant but that
may be conducted on an individual basis.
• Legally robust: to ensure confidence in an Industry Sandbox,
participants are likely to look for certainty over the rights
and obligations which will exist between them, the Industry
Sandbox itself and other participants. Participants will
therefore need to agree to contractually binding terms of
participation. Throughout the consultation, information
security has been raised as a key concern; the contractual
arrangements would need to deal particularly with participants'
respective rights and obligations in relation to the sharing and
use of information. The complexity of these issues will depend
on the type of information that is being used (for example,
whether or not it is synthetic or real data). Contractual
arrangements will also be necessary to ensure that an
Industry Sandbox cannot inadvertently become a forum for the
exchange of competitively sensitive information.
• Designed to reflect intellectual property (IPR)
considerations: Protection of intellectual property rights has
also been raised as a concern and these issues need to be
addressed in the design of an Industry Sandbox and the terms
of participation. If participants' IPR may be made available to
others for use within the parameters of the Industry Sandbox
then it could require cross-licences to be put in place. The
terms relating to IPR and any such cross-licences would
typically be mandated by the design of the Industry Sandbox
to apply to all participants in order to protect existing IPRs,
regulate how another's IPR may be used and determine who
owns IPR in any resulting work product. For example, for
participants for whom protection of trade secrets is material,
it may require care to be taken on how disclosure is managed.
It is likely that the status quo will be that arrangements
provide that participation in an Industry Sandbox does not
operate to transfer any intellectual property rights but there 33

may be occasions where a different approach is adopted
by agreement, for example, to Open Source some element
of a potential solution to a Wicked Industry Problem or for a
consortium of participants to form around developing such
a solution. Care will be needed to ensure that any differential
approach to IPR operates in a way which maintains a structure
which complies with competition law considerations,
particularly with respect to problems where the solution
sought is intended to have industry-wide applicability, e.g.
interoperability of standards. If activities may draw on IPR
contributions from different parties in order to develop a
solution to a Wicked Industry Problem, the IPR position could
be more complex and insights may be gained from analysing
the approach adopted in other collaborative research groups.
For example, in EU-sponsored consortia, funders often specify
what cross-licensing terms apply during the project, which
tends to be relatively uncontroversial. More complex is to
provide for how the IPR and work products which result from
the collaboration can be used once the testing or development
phase has ended, particularly where such use may require
ongoing use of another's IPR.
Legal and governance frameworks for organisations, such as an
Industry Sandbox, tend to have some or all of the following key
components:
• A governance body (which could be structured as a board of
directors). This would oversee the operation of an Industry
Sandbox in the interests of its sponsors, contributors and
users. This body would have terms of reference setting out
its role and responsibilities. If required by size, membership
of a leadership governance structure could be elected or
rotational to ensure fair participation. The governance body
would be responsible for ensuring that the sandbox fulfils its
objectives and that any developments beyond the initial set up
are in line with these objectives as well. Careful consideration
of the nomination processes and voting rights will be needed
in order to ensure that its neutral objectives are achieved.
An Industry Sandbox should also be designed so that it
does not inadvertently become a forum for the exchange of
competitively sensitive information and that this is reflected in
undertakings in the binding terms of participation as well as
having a robust legal structure.
• A dedicated secretariat/operational team to carry out the
day-to-day operations of an Industry Sandbox. This could
include, for example, managing applications to the Industry
Sandbox, communicating with participants and assisting the
governance body. This function could be outsourced from the
sandbox legal entity to a third party. Consideration could be
given to outsourcing to an independent third party to reduce
scope for conflicts of interest and potentially enhance external
confidence in its neutrality.
• Dedicated participant forums could be set up in order for
different types of participants, for example sponsors, to
discuss, agree and input into the strategy, operations and
priorities of the Industry Sandbox they are participating in.
• Terms of participation which regulate each participant's
rights and responsibilities in respect of an Industry Sandbox
and to each other. These terms could be tailored as appropriate
for each type of participant but, to ensure fairness and reduce
operational friction, should be the same for each participant
and potential participant of that type. The term of their
participation and ability to withdraw should be clear and there
would be consequences for those who breach the terms of
participation (for example, being bound to compensate those
who have suffered as a result of the breach, or to leave the
Industry Sandbox). It is likely that industry engagement on
developing these terms of engagement would be key to their
adoption.
• A dispute resolution procedure to deal with disputes between
participants. Although participants would have legally
enforceable rights against each other, alternative dispute
resolution procedures such as escalation, negotiation and
mediation tend to reduce cost and can ensure that differences
are reconciled quickly and easily.
• A legal structure that delivers these key components and
supports the effective functioning of an Industry Sandbox. For
example, if an Industry Sandbox were set up as a company
limited by guarantee, its participants could be members of
that company and the governing body could be its directors.
Ad hoc working groups or formal sub-committees could be
established which feed into and advise the board, which could
allow the members to be actively involved and to influence the
direction of the sandbox. There could be different categories
of members with different terms of engagement relative to
the nature of their relationship with the sandbox based on
objective criteria. The constitutional documents, together
with any additional agreements, would set out the respective
rights and duties of these groups, the terms of reference, the
governance structure and cover procedural matters (such
as the appointment of directors and voting rights). The legal
structure will also deal with the allocation of liability between
the participants. Given that a number of participants will likely
be competitors, it will also be important to ensure that the
structure is compliant from a competition law perspective –
consideration would need to be given to this both structurally
and in relation to developing and implementing a competition
law policy. The legal structure would also need to address
other potential concerns of participants, such as appropriate
protection of their intellectual property rights and funding
obligations. An area where the approach to intellectual
property rights may be more complex could be where the
solution to a Wicked Industry Problem may be advanced by
a combination of the intellectual property rights of different
participants.
Industry Sandboxes can vary in scope and complexity. Detailed
proposals on legal and governance structures will need to be
developed accordingly. Learning from this consultation process
is that the next level of detail will need to be developed through an
inclusive pan-industry engagement with interested stakeholders.
Alignment with other sandboxes on access or exit criteria could
be explored to help users participate in multiple development
environments at the same time.
34

A CASE STUDY ON LEGAL AND GOVERNANCE
FRAMEWORKS
TeX is a not-for-profit organisation, established at the initiative
of TISA and with members from across the industry, which has
facilitated the design and implementation of a forum for delivering an
innovative solution for the electronic transfer of wrappers and assets
between fund managers, platforms, wealth managers and any firm
which holds assets on behalf of investors.
Although TeX was established for a specific activity the framework
for collaboration and the process for establishing it, provides useful
insights on the proposed governance approach for an Industry
Sandbox whether it is established to focus on a single activity, for
example, to create an industry-wide standardised process, or to
create an operating environment like an Industry Sandbox in which
innovations across a number of activities can be explored.
The TeX structure uses a separate legal entity, a company limited
by guarantee, in which participants are members. There are
different categories of members related to the role they play, though
parties can be in more than one category. There are also associate
participants who have a more limited set of rights reflect the different
nature of their involvement.
Contractual relationships are also established between participants
and TeX and directly between each participant and each other
participant under a Membership Agreement. This is a standard form
agreement which means it needs to be fair and reasonable and
was agreed through consultation with the industry. Any changes to
the Membership Agreement are made in accordance with the TeX
governance structure. This means that participants can engage
directly with each other to resolve disputes if one participant
breaches their terms of participation in a way which causes loss to
the other.
Compliance is supported by having in place clear terms of reference,
service level agreements, a competition policy, a privacy policy and
a whistle-blowing policy. Separate arrangements are in a place for
associate participants. In keeping with many collaboration structures
of this nature, parties agree expressly under their participant
agreements that they will each retain their own intellectual property
rights – this is an area where the position in an Industry Sandbox
may be more complex if parties may be working together to develop
new forms of intellectual property rights and the participation
agreements will need to ensure that the position on ownership is
clear.
Voting rights were carefully constructed to reflect the nature of the
collaboration and deliver a balanced approach but TISA, as the
neutral founding body, was set up with a specific category of rights
which effectively delivers a veto right in certain circumstances to help
ensure the neutral objectives of the organisation were maintained.
This involved TISA being set up as a 'special member' with the right
to appoint its own directors to the TeX board. Part of the process
of establishing TeX was analysing the optimum structure for voting
rights to ensure its smooth operation that this position was accepted
by other TeX members and made effective through their membership
documents. An outline of the structure and the relevant constitutional
documents is set out below.
TISA EXCHANGE
LIMITED (TeX)
In setting up TeX our objectives were to support the industry in
responding to new FCA requirements and improve certainty to
consumers that processes were being completed to an agreed
standard. It also enabled reduction of cost, risk and duplication
within the industry. The FCA has consistently supported the
progress made by TISA in launching TeX.
- Peter Smith, Head of Industry Policy Liaison, TISA
- John Salmon, Technology Partner, Hogan Lovells
When we were developing the legal and governance framework for
TeX, we worked with the industry, regulators and members through
TISA, on agreeing open standard form contracts for engaging with
the platforms & UK Fund Management Groups. Having that wide
industry engagement meant we could create a transparent operating
environment with streamlined engagement and on-boarding
processes which is able to evolve to meet the needs of its members
and the industry, providing an ultimate benefit to consumers.
TISA Exchange
Limited (TeX)
TISA
Service Provider
Members
Multi-Role
Members
Asset Manager
Members
Associate or
other classes
of MemberOperator of the
Register of
Members and
TeX website
Articals of Association
1. Objectives
2. Application for and membership termination
of Membership
3. Members voting rights and members meetings
4. Appointment and removal of Directors
5. Directors powers
6. Directors voting rights and board meetings
7. Members liability
Contract Club Membership Agreement
Registration & Joining Fee Forms
1. Compitition Policy
2. Articles of Association
3. Contract Terms
4. By-Laws
5. Glossary of Defined Terms
6. Service level Agreement (SLA)
7. Whistle blowing policy
8. Privacy Policy
Associate Terms
1. Assoiate Side Letter
2. Glossary Competition
3. Competition Policy
4. Associate Privacy Policy
TISA Exchange
Limited (TeX)
TISA
Service Provider
Members
Multi-Role
Members
Asset Manager
Members
Operator of the
Register of
Members and
TeX website
1. Objectives
of Membership
5. Directors powers
8. Administration
9. Definitions
3. Contract Terms
4. By-Laws
8. Privacy Policy
Associate Terms
1. Assoiate Side L
2. Glossary Comp
3. Competition Po
4. Associate Priva
TISA Exchange
Limited (TeX)
TISA
Service Provider
Members
Multi-Role
Members
Asset Manager
Members
Associate or
other classes
Register of
Members and
TeX website
1. Objectives
of Membership
5. Directors powers
8. Administration
9. Definitions
3. Contract Terms
4. By-Laws
8. Privacy Policy
Associate Terms
TISA Exchange
Limited (TeX)
TISA
Service Provider
Members
Multi-Role
Members
Asset Manager
Members
Associate or
other classes
Register of
Members and
TeX website
1. Objectives
of Membership
5. Directors powers
8. Administration
9. Definitions
3. Contract Terms
4. By-Laws
8. Privacy Policy
Associate Terms
Source: TeX
35

4.6 FUNDING MODELS
An Industry Sandbox would be open to all types of entities in a
FinTech ecosystem, provided they meet the eligibility requirements
for at least one of the four types of sandbox participants: users,
contributors, sponsors or observers.
Industry consensus is that participation should be voluntary.
Affordability should be a consideration for ensuring an Industry
Sandbox is accessible to, in particular, the startup community.
Consultation feedback has been that an Industry Sandbox should
be set up as a not-for-profit structure. Therefore, its funding
requirements extend to covering the cost of setting it up, investment
in scaling its services, and the operational cost of running the
Industry Sandbox.
As a guiding principle, cost of participation should be tiered,
calibrated on the type of participation, the scope of the testing
conducted, and the size of the participating organisation.
The range of available funding approaches is as follows:
• Users: Users could be charged on a test-by-test or subscription
basis. Fees will be determined by the (1) size of the participating
organisation; (2) level of its utilisation of the sandbox; and
(3) duration of utilisation of the sandbox. Industry Sandbox
operators should consider the feasibility of providing free or
near-free testing to the startup community.
• Contributors: There is significant scope for contributors to
engage through in-kind support. These can include providing
pro-bono technical or other professional advice, developing
elements of the digital Industry Sandbox platform, or providing
access to data, APIs or technical infrastructure.
• Sponsors: Organisations interested in exploring a particular
issue via an Industry Sandbox (e.g. a Wicked Industry Problem)
should be able to sponsor specific environments to a level
proportionate to the resources required to set up and operate
the required testing environment and engagements
• Observers: Entities interested in the outputs from the sandbox
could be charged a fee in order to access them. This should not
extend to public bodies participating as observers. Whether the
results of a test are open to observers would be determined by
the user conducting the test. Observers, such as venture capital
funds, might find it economically beneficial to offer paid access
to an Industry Sandbox for their portfolio companies as an
analytical tool.
• Foundation funding: An Industry Sandbox should review
options to align its objective of fast-tracking open innovation
with the objectives of public bodies or private foundations
committed to supporting the growth of the UK FinTech sector
and innovation and competition in financial services.
The cost of an Industry Sandbox would depend heavily on the design
components it is set up with. Costs of operating market sandboxes
vary significantly. For indicative purposes only, we note that:
• development of a technical data sandbox environment might be
priced between GBP 25,000 and 50,000 depending on number
of participants, testing period, and data requirements;
• operational costs for low-technology shared data sandbox
environments can be around GBP 300,000 per year; and
• a technically sophisticated sandbox environment staffed with
senior researchers can cost between 1 and 1.5 million GBP
annually.

36

USER CONTRIBUTOR SPONSOR OBSERVER
STARTUP
• Deploy own tests
• Participate in collaborative
tests
• Validate products via
industry certification
• Showcase products
• Participate in User Forum
• Contribute data or other APIs
• Contribute open source code
• Contribute solutions to be used by
sandbox e.g. analytics
• Access analytics on contributed
assets
• Participate in Contributors’ Forum
• Sponsor wicked-problem
specific environments
• Conduct startups challenges
FINANCIAL
INSTITUTION
tests
• Contribute product or transactional
data
• Contribute open source code
• Contribute other APIs
• Access analytics on contributed
APIs
• Sponsor environment specific
for a Wicked Industry Problem
• Sponsor startups challenges
• Participate in Sponsors’ Forum
• Access test results
TECH OR
DATA VENDOR
tests
• Contribute data and support
services
• Contribute other APIs and /or
Reference Architectures
• Develop neutral in Certification
Capability
• Sponsor environment specific
for a Wicked Industry Problem
• Sponsor startups challenges
• Participate in Sponsors’ Forum
PROFESSIONAL
SERVICES FIRMS
• Contributed assets to an Advisory
Space
• Sponsor environment
specific for a Wicked Industry
Problemwith clients
VC • Sponsor sandbox access for
portfolio companies
• Access sandbox tests for
developing deal flow
ACADEMIA
tests
• Contribute research tools and
expertise
• Access sandbox tests for
research purposes
4.7 SANDBOX PARTICIPANT ROLES
Different FinTech ecosystem players – from startups to institutions, regulators, or academics –
can engage in an industry sandbox as one or all types of participants, all at the same time.
For example, a retail bank can test its solution to a Wicked Industry Problem with partners,
contribute product data, sponsor a challenge and observe outputs of open sandbox tests.
The table below gives suggestions of how any member of a FinTech ecosystem can engage
in the four different roles they can play in an Industry Sandbox.
37

4.7.1 ROLE OF REGULATORS AND PUBLIC BODIES
Responses to the Industry Sandbox Consultation strongly indicate that
there is demand for regulators to play a part in an Industry Sandbox.
There were five areas where respondents were keen to see regulatory
engagement with an Industry Sandbox:
1. engage in curated dialogue with sandbox participants where there
is uncertainty around the regulatory approach to an innovative
solution;
2. review Industry Sandbox tests in applications to regulatory
sandboxes, authorisation or supervisory decisions;
3. leverage an Industry Sandbox to test RegTech solutions for
regulatory use;
4. consider Industry Sandbox output towards policy development; and
5. provide a forum for international regulators and developers
of innovative solutions to discuss divergences in regulatory
approaches and the potential for alignment.
Nearly all respondents across all stakeholder groups agreed with these
asks. We note that this was the survey question with the highest degree
of convergence among stakeholder groups.
As with other aspects of an Industry Sandbox, engagement with
regulators should add to on-going global regulatory initiatives aimed at
supporting market competition and better consumer outcomes through
supporting innovation.
Engage in curated dialogue with sandbox participants
We note that many market or conduct regulators have set up innovation
units to provide direct support to startups that seek clarity on the
regulatory implications of their products.
Cohorts that, in the process of sandbox testing, identify issues where
regulatory steer might be beneficial to further product development,
secure funding, or enable partnerships with regulated entities, should
have a safe space to engage with the regulator. This space would be the
proposed Regulatory Forum under Design Components.
The same logic holds for engagement between industry and multiple
regulators, particularly ones committed to convergence of approaches,
such as regulators connected via a FinTech bridge or cooperation
agreement.
Review Industry Sandbox tests in applications to regulatory
sandboxes
An issue is the potential interoperability between an Industry Sandbox
and a Regulatory Sandbox.
Learning from the first Regulatory Sandbox, cohorts suggest that
applications to a Regulatory Sandbox could be supported by preparatory
work in an Industry Sandbox. For example:
• Partner arrangements: if a non-regulated startup needs to work
with a regulated institution during Regulatory Sandbox testing,
such partnership can be tested and secured in an Industry
Sandbox first;
• Technical development of the product: in order to show readiness
for testing, regulators usually expect a firm to prove that the
technical development of their product is as complete as possible,
which can be done in an off-market Sandbox.
• Cyber-resilience: penetration testing is often required.
Testing RegTech for Regulators
The development of RegTech solutions for regulators is an increasing
focus area addressed through internal research and adoption
programmes, accelerators or hackathons.
An Industry Sandbox could be viewed as a RegTech tool for regulators
in itself, as it supports both an infrastructural transformation and helps
develop an active tech ecosystem feedback loop, both for market
understanding and internal deployment.
At minimum, knowledge sharing between regulator initiatives, POCs
and equivalent industry projects would be beneficial. For example, an
Industry Sandbox can be used to further develop solutions originating
from a regulator's RegTech tech sprint.
A more sophisticated engagement can involve RegTech POCs developed
between industry and regulators on solutions such as regulatory data
APIs or sharing information via a distributed ledger.
Finally, developing RegTech solutions is a prime area where either an
informal steer or a more formalised guidance from a regulator can
accelerate product development, if made available in a sandbox context.
In turn, engagement with RegTech solutions could inform regulators on
how compliance obligations may be met.
Policy Development
While many grey areas of compliance can be addressed by either
increasing the knowledge of product developers or clarifying
supervisory expectations, some barriers to innovation could require
policy change to be removed.
Industry has called for continuity between regulatory teams both within
national regulators and across regulators internationally. Industry
Sandbox outputs should be available to observer regulators to support
policy development by providing analysis of the potential impact of a
policy change on customers. It may also be helpful if guidance issued
by regulators in direct engagement with industry participants, such as
the FCA's Direct Support function in its Innovation Hub, is shared on
an anonymised basis with other industry participants facing the same
issues during Sandbox testing.
At minimum, regulators should adopt an ecosystem approach to
understand the role new tools could play, such as Industry Sandboxes,
POCs and accelerators to engage, understand, deploy.
38

Living Labs are a research solution developed at the Massachusetts
Institute of Technology ("MIT"). It brings together interdisciplinary
experts to develop, deploy, and test in actual living environments
new technologies and strategies and designs, enabling companies to
quickly respond to our ever-changing world with market-tested new
digital solutions and collaborations. Living Labs are the successor to
the focus group: instead of measuring what people say they do, we
measure what they actually do.
Testbed for Data Innovation at MIT Connection Science
Testbed for Data Innovation at MIT Connection Science
MIT’s Living Lab in Andorra is helping the government and
businesses to better understand the economic vitality of their main
city, and quickly rearchitect the dynamics of human interactions
to respond to changing conditions. A rich data set compiled from
anonymised, aggregate mobility and social interaction data streams
enables very fine-grained understanding of critical dimensions
such as transportation, tourism, and health. Our new program in
Colombia is helping the government to realize the peace dividend,
and use advanced data analytics to spur economic development.
Topic areas in process across our Living Labs network include topic
areas such as transportation, health, and prosperity, as well as
enabling infrastructure areas such as digital identity, digital privacy,
cybersecurity, and digital currencies.
MIT Living Labs help organisations develop best practice for
leveraging data, improving how we collect, manage, and use personal
information, with outcomes ranging from setting appropriate privacy
policies to demonstrating systems that can be implemented in
practice.
Example of Living Labs in Financial Services
Working with a real bank in Europe, against over 400,000 customer
accounts, we have demonstrated an improvement to credit modeling
for behaviors such as late payment, over limit, or credit default
that are 30% to 50% better than traditional demographic or linear
regression models. Furthermore, our models predict adverse
credit events 30 to 60 days in advance, unlike credit bureau-based
solutions (FICO, Experian, Equifax, TransUnion) that utilize a “rear
view mirror” approach. This solution helps banks better manage
their existing customer base, and extend credit to the unbanked
or underbanked, a population estimated to be over 2 billion people
worldwide. We also devised a credit model for Small & Medium Sized
Enterprises (SME’s), which is about 35% more predictive than the
bank’s existing SME credit modeling. SME’s are estimated to have
a $2.6 trillion credit gap globally, and new analytic models based on
real-world evidence can help financial services companies to bridge
ACADEMIC COLLABORATION CASE STUDY -
MIT CONNECTION SCIENCE LIVING LABS
that gap without assuming disproportionate risk. Virtual Living Labs
are also possible: one we ran in the fall of 2016 harvested financial
market predictions from over 130 countries, combining human
intuition with machine learning, to predict the closing price of the
S&P index within 0.1% of actual.
Tiered Sponsors Consortium Membership Model
MIT Living Labs are funded through sponsorship. Sponsorship
is available at several different levels giving sponsors access
to valuable advanced resources by conducting research and
development that is too costly or too far out to be accommodated
within a corporate environment. It is also an opportunity for
corporations to bring their business challenges and concerns to the
group to see the solutions our researchers can invent.
Sponsors Benefits Highlight
• Opportunity to stay informed about emerging technologies,
design ideas, and business strategies;
• Opportunity to meet potential competitors and partners in a
pre-competitive environment;
• Senior Executive Workshop: at higher levels of sponsorship,
a sponsor may request one focused workshop at MIT or at
the sponsor’s facility to explore issues of mutual interest;
• Right to propose collaborative research projects that are of
mutual interest.
• Company Fellowship: Each full sponsor may elect to send
one staff member to MIT for up to one month as a visiting
researcher to participate in research activities, attend lectures,
pursue company research, and make use of many MIT facilities;
• Opportunity to host MIT faculty and research assistants at
company sites so they can learn more about the company and
provide relevant updates on the latest MIT research;
• Ability to meet MIT graduate students who could be recruited to
work at sponsor companies.
Connection to Industry Sandboxes
Interoperability between MIT Living Labs and an Industry Sandbox
is an opportunity to combine institutional test data, market data and
open data with our expertise in setting up industry collaborations to
resolve shared challenges-or wicked problems, to use the language
of the Industry Sandbox Consultation.
Additionally, Living Labs are a method to connect the off-market
testing environment of an Industry Sandbox to living environments
where FinTech products are deployed.
David Shrier, Managing Director,
MIT Connection Science
39

IMPLEMENTATION
CHOICES
Consultation responses provide sufficient evidence to conclude that a there is demand
for an Industry Sandbox as a shared collaborative environment, particularly as it supports
the evolution of banking-as-a-service business models, and could provide acceleration of
FinTech adoption.
While design principles identified in this Consultation would apply to most Industry
Sandboxes, different design components might be selected at the point of implementation.
Similarly, there is optionality in funding and governance models within the core principles
identified.
Industry Sandbox implementation choices can vary in the objective, complexity, and
respectively cost of the solution.
40

5 .1 INDUSTRY SANDBOX CATALOGUE
A low-cost, low-impact solution could constitute a catalogue of
existing sandbox environments with details on available assets and
access criteria. Such an environment would generate visibility and
comparability of existing sandboxes or API marketplaces, creating a
one-stop shop for developers. It will not require the opening of data
or APIs that are not already available.
A more sophisticated version of this environment might seek to
create a single point of entry to different Industry Sandboxes by
aggregating and streamlining the process of self-certification usually
required to access these.
Critical success factors for this Industry Sandbox will be to aggregate
information from as many sandbox environments as possible,
globally, and create an efficient mechanism through which the
catalogue can expand.
We can call these options an Industry Sandbox Catalogue and an
Industry Sandbox Gateway.
5.2 INDUSTRY SANDBOX FOR WICKED INDUSTRY
PROBLEMS
Adopting an Industry Sandbox can be created around a specific
Wicked Industry Problem such as digital identity, prudential risk
monitoring or RegTech.
The data, APIs and reference architectures in this environment will be
curated to meet the testing needs of solutions solving any particular
Wicked Industry Problem. Certification parameters, including
self-certification, best practice guidelines, open standards or less
formalised components will have to be tailored to the Wicked Industry
Problem.
Eligible users will have to demonstrate a connection between their
solution and the sandbox focus area. Parameters around the wicked
problem can be set by sponsors of the sandbox, according to an
established governance practice.
Success factors for this environment would be that a critical mass of
collaborators gather around a specific industry challenge. As most
such challenges are linked to regulatory issues, the participation of
relevant regulators as observers will likely be a key driver to bring this
type of collaboration together.
Consultation feedback from financial institutions was that supporting
a testing environment with clearly defined scope and purpose will be
preferable to an issue-agnostic environment.
5.3 FULLY FLEDGED INDUSTRY SANDBOX
A maximum-impact, high-cost Industry Sandbox can be built to meet
all three identified objectives – supporting product development,
industry collaboration and effective regulation.
This type of environment would be consistent with all the design
principles and incorporate most design components identified in this
consultation, and will likely evolve further in scope and sophistication.
We note that securing funding for this type of environment might be
a key challenge. Starting from an ambitious project also would not
allow Industry Sandbox developers to learn from building smaller,
more focused testing environments. Therefore, this type of sandbox
is likely an end-phase of a more measured project plan.

41

6.1 UMBRELLA SANDBOX
The FinTech market continues to grow and many regulators are
assessing how they address the needs of startups for direct
support and guidance through the regulatory process.
Regulators could participate directly in the Industry Sandbox
community to help promote understanding of new technologies and
trends within financial services firms. Their involvement may also
provide early sight of possible regulatory questions arising from new
and innovative technology, helping to prioritise key resources and
optimise operational approaches.
New technologies need time and space to develop a better
understanding of their potential impact before any regulatory
assessments can be made. Yet, making that first step as a startup,
investor, or financial institution requires a great degree of certainty
in regulatory treatment. Greater collaboration with regulators
would allow for a more consistent link between the innovation hubs
sitting within financial institutions and the rest of the organisation,
ultimately allowing a better opportunity for FinTech to be adopted
and integrated.
There is also a balance to be struck between the use of principle-
based regulation and an industry that may appear at times to be
asking for a rules-based approach. Unintended consequences, or a
blurring of the lines between the two approaches, can be avoided by
the greater collaboration and sharing of knowledge afforded by an
Industry Sandbox.
Industry could arguably fill a gap in curating these necessary
conversations, lifting some of the burden currently on regulators
to effectively and productively share regulatory knowledge in the
FinTech community. Ultimately this raises the question: ‘is there
space for industry players to have any delegated authority as a step
to reduce the regulatory burden?’
In the FCA Regulatory Sandbox Report of November 2015, industry
was invited to consider an “umbrella sandbox”-a not-for-profit
sandbox umbrella company that could seek authorisation from
the FCA and then allow innovative businesses to act as ‘appointed
representatives’ for the duration of the trial in question.
As per that report, the FCA would help with setting up the umbrella
and provide ongoing support and advice.
We believe this question can only be properly explored in a separate
consultation process.
NEXT
STEPS
6
6.2 ACCESS TO LIVE CUSTOMER DATA
Access to live customer data was left out of scope for the purposes
of this Consultation. It needs to be noted, however, that the issue
was repeatedly raised as the concept of developing a community
We often talk about sandboxes emulating Federal Drug
Administration drug trials in financial services. The reality is that
a Regulatory Sandbox can be compared to the final stage of a
drug trial, where a medicine is tested on a large patient sample.
This leaves a gap in developing testing environments for earlier
stages, when the sample populations are in the tens or hundreds.
Allowing digital access to volunteer beta-testers in an Industry
Sandbox could be that mechanism.
- Michael Meyer, Founder, RegTechLab
6.3 DEVELOPING AN INDUSTRY SANDBOX
As per the agreed scope of this Consultation, this Report assesses
the demand for, feasibility of and role of regulators in an Industry
Sandbox. A next step for the Industry Sandbox initiative would
be leveraging these findings towards the development of one, or
multiple, Industry Sandboxes. The Consultation team anticipates
that different groups of industry players would come together to
build shared sandboxes that align with their respective priorities
and stakeholders. A key consultation recommendation is that
such projects are open, collaborative and interconnected to avoid
the duplication of effort and spread of resources in the next
phase of FinTech open innovation. Maintaining transparency and
efficient flow of knowledge would be critical. To that end, sandbox
developers could consider what design components could be
shared between different Industry Sandboxes. Participants' Forums,
Regulators' Observer Forums in particular, or Certification Capability
might be two such components.
of real-life beta-testers was reviewed in this Consultation. Most retail
market products would seek to access such a community as part of
their product development.
In financial services, access to live customer data would clearly need
to comply with relevant data protection regulation. In the context of
the EU General Data Protection Regulation, any third party accessing
non-anonymised customers’ transactional data would need to
receive explicit consent. Under PSD2, the third party would also need
to be formally authorised as such.
This leaves a potential gap, whereby a startup cannot access the data
of a limited number of consenting customers prior to seeking third-
party authorisation under PSD2, for product validation purposes.
Such access, with any associated liability management and
insurance cover, could be contractually arranged between an Industry
Sandbox and a financial institution.
Using such governance arrangement to equip an Industry Sandbox
with a community of willing beta-testers can further support the
validation of innovative products.
42

ANNEXES
Annex 1: FCA Invitation Letter
Annex 2: Innovate Finance Member Sandboxes Proposal
Annex 3: Summary of Consultation Governance and Input
Annex 4: Survey Results
Annex 5: Detailed Summary of Sample Sandboxes (incl. Pistolia &
Boston)
Annex 6: BBA Response to Call for Input
Annex 7: What are Industry Sandbox Design Sessions?
ACKNOWLEDGEMENTS
43

ANNEX 1:
FCA INVITATION LETTER
44

ANNEX 2:
INNOVATE FINANCE MEMBER
SANDBOXES PROPOSAL
46

MAY 2016 JULY - AUGUST 2016
SteerCo
Kick Off
Consultation Launch
Global Stakeholder Mapping
Industry Survey
SEPTEMBER 2016
OCTOBER -
NOVEMBER 2016
Industry Rountables
Hypotheses Validation
via Design Sessions
Call For Input
22nd
NOVEMBER 2016
13th
JANUARY 2017
Consultation Findings Preview
INNOVATE FINANCE
GLOBAL SUMMIT 2017
FEBRUARY 2017
Consultation Report
MAY 2017
FCA Invitation to
Chair Consultation
INNOVATE FINANCE
GLOBAL SUMMIT 2016
Consultation Timeline
The consultation process was overseen by the following Steering Committee:
Technical Advisory Board (technical expertise)
1. Jean Donnelly, Executive Director, FinTech Sandbox
2. Chris Gorst, Prize Lead, OpenUp Challenge, NESTA
3. Keith Saxton, Chair Financial Services & Payments
Programme, techUK
4. Peter Smith, Global Head of Industry Policy Liaison,TISA
5. Barry West, Senior Associate / RegTech Team, FCA
Industry Advisory Board
1. Matthew Field, Policy Adviser, Digital, BBA
2. Ruth Milligan, Head of Financial Services &
Payments, techUK
3. TISA
SteerCo
1. Lawrence Wintermeyer, CEO, Innovate Finance (chair)
2. Sarah McKenzie, Anna Wallace, Innovation Hub, FCA
3. Rachel Kent, Global Head of FIS, Hogan Lovells
4. Ozlem Bas, Policy Adviser, HMT (observer)
Secretariat: Innovate Finance
1. Dea Markova, Head of Programmes (project lead)
2. Daniel Morgan, Director of Policy and Regulation
Delivery Partner, Design Sessions:
Innovation Arts
Delivery Partners: Legal and Governence
Hogan Lovells
Global subject matter experts (technological, sandbox,
ecosystem etc)
ANNEX 3:
SUMMARY OF CONSULTATION
GOVERNANCE AND INPUT
48

ANNEX 4:
SURVEY RESULTS
Q1
0%
10%
20%
30%
40%
50%
60%
Strongly
agree
Agree Neither agree
nor disagree
Disagree Strongly
disagree
Facilitated access to relevant datasets will expedite
my company’s route to market
52%
31%
3%
0%
14%
Q2
0 10 20 30 40 50 60
AML/KYC Data
Credit Data
Anonymized Customer Transaction Data
Global Market Data (Live & Historic)
Social Media Data
Company Data
Loan Morgage Data
Reference/ Compliance Data
Financials
Holdings Data
Sample Holdings Portfolios (Multi-Asset)
News & Research
Security Price Data (Tick History )
Benchmark Data
Economic Data
Real Estate Data
Corporate Fundamentals
Others (please specify)
Operational Data
What datasets would your company be interested in having access to in an
off-market testing (e.g. sandbox) enviroment?
57%
50%
50%
43%
37%
37%
37%
37%
30%
27%
30%
23%
23%
23%
23%
13%
13%
10%
10%
0 1 2 3 4 5 6
What other sandbox ‘assets’ could decrease the time and cost associated with developing your product / service?
(lower score = higher preference)
Access to integrate tools / APIs 3.00
Access to a development environments (sandboxes) 3.19
Support with procurement into ﬁnancial institions 3.34
Legal advice 4.68
Access to hosting environments 5.35
Access to software 5.35
Access to pre-build solution stacks 5.41
Consulting services 5.56
Q3
STARTUPS
STARTUPS
STARTUPS
49

0
10
20
30
40
50
60
70
80
Strongly agree Agree Neither agree
nor disagree
Disagree Strongly
Disagree
50%
23%
44%
69%
6% 8%
0% 0% 0% 0%
My Institution current actively engages with FinTech startups
Financial Institution
Technology Vendor
Q4
Q5
0 20 40 60 80 100
88%
69%
38%
63%
13%
Constituting a business development
Supporting engagement with institutional clients
Representing an investment opportunity
Accelerating internal innovation
Other (please specify)
Engagement with FinTech and Startups supports our business by
0.0 0.5 1.0 1.5 2.0 2.5 3.0
Our institution’s procurement process for
startups can be made more efﬁcient
Developing multiple proofs-of-concept is
relativly costly and time consuming
It is difﬁcult to integrate FinTech startups
at scale into our production
It is challenging to navigate the volumes of
external innovation of potential business interest
Please rank the following potential challenges in sources innovation externally
(1:Strongly agree, 5: Strongly disagree)
1.85
2.13
2.15
2.31
2.15
2.88
2.31
2.07
Financial Instutute
Technology Vendors
Q6
TECHNOLOGY VENDORS
50

0
20
40
60
80
100
No
Yes
Financial InstitutionTechnology VendorStartup
Have you or your company worked in sandbox enviroment before?
33%
67%
100%
54%
46%
0
10
20
30
40
50
60
Strongly disagreeDisagreeNeither Disagree nor AgreeAgreeStrongly Agree
My organisation would contribute to the development of a sandbox as shared industry utility
56%
23%
31%
23%
6%
31%
0%
23%
6%
0%
Technology Vendor
Financial Institution
Q7
Q8
51

0 20 40 60 80 100
What Sandbox ‘assets’ could your organisation contribute to a sandbox environment?
Access and integration tools to system APIs
Consulting services
Access to pre-build solution stacks
Access to development environments (sandboxes)
Access to software
Access to hosting environments
Support with procurement into ﬁnancial institutions
88%
75%
69%
69%
75%
56%
31%
31%
Q9
Q10
0 5 10 15 20 25
My business area and / or organisation will be able to contribute any assets to an industry sandbox
Agree: access to systems via sandbox / APIs
Agree: access to certain types of
data via data feed / APIs
Agree: access to other sandbox assets
Disagree
8%
23%
23%
23%
15%
TECHNOLOGY VENDORS
FINANCIAL INSTITUTIONS
52

Q11
0
10
20
30
40
50 Financial Institutions
Technology Vendor
Strongly DisagreeDisagreeNeither agree or disagreeAgreeStrongly Agree
50%
23%
44%
46%
6%
8%
0%
8%
0%
8%
My Organisation could beneﬁt from the development of an sandbox as a shared industry utility
0.0 0.5 1.0 1.5 2.0 2.5 3.0
Financial Institutions
Technology Vendor
Startup
Leverage sandbox output towards development
of applicable regulatory / supervisory approach
Use sandbox to identify RegTech
solutions for FCA use
Make further feedback on regulatory
treatment available to sandbox participants
Review sandbox tests inauthorisation
or supervisory decisions
2.04
2.00
1.67
2.21
2.08
1.71
2.04
2.15
1.79
2.00
2.58
1.86
This type of FCA engagement would contribute to a sandbox environment:
(1: Strongly agree, 5: Strongly disagree)
Q12
53

ANNEX 5:
DETAILED SUMMARY OF
SAMPLE SANDBOXES
Boston FinTech Sandbox
Industry
NESTA Open up Challenge Sandbox
Industry
TISA Exchange
Industry
Level One Project
Industry
Industry
Open Stack India
Industry
Proprietary
Capital One DEVEXCHANGE
Sandbox
Proprietary
Salesforce Sandbox
Proprietary
Cisco DevNet Sandbox
Proprietary
Proprietary
RBS Bank of APIs
Proprietary
Starling Bank Sandbox
BBVA API Market
and Sandbox
Proprietary
Fidor Banking API
Proprietary
API Market Place
programmableweb
API Market Place
MashApe
API Market Place
Akana API Economy
Plaform
API Market Place
For Profit
Alphapack Sandbox
For Profit
TESOBE Open Bank Project
For ProfitGOV.UK Verify
Sandbox
Other
Other
Sandbox
(Country)
Description Users Funding Data Technologies
Boston FinTech
Sandbox
(United States)
Boston-based non-profit providing eligible
startups with free access to predominantly
market data.
FinTechs. Businesses should be
physically located in one of the
four cities: London, Boston, New
York or San Francisco.
Platinum Sponsors: Fedelity , F-Prime
Capital, Thompson Reuters, Silicon Valley
Bank, Amazon Web Services, Intel, State
Street
Sliver Sponsors: SIX, Goodwin
Procter LLP, 406 Ventures
Market and Industry Data
Providers include: Thomson
Reuters, FACTSET, Morningstar,
S&P, CME, Moody's Analytics, etc
Infrastructure and Platform as Service
solutions offer up to $15,000 in credits
per startup to Amazon Web Services plus
Business-level AWS Support up to $5,000
per startup.
Level One Project
(United States)
Funded by Bill and Melinda Gates Foundation.
Level One Sandbox is intended for those who
have a need to access a reference ecosystem as
part of their development work. It has 3 mobile
wallet providers, an interoperability service for
transfers, a bulk payer and a bank represented
within the ecosystem. The downloadable API
would be used to integrate into the system. The
sandbox is representative of a vision for a pro-
poor digital financial services ecosystem, but
does not map directly to any systems deployed
in the real world today.
FinTechs, Banks, Telecoms (1) Not-for-profit/cost recovery model.
(2) Participants pay fees (as determined
by predetermined rules) sufficient to
cover costs, as well as any investment or
innovation capabilities deemed necessary
to the system.
(3) Private-sector entity is commissioned
to operate some shared component of
the system while the profits of that entity
should be subject to scrutiny and limits.
Framework/Infrastructure
(1) Open Loop interoperability between all
providers – the system should be open to
all actors, including FIs and regulated non-
traditional financial services providers.
(2) Immediate Funds Transfers and Same
Day Settlement – Provides immediate
notification of payment from the payer to the
payee, transfers funds. The system should
settle funds among participants at least
once a day, on the same day. This is the
most efficient way of managing liquidity.
(3) Push Payments – Person who initiates
transaction should always be the payer.
May provide ‘request to pay’ service, but
authorization rest with the payer.
(4) Adherence to Open, International
Standards – The system should adhere
to internationally accepted payments
standards (ISO20022).
(5) Adequate and Shared Fraud Service –
Shared risk management leads to lower
fraud and more secure schemes.
(6) Efficient and Tiered KYC – Account
opening requirements should vary based on
need, level of transactions, services provided.
(7) Transaction Irrevocability – The system
should not allow transaction reversal unless
in extreme circumstances in order to reduce
complexity and cost.
NESTA Open Up
Challenge Sandbox
(United Kingdom)
A new £5m challenge prize for the future of small business banking,
getting ready for UK "Open Banking" in early 2018.
Open Banking Ltd (formerly the Implementation Entity) is the
delivery body responsible for developing the open banking API
standards and frameworks. Its work will be led by a Steering Group
and informed by Advisory Groups.
FinTechs The Open Up Challenge is run independently by
Nesta's Challenge Prize Centre, with backing from
the CMA and funding from eight of the UK’s largest
providers of SME banking Barclays, HSBC, Lloyds
Banking Group, RBS, Santander, AIB Group (UK)
p.l.c, Bank of Ireland UK and Danske Bank.
Open Banking APIs Open Banking APIs
54

Sandbox
(Country)
Description User Funding Data Technologies
TISA Exchange
(United Kingdom)
Having open standards and a structure which
encourages multiple players, TISA Exchange promotes
competition, and instigates the drive to improve
performance and reduce cost.
It is only open to custodians,
trustees and firms that run
institutional and retail funds.
Subscription model, where a schedule of payments
was design to cover the initial setup cost and the
ongoing operational costs, with founding members
effectively receiving a rebate. Initial fees were
£12,000 pa, reduced to £5K and £2K. Set up cost
was near £500,000.
Market Data
Open Stack India
(India)
The OpenStack Foundation is an independent body
providing shared resources to help achieve the
OpenStack Mission by Protecting, Empowering, and
Promoting OpenStack software and the community
around it, including users, developers and the entire
ecosystem.
OpenStack is for service
providers, enterprises,
government agencies and
academic institutions that want
to build public or private clouds.
Industries range from IT and
telco to SaaS and eCommerce
to finance and healthcare.
Platinum Members : AT&T, ubuntu, Huawei, IBM,
Intel etc.
Gold Members: Cisco, Dell EMC, Ericsson, Fujitsu,
NetApp
Infrastucture Donors: Rackspace, Vexxhost, Hewlett
Packard Enterprise
Corporate Sponsors: Accenture, BBVA, Comcast,
Lenovo, Nokia, Orange
Supporting Organizations: AppDynamics, Catalyst,
Cognizant, Dynatrace
www.openstack.org/foundation/companies
Capital One
DEVEXCHANGE
Sandbox
(United States)
Philosophy: We’ve done the heavy lifting so you
can focus on creating great customer experiences.
Powerful technology
that goes beyond banking.
Testimony: By making available the foundational
blocks to abstract complex financial rails and
core backend processes as well as their other
natural assets (access to low-cost capital, strong
customer base and brands) banks will help unbundle
the financial services sector, create new vibrant
verticals, and build alternatives to traditional banking
consumer experiences.
Open to all customers with
registrations
Capital One API products covers, (1)
identify authentication through
registered mobile device, (2)
Credit Offers of personalized
list of credit cards, (3)
Rewards on miles, points, and
cash earned on bank accounts
and (4) Bank Account.
Salesforce
Sandbox
(United States)
Four sandbox types available:
1. Developer Sandbox – intended for development
and testing in an isolated environment
2. Developer Pro Sandbox – host larger data sets
than a Developer sandbox, and to handle more
development and quality assurance tasks and for
integration testing or user training.
3. Partial Copy Sandbox – support UAT user
acceptance testing
4. Full Sandbox – support performance testing, load
testing, and staging.
Premium on licences-based model. Different
sandbox environments and licenses that depend
on customers’ needs for storage, templates, copy
configuration, and frequency of refresh.
Sandbox Licence:
(1) Full Sandbox licence
(2) Partial Copy Sandbox licence
(3) Developer Pro Sandbox licence
(4) Developer Sandbox licence
Salesforce data (1) Analytics
(2) Reports and Dashboards
(3) Salesforce Development Tools
(4) Debugging Suites
(5) Testing framework.
Cisco DevNet
Sandbox
(United States)
There are two types of sandboxes, Always-On and
Reservation. Each sandbox typically highlights
one Cisco product (think, CallManager, APIC, etc).
Sandboxes can be used for development, testing
APIs, learning how to configure a product, training,
hackathons, and much more
Developers Cisco Third-party data Sandbox Catalog
(1) Networking
(2) IoT
(3) Datacenter
(4) Collaboration
(5) Cloud
(6) Analytics & Automations
(7) Security.
RBS Bank of APIs
(United Kingdom)
Driven by 48-hour Hackathons, in a team of coders,
designers, and business people to create a working
prototype to showcase. IP belongs to participants.
FinTechs, Banks, Individual
developers
RBS Blue Bank API allows you
to log on as a simulated
customer, enumerate the
set of accounts belonging
to the customer, enumerate
transactions and make
simulated payment requests.
The API also provides branch
and ATM information.
Starling Bank
Sandbox
(United Kingdom)
The first UK licensed bank to launch a public API
that's ready for PSD2
Starling has built a public API that will enable
third-parties to access customer data (with their
permission, of course) and build on top of the
Starling Platform to create products and services
that customers will love.
Beta version users
developers
Starling Bank PSD2 APIs
BBVA API Market and
Sandbox
(Spain)
FinTechs There is no cost associated with
accessing and using the APIs in the
sandbox environment.
For using the APIs in the production
environment there is a cost based
on the services to consumed and
their intended use.
API catalog include Payments, PayStats,
Notifications, Customers, Accounts,
Cards, and Loans.
In response to Revised Directive
on Payment Services (PSD2)
to promote secure and fast
online, mobile, and cross-border
payment transactions and
to accelerate digitalisation
of banking industry, BBVA
implemented account information
services (AIS) and payment
initiation services (PIS) available
at its API marketplace.
Fidor Banking API
(Germany)
Munich-based Fidor is the first digital-only bank in Germany. Fidor
commercializes its tech stack to banks and startups around the
world. The sandbox in test environment offers users the same
functionality as the live API, so users can start developing their
applications without risk of losing money or unintentionally altering
data.
FinTechs Registering, using, and testing with
the APIs in the sandbox is free of
charge.
If members plan to offer third
party services to existing Fidor
Bank customers or need extended
services (e.g. trust account), contact
Fidor Business Development.
Potential monthly flat fee: EUR 14,90.
API specific for mobile app
development,
Money Transfer, Transactions Filtering,
Future payments, High-level user
information, Create a Customer, etc
RESTful API, JSON format, and
OAuth2.0 authorization.
55

Sandbox Description Users Funding Data Technologies
programmableweb
(United States)
ProgrammableWeb provides daily industry news, analysis, case
studies, developer tools, technical resources, and the world’s
largest directory of APIs.
Developers
All members listed in public
directory
Advertisement
Request a Media Kit
Feature
1. run-of-site or targeted ads
2. content and channel targeting
3. geographic filter
4. network advertising
5. social media advertising
6. newsletter advertising
Third-party APIs Features
(1) API news and analysis
(2) API directory listing and search
(3) API showcase in applications
(4) API research, whitepaper,
conference
(5) API education, how-to, source
code
(6) Member directory
MashApe
(United States)
MashApe's mission is to facilitate a new revolution in software
production by serving as the backbone of the distribution and
consumption of data and services through APIs.
Developers MashApe Third-Party APIs The open-source API Gateway
(1) RESTful interface
(2) Plugin Oriented
(3) Platform Agnostic
(4) Simple Scaling
The Analytics Platform for APIs,
Microservices and Serverless
Software.
Akana API Economy
Platform
(United States)
The Akana Platform provides an end-to-end API Management
solution for designing, implementing, securing, managing,
monitoring, and publishing APIs. It is available as a SaaS platform,
on-premises, and as a hybrid deployment.
The world's largest
companies including
Bank of America, Pfizer,
and Verizon use Akana
products to harness the
power of their technology
and transform their
businesses.
Akana is a privately held company
backed by leading investors
including:
(1) Redpoint Ventures
(2) Draper Fisher Jurvetson
(3) Palisades Ventures
(4) Paladin Capital Group
(5) Navigation Capital Partners
Akana APIs The Akana (formerly SOA
Software) API Gateway solution
streamlines management,
deployment, development
and operation of APIs,
enhancing security and
regulatory compliance through
authentication, authorisation and
audit capabilities.
(1) Authentication and
Authorisation
(2) Message Security
(3) Threat Protection
(4) Orchestration, Mediation and
Transformation
(5) Analytics and Monitoring
(6) Unified API and SOA (REST/
XML, REST/JSON and SOAP)
Sandbox
(United States)
A software deployment platform that empowers regional banks
and credit unions to quickly and safely try new software from third
party developers often startups. The product solves data security
and legacy system integration problems that currently cripple a
financial institution's (FI) ability to work with unproven vendors.
Developers, Banks and
Credit Unions
For-profit company banking APIs For developers:
(1) Build software using
standardised, RESTful banking
APIs
(2) Add configuration and wrap
services in Docker
(3) Use the CLI to upload new
releases of software to the
catalog
(4) 4. Bank employees install the
software against data sources
they select
For Banks & Credit Unions:
(1) Pick a vendor or bring your
own
(2) Sandbox connects to your
systems quickly
(3) Safely try out software
throughout your organisation
without burdening IT
(4) Once you're happy, deploy to
production with confidence
TESOBE Open Bank
Project
(Germany)
Banks can start using Open Bank Project (OBP) in sandbox mode
for innovation programs or proof of concepts (POCs) with startups
and then quickly transition to a production configuration in which
OBP interacts with the core banking systems of the bank.
developers
For-profit company 130+ RESTful APIs covering transaction
history, payments, entitlements and
metadata.
Built on a secure, enterprise ready
technology stack that supports
secure Internet protocols such
as OAuth
GOV.UK Verify Sandbox
(United Kingdom)
The Verify Sandbox Environment will enable interested parties
test how their services would incorporate digital identities that
meet GOV.UK Verify standards. It allows these interested parties
to consider the operational and technical implications of adopting
Verify through a test infrastructure so as to inform their business
cases and roadmaps for adoption.
Any organisation that
wants to test and learn
about Verify can do so
by engaging with a self-
certified hub provider.
UK Government Initiative The Identity Providers will enable a
credential Authentication and the return
of the matching data set.
Where the Hub Provider offers the
OpenID Connect protocol it is best
practice to align with the self-
certification requirements defined
by the OpenID Foundation defined
via the OIXnet website.
56

ANNEX 5:
BEST PRACTICES FROM LIFE SCIENCES:
THE PISTOLIA ALLIANCE
by Rob Gill, HCL
The Pistoia Alliance is a non-profit membership association set
up to solve shared challenges in life science R&D by means of
pre-competitive collaboration. Data analysis and management
software, data format and communication standards, and
information management best practices were all identified as
areas where significant efficiencies could be achieved without
affecting competitive advantage. Solutions generated are released
free of charge and without restriction for the benefit of the whole
life science industry. Pharmaceutical company members are able
to achieve early wins by supporting projects that directly meet
their requirements, while technology vendor members are able to
demonstrate their expertise and goodwill while gaining an improved
understanding of their customer’s needs that can develop into new
product opportunities.
Tiered annual membership fees cover the running costs of
the organisation and also contribute towards the development
of business cases for potential projects. Projects are funded
separately with dedicated fundraising from members, and only
members may volunteer their staff to participate in a project. The
membership is diverse and includes pharmaceutical companies,
academic research groups, technology vendors, publishers, and
SMEs. Most of the world’s largest pharmaceutical companies are
involved. Tightly defined policies set out the rules by which conflict
of interest, intellectual property, and monopoly issues are managed,
and all members are bound to follow them at all times while working
on a Pistoia Alliance project.
Newly proposed project ideas are socialised among key member
contacts with only the best taken forward for development of a
business case. Once the business case is written and has attracted
sufficient funds to proceed, a paid project manager is appointed,
overseen by a steering committee with one volunteer representative
from each funding organisation. The committee defines the
project’s priorities while also bearing in mind the needs of the
wider community. The remainder of the project team, tasked with
actually delivering the work, are volunteers from Pistoia Alliance
member organisations. All work is monitored by the Pistoia Alliance
operations team which in turn reports to an elected board of
directors. A separate advisory board provides guidance on strategy
.
A recent successful Pistoia Alliance project has been Ontologies
Mapping. Life science research is a distributed task, with
pharmaceutical companies simultaneously consuming publicly
available academic output, contracting out routine experiments,
and privately generating commercially sensitive data within
their own four walls. Each of these flows of information must
be combined and analysed to produce the results necessary to
progress candidate drugs through the pipeline, to verify their safety
and efficacy, and ultimately gain confirmation from the regulatory
authorities that the product can be launched to market.
Combining these data sources effectively requires an understanding
of what data is represented and what the values mean, both of
which can be facilitated by the use of dictionaries of controlled
vocabularies, also known as ontologies. When data moves between
organisations, the ontologies used in that data must be shared and
translations made to facilitate linking of data. These translations,
or mappings, must be continuously maintained over time as the
underlying ontologies evolve. Any organisation using a private
ontology not known to others must produce its own mappings for
internal use. Publishers of academic data using obscure ontologies
also benefit from providing mappings to established standards that
make their resources accessible to a wider range of users.
The Pistoia Alliance set up the Ontologies Mapping project
to establish best practice and a common toolset to enable
organisations to create and maintain these mappings, replacing
what was previously an ad-hoc and time-consuming process that
varied significantly from one organisation to the next. Over 100
individuals signed up for the kick-off meeting, and almost 400 for
the most recent project webinar, clearly demonstrating the high
level of interest and engagement that this project has generated
across the industry.
57

ANNEX 5:
BEST PRACTICES FROM FINANCIAL
SERVICES: FINTECH SANDBOX
by Jean Donnelly, Executive Director, FinTech Sandbox
The Basics
The financial services industry relies to a great extent on FinTech
startups to tackle difficult technological challenges, create new
paradigms, and drive innovation. But FinTech entrepreneurs have
a unique problem, which is the high cost of data they need to build
applications. FinTech Sandbox is a Boston-based nonprofit fostering
innovation by providing free, streamlined access to critical data and
resources to FinTech entrepreneurs and startups around the globe.
Since 2015, we have worked with startups, data providers, and
financial institutions to accelerate product development for financial
services.
By having a Sandbox where startups can iterate on their product,
significant advances can be made. The goals of the FinTech
Sandbox are to:
• Provide a functional leg-up for FinTech entrepreneurs
• Foster a GLOBAL collaborative FinTech community
• Make an enduring impact on the state of FinTech data
and API access
“As FinTech entrepreneurs and investors we started FinTech
Sandbox because we saw that access to data was a large barrier
to innovation. By providing free data and infrastructure for FinTech
entrepreneurs, we can fuel the development of important new
technologies to the benefit of the entire industry.”
- David Jegen, co-founder of the FinTech Sandbox
For the Startups – The FinTech Sandbox provides access to
premium data sets to advance product development, interactions
with financial institutions and investors who can help guide product
development, as well as participation in events to enable proof of
concept engagements with financial institutions.
“Data – especially financial data – is expensive, and obtaining it can
prove prohibitive to Fintech startups. Our partnership with FinTech
Sandbox allowed us to access the level of data we needed and
determine what information was truly beneficial to what we were
trying to achieve…”
- James Isilay, co-founder of Cognism, FinTech Sandbox alumnus
For the Data Partners – By providing access to their data sets, data
partners are front row to the next generation of products being
developed and to get feedback on their existing data sets and APIs
for development
“Today’s innovations happen through ecosystems and
communities…”
- Ranjit Tinaikar, former MD Thomson Reuters
For the Financial Institutions – By providing sponsorship and
feedback, corporations can gain early access to new and innovative
technologies, collaboration with a smart community, and
participation in events promoting advancement of FinTech.
“Getting the right introduction to the right people within these
institutions – can be challenging for small firms. FinTech Sandbox
makes that happen for its members. That is huge.”
- Charles Pardue, CEO of Prophis Technology, FinTech Sandbox
alumnus
Since launching in March of 2015, FinTech Sandbox has partnered
with 32 data partners, 62 startups and worked directly with eight
financial sponsors as well as countless event sponsors. We have
facilitated over 300 conversations with partners and potential
customers to advance the goals of the startups we work with.
The Opportunity
In 2017, we are seeing more financial institutions, technology and
consulting firms, and accelerators looking to advance the Sandbox
concept to create the full infrastructure to allow institutions to
have “innovation technology stacks” where they can plug and play
different new applications and get a better understanding of the
impact on their architecture and integrations. This also allows
greater integration testing for the startups, as well as ability to invite
expanded stakeholders, including regulators and end customers, to
participate.
Innovate Finance and partners have pulled together a detailed
blueprint of how to move forward the concept of the FinTech
Sandbox to a more developed model that can further benefit
multiple stakeholders groups.
58

ANNEX 6:
BBA RESPONSE TO
CALL FOR INPUT
59

ANNEX 7:
WHAT ARE INDUSTRY SANDBOX DESIGN
SESSIONS?
by Charlie King, Director, Innovation Arts
The challenge of open collaboration
Innovation Arts worked with Innovate Finance in their roles as chairs
of the Industry Sandbox Consultation.
The ambition of the Consultation team was that the consultation
process should be open, innovative, collaborative and accelerated.
The FinTech sector, however, is evolving rapidly and has many
different types of player, many of whom compete with each other.
How, then, could we bring together a sufficiently broad
representation of the industry, and have them collaborate and
converge effectively within a tight timeframe?
Creating the optimal conditions for a diverse group of contributors
to align on a complex organisational challenge is precisely the
role of Innovation Arts, a globally-recognised hybrid strategy
consultancy and design agency.
Using a ‘Design Thinking’ based approach, Innovation Arts
facilitated a core group of sponsors through the co-design and
delivery of a series of collaborative working sessions in which wider
groups of industry representatives were able to converge rapidly on
the requisite components and principles of an industry sandbox.
Design Thinking
Simply put, Design Thinking is the application of the principles of
design (that one might associate with product design, media design,
or architecture) to a broader context, such as a business strategy or
an industry-wide consultation on an innovative concept.
By applying principles like divergence, modelling, iteration,
prototyping, and convergence, the outcomes of these working
sessions were made robust and representative, and were arrived at
more rapidly than by more conventional means.
Instead of trying to tackle the objective of building a blueprint for
an Industry Sandbox right from the outset, Innovation Arts takes
participants through a phased non-linear approach which builds to
a shared, aligned and resilient outcome.
In ‘Framing’, the context and principles of the challenge are
understood, as well as the participants’ own divergent viewpoints
and priorities. Through ‘Architecting’, these elements of raw material
are tested and worked in various ways to generate models and
prototypes which are, in turn, challenged and iterated. In ‘Building’,
the elements and principles of a shared proposal are converged
upon and assembled into a product that is ready to ship from
the point of view of all of its co-creators. Finally, in ‘Using’, this
final build is once again challenged by its stakeholders to test its
robustness: either it is ready to deploy, or it should return to the (re)
Framing stage.
Working Sessions
Innovation Arts facilitated industry representatives through a series
of Working Sessions, along the normal consultation timeline, to
arrive at an agreed Sandbox Blueprint that integrated the viewpoints
and motivations of the widest possible industry representation.
On 5th May 2016, a core team from the Innovate Finance, The
FCA, Hogan Lovells, and TISA defined the guiding principles and
ambitions for the consultation process.
From this session, we identified a core set of design ‘sponsors’ to
co-design a working session to be held in November.
On 22nd November 2016, we brought together 40 representatives
from across the industry, to consider the working hypotheses
emerging from the consultation to date, and to converge on the
key elements of an Industry Sandbox; what it should do, and what
components it should have.
On 12th January 2017, 19 stakeholders from across the industry
took the elements emerging from the 22nd November session and
iterated them to arrive at descriptions of feasible types of Sandbox,
from ‘Minimum Viable Product’ to ‘Ultimate Aspirational Product’,
together with requisite governance and funding frameworks.
Overall approach
By taking this approach of integrating collaborative working
sessions into the traditional consultation process, we were able
to conserve the rigour of the consultation, while accelerating the
process, and maximising the depth of collaboration, openness and
innovative thinking – despite the complexity of the stakeholder
landscape.
63

CONSULTATION TEAM
STEERING COMMITTEE
Lawrence Wintermeyer, CEO, Innovate Finance: Chair
Rachel Kent, Partner, Head of Financial Institutions Group, Hogan Lovells
Sarah McKenzie, Innovation Hub / Strategy and Competition, FCA
Ozlem Bas, Policy Adviser – Banking Competition, HM Treasury (observer)
TECHNICAL ADVISORY BOARD
Jean Donnelly, Executive Director, FinTech Sandbox
Barry West, Senior Associate / RegTech Team, FCA
Chris Gorst, Prize Lead, OpenUp Challenge, NESTA
Keith Saxton, Chair Financial Services & Payments Programme, techUK
Peter Smith, Global Head of Industry Policy Liaison,TISA
INDUSTRY ADVISORY BOARD:
BBA, techUK, TISA
Secretariat:
Dea Markova, Head of Programmes, Innovate Finance: Project Lead
Daniel Morgan, Director of Policy and Regulation, Innovate Finance: Policy Advisor
Joy Blundell: Facilitation Associate
Kevin Rook: Research Associate
Communications, Marketing and Design:
Georgia Hanias, Head of Global Communications and Diversity Programmes, Innovate Finance
Jessica Blakey, Marketing Manager, Innovate Finance
Susan Tyler, Brand and Design Associate, Innovate Finance
Delivery Partners:
Charlie King, Director, Innovation Arts and
Pamela Buxton, Consultant, Hogan Lovells
Innovate Finance would like to thank the Steering Committee and Boards, Innovation Arts and Hogan Lovells
for their time, generosity and support throughout this consultation process.
67

www.industrysandbox.org
sandbox@innovatefinance.com
Lawrence Wintermeyer
CEO, Innovate Finance
lawrence@innovatefinance.com
Dea Markova
Head of Programmes, Innovate Finance
dea@innovatefinance.com

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