Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Category Archives: Fintech Opinions
Canada Aims to Regulate AI in Search & Social Media
Regulation | Oct 10, 2023
Image: Unsplash/Austin Chan
The Canadian government, through ISED Minister François-Philippe Champagne, has revealed plans to regulate AI, particularly in how it is utilized to prioritize content display on search engines and social media platforms.
This comes amidst the study of Bill C-27, a bill focused on privacy reform and AI regulation. Notably, the government has opted not to disclose the actual text of the planned amendments to the bill.
Targeted AI Systems
The regulation zeroes in on several classes of AI systems, including those related to employment determinations, service provision, biometric information processing, content moderation on online platforms, healthcare, administrative decisions, and law enforcement assistance.
See: Will Canada’s New Voluntary AI Code Hinder Innovation?
Unlike the European Union (EU), Canada’s regulation includes a category for content moderation and prioritization of content presentation, which is not present in the EU’s regulations. This inclusion could mean more extensive regulation, affecting how platforms like Google and TikTok utilize AI to generate search results, translations, and user recommendations.
By categorizing search and social media results as “high impact” systems, Bill C-27 introduces a slew of regulations and new powers, encompassing risk mitigation, record-keeping, and public disclosures. The Minister can demand record disclosure, mandate an audit, and order virtually any measures resulting from the audit. Non-compliance could result in penalties up to 3% of gross global revenues.
Aligning with Global Powers?
While the government claims alignment with the EU, Canada seems to be an outlier, especially when compared to the EU and the U.S., particularly regarding the regulation of algorithms and discoverability. The specific obligations remain somewhat uncertain due to the non-disclosure of the amendment texts.
See: Experts Urge for AI Regulation: How is Canada Responding?
While many Canadians have advocated for rules to prevent bias and other harms emanating from AI, the inclusion of content moderation and discoverability/prioritization has come as a surprise. Equating AI search and discoverability with issues like bias in hiring or uses by law enforcement has sparked discussions and will likely be a focal point of debates moving forward.
Examples of Unintended Consequences
The stringent regulations on AI, especially in content moderation and discoverability, might stifle technological innovation. Developers and companies might be hesitant to explore and implement new AI technologies due to the fear of non-compliance with the regulatory framework. This could potentially slow down advancements in AI applications within Canada, causing the nation to lag behind in the global tech race.
The financial and administrative burden of adhering to the new regulations might be particularly heavy for SMEs. Implementing, managing, and ensuring compliance with the AI regulations might require resources that many smaller companies lack. This could inadvertently favor larger corporations that possess the necessary resources, thereby widening the gap between large enterprises and SMEs in the digital space.
See: Digital Dollar and Tensions Over Transaction-Monitoring
The regulation of content moderation algorithms might inadvertently impact freedom of expression online. If platforms are mandated to modify their AI systems to comply with government regulations, it might influence what content is surfaced and suppressed, potentially leading to bias or the muting of certain voices and perspectives. This could spark debates and concerns regarding censorship and the impartiality of AI-driven content moderation and discoverability on social media platforms.
Conclusion
Canada’s plan to regulate AI in search and social media content moderation and discoverability marks a significant step in the digital regulation realm. While it addresses numerous concerns related to bias and harm prevention, the surprise inclusion of content moderation and discoverability raises new questions and considerations for digital platforms and businesses. Stay abreast of regulatory updates, subscribe to NCFAs weekly newsletter and join NCFA today.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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3 Bank ‘Sell-down’ Pact at Elon Musk’s X?
Funding | Oct 9, 2023
Image: Unsplash/Alice Pasqual
3 of the seven banks that funded X's acquisition (formally Twitter) - Morgan Stanley, Barclays, and Bank of America, which collectively provided almost 70% of the financing, have reportedly formed a strategic alliance to safeguard their investments amidst the financial chaos.
Elon Musk's acquisition of Twitter, valued at $44 billion, has been a subject of intense scrutiny and speculation, particularly due to the financial turbulence experienced by X, Musk's financial entity.
As reported by Fortune, banks may have formed an alliance, known as a "sell-down letter," is designed to prevent the banks from breaking ranks and is set to expire on January 15th. The letter typically mandates that if one bank receives an offer for its loans, it cannot accept without offering the other members the same deal on a pro rata basis, thereby preventing a “divide and conquer” approach by potential buyers.
Lack of Financial Transparency and Musk's Potential Power Play
The banks involved in the deal have expressed significant frustration due to the lack of transparent financial information provided by X. The scarcity of data has hindered the lenders from presenting a full package to potential purchasers, thereby complicating the process of offloading the debt.
See: Twitter and eToro Partner to Offer Real-time Trading Data and Buy/Sell Options for Stocks and Cryptocurrencies
The banks are optimistic that the appointment of a new CEO, Linda Yaccarino, and the potential hiring of a CFO will enhance financial transparency and provide a clearer view of the books in the future.
Despite the financial turmoil, Elon Musk is speculated to be in a position where he could potentially purchase a substantial portion of the debt that is currently plaguing X, possibly at a significantly reduced rate.
Alternatively, he might negotiate a deal where the banks write off some of the loans, which would enhance X’s financial standing and enable them to safely syndicate the remaining debt. The lack of information available to the lenders makes it difficult for them to sell to other parties, thereby placing Musk in a potentially advantageous position.
FAQ
What is the "sell-down letter" agreement among the banks?
The "sell-down letter" is an agreement among Morgan Stanley, Barclays, and Bank of America, which prevents them from individually accepting offers for their loans without providing the other banks the opportunity to access the same deal, thereby avoiding a competitive undercutting scenario.
How has the lack of financial information from X impacted the banks?
The banks have expressed frustration due to the insufficient flow of financial information from X, which has prevented them from presenting a comprehensive package to potential purchasers of the debt, thereby complicating the financial resolution of the situation.
See: Elon’s Vision for a Twitter Payment System (and then Super App)
How might Elon Musk utilize his position to navigate the financial challenges faced by X?
Musk could potentially leverage the situation by purchasing a significant portion of X’s debt at a reduced rate or negotiate a solution where the banks write off some of the loans, thereby improving X’s financial standing and facilitating the syndication of the remaining debt.
What challenges are the banks facing in selling the debt to other investors?
The banks are unable to sell the debt to investors as initially planned due to the rapid deterioration of X’s finances since Musk’s takeover. They are now left holding all of it on their balance sheets, and the only way to unload the loans might be by accepting deep discounts from potential buyers, such as hedge funds.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Insights into CFOs Strategic Recalibration
Survey Insights | Oct 4, 2023
Image: Unsplash/Ch pski
In the face of economic and technological shifts, CFOs and finance leaders are recalibrating their strategies, balancing the imperative of cost control with the potential of technological advancements.
Insights from two pivotal surveys, one conducted by U.S. Bank and the other by Stripe, provide a comprehensive view of the current and future landscape of finance departments globally. Below are some key insights from the amalgamated findings:
1. Prioritization of Cost Control
- The U.S. Bank survey indicates a significant shift towards cost control within finance departments, with 38% of CFOs prioritizing internal finance-function cost control, even surpassing the emphasis on maintaining costs across the entire business.
- Driving revenue growth was the fifth-highest priority (23%), up slightly from 2022 but down from the second-highest priority (35%) in 2021.
- 56% of finance leaders currently struggle to balance cost cutting and building resiliency with investment in future growth, up from 46% in 2021.
- This insight points towards a defensive and conservative approach adopted by finance leaders, potentially driven by prevailing economic conditions, such as the end of the low-cost capital era and persistent inflation in some sectors.
2. Tech Integration and Automation
- The Stripe survey reveals a strong inclination among finance leaders towards technological advancements, with nearly 40% listing "digital technologies to automate financial operations" as one of the top initiatives they are most excited about in 2023.
- Despite the current manual handling of a significant portion of back-office operations, there is a palpable excitement about employing technologies and innovations to streamline processes and enhance efficiency, albeit with a balanced approach that does not completely eliminate human intervention.
3. Increased Appetite for Digital Payments
- 68% of respondents intend to use instant payments (i.e. FedNow Service) two years from now. The survey found that 42% currently use real-time payments, up from 38% in 2022.
4. Data Consolidation and Management Challenges
- The Stripe survey highlights that 63% of finance teams use more than 10 different systems to access crucial business metrics, and 55% of finance leaders aim to consolidate software programs within the next one to two years, primarily to centralize data.
- This insight underscores the challenges faced by finance departments in managing data across multiple systems and the strategic importance of data centralization in facilitating faster, more accurate decision-making and driving business growth.
Walking A Tight Rope
These insights collectively underscore the evolving landscape of financial management, where CFOs and finance leaders are navigating through the complexities of economic challenges while also aspiring to harness the potential of technological advancements to streamline operations, enhance efficiency, and facilitate strategic, data-driven decision-making.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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The UK’s PRA Commitment to International Competitiveness and Growth
Regulatory Insights | Sep 21, 2023
Image: Vicky Saporta, Executive Director, Prudential Policy Directorate at the Bank of England
A recent speech by Victoria Saporta at the Bank of England conference sheds light on the Prudential Regulation Authority's (PRA) vision and its commitment to bolstering the UK's position as a global financial hub focusing on international competitiveness and growth.
- Victoria Saporta, Executive Director, Prudential Policy highlighted the PRA's new secondary objective, which emphasizes facilitating the UK economy's international competitiveness and growth over the medium to long term. This objective aligns with international standards, ensuring that the UK remains a key player on the global stage.
- The PRA's approach to this objective isn't entirely new. They initiated a conversation about a year ago with a Discussion Paper that outlined their policy approach. Saporta's speech in February further solidified the PRA's stance, proposing regulatory foundations that would guide their approach.
Three Pillars of Competitiveness and Growth
See: Canada’s Competition Problem: 7 Reasons
Saporta outlined three main foundations that the PRA believes are crucial for harnessing the UK’s strengths:
- Trust: A strong emphasis on maintaining trust in the PRA and the UK's prudential framework.
- Effective Processes: The need for streamlined regulatory processes and proactive engagement.
- Responsiveness: A commitment to addressing UK-specific risks and opportunities head-on.
A pilot survey conducted by the PRA provided valuable feedback from stakeholders. A whopping 93% of respondents expressed trust in the PRA’s framework, and a similar percentage appreciated the PRA's stable and predictable regulatory environment.
Operational efficiency stands as a key area of focus for the PRA. The authority is taking steps to enhance transparency, with initiatives like more frequent reporting on regulatory transactions.
What Can Canadian Regulators Learn?
Canadian regulators, like their counterparts worldwide, are constantly seeking ways to enhance their regulatory frameworks, ensure financial stability, and foster economic growth. Drawing from the insights of Victoria Saporta's speech at the Bank of England conference and the PRA's approach, here are a few select lessons Canadian regulators can learn:
See: NCFA Response to FINTRAC’s ‘Knee Jerk’ Regulations Requiring Donation Crowdfunding Platforms to Register and Comply with AML/ATF Legislation
1. Embrace a Clear Vision with Defined Objectives
The PRA's new secondary objective emphasizes facilitating international competitiveness and growth. Canadian regulators can similarly define clear, actionable objectives that align with both domestic needs and global standards. These should be S.M.A.R.T goals with measurable outcomes with performance updates being regularly communicated to industry and the public in a transparent and timely manner.
2. Streamline Regulatory Processes and Agility
Operational efficiency is crucial for a responsive regulatory environment. By simplifying processes, adopting technology, and ensuring transparency, Canadian regulators can make it easier for institutions to comply with regulations and for consumers to understand their rights.
3. Engage with Stakeholders
The PRA's pilot survey is a testament to the importance of stakeholder feedback. Canadian regulators can benefit from regular engagement with industry participants, consumers, and other stakeholders to gather insights and refine their approach.
4. Collaborate Across Regulatory Bodies
Financial regulation often involves multiple agencies and bodies. By fostering collaboration and coordination among these entities, Canadian regulators can ensure a holistic and consistent approach to financial oversight rather than create political headwinds or inefficiencies.
Conclusion
Victoria Saporta's enlightening speech at the Bank of England conference underscores the PRA's unwavering commitment to fortifying the UK's stature in the global financial arena. By emphasizing trust, operational efficiency, and responsiveness, the PRA sets a gold standard for regulatory frameworks. The insights gleaned offer invaluable lessons, not just for the UK but for global counterparts like Canada.
See: March 1, 2019: NCFA Submission to the Ontario Securities Commission on Regulatory Burden
As the financial landscape continues to evolve, the principles of clear vision, streamlined processes, engage with stakeholders, and inter-agency collaboration remain paramount. These guiding tenets, as highlighted by Saporta, serve as a beacon for regulators worldwide, ensuring that financial systems are robust, transparent, and in tune with the needs of the times.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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A Scaling Fintech’s Decision “To Bank or Not to Bank?”
Digital Banking | Sep 18, 2023
Image: Unsplash/Susan Q Yin
As the industry matures, the decision to become a bank or remain an independent fintech entity is becoming increasingly significant. The recent decision by Figure, led by its visionary CEO Mike Cagney, to withdraw its bank application has ignited a fresh debate on this topic.
Mike Cagney's leadership at Figure (and Co-founder of SoFi) has always been characterized by forward-thinking and innovation. His decision for Figure not to become a bank wasn't a reflection of the company's inability to do so, but rather a strategic choice rooted in a broader vision for the fintech industry. Cagney's perspective offers valuable insights for other fintech leaders grappling with similar decisions.
When my startup, Figure, recently withdrew our OCC bank application, many in the media took it as a sign that fintechs like us need to become a bank to survive—but that the process is simply too hard. They got it wrong.
- While becoming a bank can simplify licensing processes, it also brings with it a slew of regulatory hurdles and licensing challenges. For fintechs like Figure, which already hold numerous state licenses, the allure of a single banking license might be outweighed by the regulatory constraints that come with it.
- Traditional banking models come with stringent capital requirements, especially for specific loan types. These requirements can make certain financial products uneconomical for banks but lucrative for fintechs.
- Fintechs, unlike banks, trade on earnings, allowing for more dynamic growth opportunities. Banks, on the other hand, often trade on a multiple of book value, potentially limiting their market capitalization growth.
- One of Figure's standout achievements under Cagney's leadership has been its pioneering work with public blockchains. Regulatory views on such innovations can be restrictive for banks who are less flexible, potentially stifling the very innovation that fintechs thrive on.
See: The OCC is Facing Calls to Pull Guidance That Allows Banks to Do Some Crypto Business
Having said that, there are numerous pros of becoming a bank that we shouldn't overlook!
- Fintech companies often have to manage multiple state licenses for various financial services. Becoming a bank would simplify the licensing process, allowing them to operate under a single banking license across states.
- Having one regulator can lead to significant operational and compliance savings.
- Banks have the ability (and the requirement) to accept deposits insured by the FDIC. This can provide a more stable and predictable source of financing compared to wholesale capital markets.
- Banks can access funding backstops such as the FHLB and the Fed Window, which can offer lower costs.
Where Does the Rubber Hit the Road for Growing Fintechs?
For many fintechs, the decision to become a bank is not just about regulatory and capital considerations. It's about identity. Fintechs, at their core, are disruptors. They challenge traditional financial models, introduce innovations, and often operate at the cutting edge of technology.
See: When Big techs and fintechs own banks
The real question is: Can fintechs maintain their innovative edge within the confines of a traditional banking model? Or do they risk losing their unique value proposition by becoming too enmeshed in the very system they set out to disrupt?
As more fintechs reach the crossroads that Figure encountered, they would do well to consider not just the immediate benefits of becoming a bank, but the long-term implications for their brand, their innovation potential, and their role in reshaping the financial landscape.
While the allure of becoming a bank is undeniable, as Mike Cagney's leadership at Figure illustrates, sometimes the boldest move is to chart a course that aligns with the company's core values and vision for the future of finance.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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The Hub OpEd: The Online News Act is Flawed
OpEd | Sep 5, 2023
Image: Unsplash/Austin Distel
In a compelling op-ed by The Hub, the Trudeau government's recent draft regulations for the Online News Act, Bill C-18, are scrutinized. The regulations aim to ensure tech giants like Google and Meta compensate Canadian news media organizations, but the underlying assumptions and approach of the legislation raise significant concerns.
The regulations, designed to clarify the implementation of the legislation, are based on flawed assumptions. They attempt to dictate the intricacies of business-to-business relationships, turning private companies into instruments of public policy. This has significant implications for policy outcomes, public accountability, and market functioning.
The government's stance is that challenges in journalism indicate a market failure requiring policy intervention. However, the Online News Act outsources the implementation of this policy to private platforms, determining which media organizations should receive financial support, which is a questionable approach.
See: Are we headed towards Meta-Banking?
The proposed funding formula for supporting journalism is convoluted. It ties the compensation from tech giants to their global revenues and Canada's share of global GDP, rather than focusing on their Canadian revenues and the journalism sector's share of Canada's GDP. This approach seems to double the level of public subsidies to media organizations without a clear rationale.
While there's a genuine concern about supporting news journalism, especially at the local level, the current approach of the Online News Act is circuitous and flawed. A direct government intervention, transparent and accountable, might be a more effective solution to address the challenges faced by the journalism industry in Canada.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Aligning Fees with Sustainability Goals – Impact Linked Carry
Impact Investing | Aug 23, 2023
Image: Unsplash/John Cameron
In the intricate dance of finance, impact investing is taking center stage, pushing for a harmonious blend of profit and purpose. Drawing insights from a recent PitchBook article, we delve into how limited partners are influencing the alignment of fund fees with sustainability goals.
The Rise of Impact Funds
- Environmental, social, and governance (ESG) factors have become a cornerstone for LP mandates.
- Recent reports, such as the 2022 PwC study, highlight an anticipated growth in ESG-related assets under management (AUM) to a staggering $33.9 trillion by 2026, up from $18.4 trillion in 2021. This surge underscores the increasing importance of sustainable investments in the global financial landscape.
- Despite a general slowdown in PE fundraising, impact-focused funds have shown remarkable resilience. Data from PitchBook reveals that 2022 saw impact funds amass nearly $22 billion across 21 global funds, setting a new benchmark for capital accumulation.
See: Alternative forms of capital will be key to develop sustainable economic systems
- Paula Langton, a renowned figure in fund placement at Campbell Lutyens, noted a surge in sustainability-focused activities. She emphasized the growing willingness of LPs to commit to newer, previously unheard-of entities, especially those centered around climate action.
Impact-Linked Carry
- Furthermore, LPs are now advocating for GPs to tether their carried interest to tangible goals, such as carbon emission reduction or enhancing gender and racial diversity within portfolio company boards.
- The concept of impact-linked carry isn't novel. It traces its origins back to the late 2000s when Aureos Capital in London introduced a base rate of carry with provisions for enhanced rates upon achieving impact targets.
- Fast forward to today, and industry giants like Apollo Global Management and EQT have adopted similar models, linking carried interest to the realization of an impact fund's mission.
Challenges and Authenticity
- However, the road to impact investing is not without its challenges. Luke Dixon, a key player at Dot Investing, highlighted potential pitfalls, such as GPs potentially prioritizing data collection over genuine impact. The onus of proving an investment's impact lies with the GPs, but LPs and consultants are investing heavily in ensuring authenticity and preventing practices like greenwashing.
See: Report: ESG Ratings and Data in Financial Services – Practitioners Perspective
- With the rapid growth of impact investing, regulatory bodies are stepping in. Proposals from the European Securities and Markets Authority suggest stringent criteria for funds using "impact" in their names, emphasizing measurable social or environmental impacts. The European Investment Fund pioneered the emphasis on genuine impact investments back in 2008. Today, the sector is witnessing exponential growth, with GPs bolstering their presence in this promising domain.
In Conclusion
- The landscape of impact investing is undergoing a transformative shift. As the sector matures, collaboration between LPs, GPs, and regulatory bodies will be pivotal in ensuring that impact investing not only promises but also delivers a sustainable future.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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