Aren’t Neo Banks Actually DSA Of Sponsor Banks? 

Several Founders, Co-Founders, CXO Bankers, CXO Fintech professional & people who participated in the ePanel discussions:

  • Mr. Sandeep Todi, Co-Founder & CBO, Remitr
  • Mr. Ajay B Panicker, CEO & Founder, NetPay Limited
  • Mr. Probir Roy, Co-founder, Paymate
  • Mr. Mukesh Bubna, Founder, Monexo FinTech Pvt. Limited
  • Mr. Shashank Chowdhury, Former Executive VP- Inclusion Initiatives, Vakrangee Software Ltd
  • Mr. Subbiaa Olimuthu, former Product Manager – RuPay Product
  • Mr. Aishwarya Jaishankar, Co-Founder, Hyperface Technologies
  • Mr. Babu Thomas, Assistant General Manager, The Federal Bank Ltd
  • Mr. Sujatha Mohan, Sr. Director – Payments- APMEA Region, FIS
  • Mr. Subbanna Tummalapalli, CISO, Utkarsh Small Finance Bank
  • Mr. Neeraj Chandra, Head of Operations and Technology, India, Abu Dhabi Commercial Bank
  • Mr. Ketan Pradhan, former SVP- Customer Value Management, Vodafone Idea Limited
  • Mr. Hemal Shah, former Technical Product Manager, Mastercard
  • Mr. Vikas R Panditrao, Co-Founder, Forum of Industry and Academic Knowledge Sharing (FIAKS)
  • Many other CEO/CXO Bankers & Fintech professionals on FIAKS Forum requested to remain anonymous

Now here’s another problem statement- A Neobank Platform (NP1) is powered by a Sponsor Bank (B1). Now a customer C1 is signing for the services of NP1. Suddenly the customer C1 starts receiving spam emails from bank B1? Can Bank B1 send the promo email messages to customers of neobank platform provider NP1? Please note carefully customer C1 has signed with NP1 and not with B1. 

The above issue needs to be mainly analyzed in two parts;

  • Are banks allowed to send promotional emails or messages to non-customers? Is there any regulation that they cannot solicit business? A member states, as far as I know, nothing stops them whether they send it to the customers of  NP1 or anyone else.
  • Whether NP1 can share the data of their customers to B1 would of course depend on whether express consent has been obtained by NP1 from their customer. Personal data collected by an organization should be used only for the purpose for which the same has been collected, even by the same organization. Personal data of a customer cannot be shared even with the group companies without the explicit consent of the customer.

From another interesting perspective;

  • For all promos and ads that we receive, do we question why we receive them when there is no direct connection? For example, even when our phone is only near us and we are talking to anyone about certain products & then the next thing we see an ad related to that, do we question why?
  • So why should a bank send us promo mail to raise this question?

Now here are several viewpoints put forth by members;

  • To be frank, B1 shouldn’t be doing this if they have signed the exclusivity agreement on customer reach out. Any product/offer/services – requirement/issue should be handled through NP1. But off late I am personally seeing a couple of new generation banks who are major neobank’s sponsors that interact with customers directly.
  • Depends on who the fintech is, if it is a licensed PPI, payment aggregator, etc, then the bank does not front end and therefore cannot reach out to customers. A neo bank is not an authorized entity under RBI, at best these debit cards are co-brand arrangements! Banks will own these customers in the eye of the regulator! Now you can’t tell banks you keep the skin of the onion, I will keep the flesh! When banks bear the brunt of regulation, they will demand customer ownership!
  • Another member opines, this is something why I tell the neo banks to keep an eye on the fine print. From acquisition to servicing to cross-sell, the boundaries need to be clearly defined. But from a regulatory point of view, banks are responsible to these customers, take the example of a change in service charges. As per the regulator, this needs a 30-day notice, are neo banks ready to take this responsibility and maintain logs of the communication to the customer for 7 years as stipulated by RBI? In the event of a customer dispute, it’s the bank that needs to answer, from RBI audits to banking ombudsman. Finally, B1 owns regulatory compliance and it will not take the burden unless it can derive more value.

If you ask the bank then they will say we are the sponsor and neo bank is just a DSA (direct selling agent) who gets us an account;

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2021-06-12T22:33:40+05:30June 12th, 2021|Categories: FIAKS bespoke|Tags: |Comments Off on Aren’t Neo Banks Actually DSA Of Sponsor Banks? 
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