Friday, Feb 26, 2021
How to Build a Regulatory Sandbox
Ivo Jenik, Senior Financial Sector Specialist at the Consultative Group to Assist the Poor (CGAP) talks to TC about the objectives of a regulatory sandbox, and how to design and implement a sandbox.
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Chuin Hwei Ng:
Hi, everyone. Welcome to TC Podcast on the go. I'm Chuin Hwei Ng, program director from Toronto Center. Today, we are going to be talking about regulatory sandboxes. What are they? And the guiding principles on how to design and implement them.
My guest today is Ivo Jenik, author of the technical guide on How to Build a Regulatory Sandbox: A Practical Guide for Policy Makers. And that guide was published in September, 2020. Ivo is senior financial sector specialist at the Consultative Group to Assist the Poor, or CGAP. And that is a financial inclusion think tank hosted by The World Bank. Ivo, it's great to have you on the podcast.
Ivo Jenik:
Thanks for having me, Chuin Hwei. It's a great pleasure.
Chuin Hwei Ng:
I wonder if you could start us off by defining what a regulatory sandbox is.
Ivo Jenik:
Let me say that, to me, regulatory sandbox is a new policy tool that allows regulators to stretch their comfort zone when they deal with innovation. But this is obviously a very high level definition. And I should also say that the way we define regulatory sandbox at CGAP has changed over the time.
We started this work in 2016, '17, when we published the first working paper. And in that paper we defined regulatory sandbox, very much focusing on how the sandbox looks like from outside. Or if you will, what are the external characteristics of sandbox?
So we focused on sandbox being a framework put in place by regulators to allow live testing in the marketplace or innovation. And that was a, I think, very pertinent definition to our understanding at that point. And I wouldn't say that that definition is invalid, but we have evolved in our thinking.
And the definition in the most recent guide that you refer to focuses more on the core function of the sandbox. So we now talk about regulatory sandbox as a tool that allows regulators to generate insights for regulatory response to innovation where live testing is necessary.
And so I think this shift in thinking and definition is very important because it helps to refocus attention to what matters most. And that is what is the core objective and utility of sandbox for the regulators? What it is that they're getting from sandbox.
Chuin Hwei Ng:
Thank you, Ivo. It seems that you have been involved in this work for some time, and thank you for that short history. I'm wondering, could you tell us how the idea of the technical guide on How to Build a Regulatory Sandbox, how that came about? And how you personally came to be involved in this work and in authoring the guide?
Ivo Jenik:
The idea behind the guide is to summarize the years of our work and insights we've collected throughout, and offer something that's very practical and in a way, normative advice or answer to the question of whether to have a sandbox and under what circumstances. Or whether other innovation, facilitators or tools are more relevant.
As I mentioned, we started this work in 2017 so the guide summarizes really almost four years of our work. And I co-author it, I should say. I'm not the only author. I co-authored it with my colleague Schan Duff whose big contribution, among other things, is the decision tree.
And it's one among many publications on this topic that people can find on our website. But let me tell you a little bit of the history of how this guide came to existence. So in 2017, very short after the FCA UK started their first cohort and people started noticing regulatory sandbox as a concept, we decided to look into more details, what it is, how it works, and started getting involved also in country work.
So we worked with regulator in Kenya, in Uganda, in Sierra Leone and with other regulators in different capacities, either as an institution or individual team members. We did a survey, and I'll talk about it a little bit later.
We did a sandbox sweep, which was an analysis of more than 100 firms that have tested in regulatory sandbox, interviewed a lot of experts and so on and so forth. And over the time, we started spotting some common challenges, good practices, misconceptions, frequently asked questions.
And so the guide is a result of what we found and how we understand sandbox after all of this. One thing that has become very clear on this journey is that regulatory sandbox gained so much attention and traction because it appeared to be an answer, if not the answer, in people's minds, to the challenge that regulators have been facing.
Vis-a-vis innovation and vis-a-vis very rapidly changing financial markets as a result of technological advancements. And so we did understand that need. And we also did understand that that is why we need to really explain to regulators what sandbox can or cannot do because as a tool, it does have limits and can only do certain things.
And I think they are now very much embedded in how we define regulatory sandbox. So all of this provided inputs to the guide. And last year we thought, "Okay, we do know probably enough about regulatory sandboxes to summarize it in a way that would provide, I would say, unambiguous answers to some of those key questions that regulators wrestle with." And so we published the guide.
Chuin Hwei Ng:
That sounds like a fascinating journey to publishing the guide. And I was struck by a statement right at the beginning of the guide on the immense potential of regulatory sandboxes to foster financial inclusion. And it says that sandboxes can enable firms to experiment, in a safe space, with new technologies that foster access of underserved populations to financial services. So I'm wondering, could you talk us through some examples of sandboxes that have led to improved financial access and inclusion?
Ivo Jenik:
This is a great question. And I should probably explain, building on to my previous answer, why CGAP got involved in this place in the first place. So to the extent to which innovation is a critical enabler of financial inclusion, we believe that sandboxes could play a role in advancing the financial inclusion objective.
What I mean by that is that we see that financial inclusion is a hard challenge to address. And that some traditional methods and traditional players are probably not sufficient to bring this many people who remain outside of the formal financial sector inside of it.
And so we believe that innovation can be a critical component in addressing some of those prevailing challenges. And we saw it in the past with mobile money, for example. In many markets mobile money, as an innovation, did a great job advancing access to formal financial services.
And so this future potential of innovation is really important to unlock, to see a big progress on financial inclusion, and sandbox can be one of the tools that can help to unlock that potential. But I should say that only few regulatory sandboxes have financial inclusion as their explicit or even primary objective.
Most regulatory sandboxes are open to any sort of innovation. And I think that that makes sense. So we did try to answer the question that you are asking and see what's the impact of regulatory sandboxes on financial inclusion because after all, CGAP is a financial inclusion-oriented think tank so it's a critical question for us to ask.
And so that's why we did the sweep. And again, what I mean by sweep is a relatively detailed analysis of 134 firms that have tested or graduated from 16 different sandboxes. And we try to understand what they are, what kind of technology they test, and what kind of market segment they're trying to serve.
And then we applied relatively simple framework to assess whether what they do is relevant to financial inclusion. And first, we applied relatively strict criteria and we came up with the number of 20%. 20% of those analyzed firms did do something that was focused on financial inclusion specifically, either addressing very specific financial inclusion barrier or specifically addressing excluded or underserved segment.
And then we applied a little broader criteria, including firms that do test products that are usually considered important in the financial inclusion space, such as remittances, such as certain savings, products or micro credit. And we came up with an additional 18%.
So in our sample, around 38% of the firms somehow related their testing or products to financial inclusion, which I thought was a fairly, fairly large number. But I understand that your question is probably about very specific examples, concrete things that I can refer to, that helped advance financial inclusion.
And so let me give you two examples. One is eKYC and remote onboarding. We've seen it in multiple sandboxes, the idea of testing alternative ways to onboard customers. And we know that in financial inclusion space, onboarding is a big challenge because many people do not have formal ID.
In fact, one billion people currently does not have any way to prove who they are. And so that's a big barrier for the AML/CFT reasons. So that's one example. The other example is alternative credit scoring as a way to expand access to formal credit, to people who don't necessarily have a previous credit history.
But what I would say is that these are all indicators of how innovation and sandboxes impact lives of individual people. We would love to know, obviously, what is the actual impact on those individual people, how their lives got improved as a result of innovation tested in a sandbox.
And for that, I'm afraid that we don't have robust enough data yet because many of those sandboxes are fairly new. Many of those tested innovations are still at the very early stage. But I hope that in a year or two, we or somebody else will be able to really look into the data and say, "This is how this specific innovation have helped improve life of excluded and underserved people."
Chuin Hwei Ng:
Ivo, thank you for that. I think that, as you pointed out, there is a narrow definition and there's also a broad definition of financial inclusion. But ultimately, it really translates to access of individuals and access of underserved populations, actually, to financial services.
And I'd just like to add here that financial inclusion is a cause that Toronto Center is committed to. And we have incorporated that aspect in many of our capacity-building programs with our partners in developing economies.
And I'd just like to turn now to focus a little bit more on the regulatory perspective. Now as a financial regulator, regulatory sandboxes are just one of the many tools available. So why use a regulatory sandbox versus other tools such as formal rule-making processes or other ways of allowing innovation? Why use a regulatory sandbox?
Ivo Jenik:
This is a great question and really the key topic of the guide. And I would say, if you don't need to test the innovation in the live marketplace to identify or effect a regulatory change, then you most likely do not need a regulatory sandbox, but perhaps some of those other tools.
And we try to unpack this idea through a decision tree that is included in the technical guide, and that seeks to provide very normative, very definitive answer to the very question, when sandbox is relevant and when other tools may be better suited for the regulatory needs.
And when you look at the decision tree, what probably strikes you first is that many of those decision lines do not lead to sandbox, but they actually end up with those other alternatives, a regulatory change being one of them.
Because we believe that while the regulatory sandbox is a very important tool, it also is a tool that really serves that specific, relatively narrow use case that I talked about at the beginning in definition, which is to collect evidence through live testing only to inform a regulatory response to innovation.
And so I would say that if you follow the decision tree you will see that, in many instances, some other tools may be better suited. And the question is whether those tools are an alternative to regulatory sandbox, or whether they are mutually exclusive, or whether they should be applied in par with regulatory sandbox.
And we see all of these three scenarios. So let me give examples just to illustrate what the decision tree is trying to hint to. So for instance, if a regulator feels there is a need for a regulatory change because certain regulation creates a barrier to modernization of the financial sector or to a specific innovation...
And to make regulatory change, evidence from live testing is not necessary. For instance, because there's already emerging best practice, internationally, of how to regulate certain things. I don't want to give to you specific examples because this may mean different things for different regulators.
But just for sake of this conversation, let's say a crowd funding. Crowd funding has been around for quite some time. So in theory, you can just look at what other countries are doing and put a regulatory framework in place without having a sandbox framework.
Now, I can imagine a scenario where to get more comfortable with crowdfunding, regulators also may want to push a crowdfunding platform through the sandbox to first see how it works in the live marketplace, and then use that lesson or evidence from sandbox to regulate.
Which is to say that we cannot really generalize how people will answer the questions that we laid out in the decision tree, because they may answer them in a very different way. But the point is that there might be circumstances under which regulators should just go directly and change the regulatory framework or provide guidance to address uncertainty without testing in the regulatory sandbox.
Or launch one of those other innovation facilitators such as fintech office, for example, to start engaging with the fintech industry or with innovators. So some of these could be alternatives to sandbox. Some of these could be mutually exclusive where sandbox simply would not help to achieve the same objective as the other tool would.
And some of them, and many of them actually, will likely be implemented in parallel. And I think we've seen, from our work, very strongly that implementing those other innovation facilitators alongside with regulatory sandbox helps to create synergy.
So if you have a fintech office along with the sandbox, it definitely reinforces either of those tools. I would say maybe, oftentimes, it's a good idea to start with a small initiative such as fintech office, just opening your door and communication lines to innovators.
And over the time, assess their interests and the barriers they wrestle with and decide whether you want to have a sandbox as something that solves that very specific niche challenge, and is also more resource intensive than just opening a fintech office.
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Chuin Hwei Ng:
So let's say after having gone through the decision tree, consider the options, the regulator came to the conclusion is that, "Well, the sandbox is something that serves our purpose," and they would like to go ahead of it. So let's talk a bit about the principles of designing a regulatory sandbox.
I'm having the image of a sandbox in my mind, and it seems very critical to set the boundaries of the sandbox to keep it safe for the people or the players inside. And it seems that there will be many kinds of boundaries. Boundaries in terms of who is eligible to play in the sandbox, and boundaries in terms of restrictions.
So what products and services, and on whom these products can be tested on. And also criteria to exit the sandbox. So I'm wondering, could you walk us through the main design principles of a sandbox?
Ivo Jenik:
Yes. So there are a couple of important elements, design elements, of the sandbox. But I would say that what is the critical one is well-defined objectives. What the sandbox is trying to achieve? What kind of issue it's trying to help solve, and what is the root cause of that issue or challenge that regulator face?
And then three threshold constraints that, in our view, determine design choices when designing a sandbox. When you look at the sandboxes... And now there are close to 87 boxes operating or under construction, so to speak, all around the world.
My colleagues from The World Bank actually mapped them out and you can see them in an interactive map. When you look at them from the 35,000 feet point of view, they all look alike because they all have same five design elements.
Defining eligibility, who's able to or who's eligible to test in regulatory sandbox? Time for applications, and time for the tests. Who bears the cost of testing? Safeguards, which is the barriers that you've been talking about. And then exit scenarios and exit options.
Obviously, there are other elements such as governance and internal processes, but I think those five are really shared all across. But once you start looking into detail, you'll see that each element includes a multiple different choices. And that really adds to a great variety of models.
So for instance, only already licensed institutions can be eligible to test in the sandbox, as compared to new entrants, startup companies, sometimes even individuals partnering with institutions. Time for application can be on cohort base, or it can be open at any time on tap or on demand application basis.
So I could continue like this. And it means that there is a great variety, as I mentioned. And so one question that we ask ourselves is, are there factors that determine those design choices so that regulators take them into account and decide what is best for their very specific circumstances?
And we came up with three threshold constraints that we believe are essential for making those design choices, and that are most likely common to all regulators around the world. First, it's a legal and regulatory framework. Second, it's a market demand. And third, it's capacity.
Legal and regulatory framework clearly determines what the regulator can or cannot do in designing or in running a regulatory sandbox. But it also obviously defines, what are the challenges that innovators likely face? Then there is a market demand which mostly refers to how mature and how active your innovation market is, how many new fintech startups emerge in your market, and how much demand for a regulatory sandbox there's going to be.
And then capacity is both capacity of the regulator to design and implement the regulatory assembled, but also capacity of the market to participate in such initiative. And so we try to take those three threshold constraints and start combining them with the five design elements, making clear where specific circumstances lead to specific design choices.
So again, let me give you one specific example. For example, high capacity and high demand. So this combination where a regulator does have a lot of resources, and there's also a lot of demand in the market for regulatory sandbox.
Then you may want to have a cohort-based sandbox with a dedicated sandbox team where you can bring subject matter experts who are specialized in the areas that you see most prominently featured in the innovative space in your market, and so on and so forth.
Let me just compare this with the low capacity and high demand where you may need to have more distributed team focused on sandboxes, where there are multiple departments supporting the initiative, where you need to have perhaps more strict eligibility criteria to limit the number of applicants you get in cohorts.
When you may have short testing windows to better work with the capacity that you already have in the regulatory agency again, and so on and so forth. Usually relatively long lists of things that you should consider. So in this way, we believe that regulators can put some framework in how they think about this design of regulatory sandbox, instead of just following a blueprint of other regulatory agencies.
So in terms of safeguards and limits to sandbox, there are a number of options that regulators have at their disposal usually. And we did ask this question in our survey. So we did a survey of around 30 different regulatory agencies with regulatory sandbox or similar initiative in place.
And one question that we ask is, do you apply safeguards during the sandbox test? And what kind of safeguards do you apply? And number one safeguard is disclosure requirements. Just making sure that people understand, the clients understand that they are taking part in the sandbox testing. So that was one.
The limited number of clients was number two. Making sure that if something goes wrong, only a small number of people is affected. The complaints handling mechanism in place was number three. Making sure that if those people are affected, they have effective ways of complaining and get compensation or another form of redress.
And then there were other that related to AML/CFT and other consumer protection issues. And then there were set of safeguards that would be bespoke to a very specific innovation. So for example, if you test a robo-advisor, a safeguard would be to put a human advisor to vet the advice provided by the robo-advisor during the test. So these are some of the constraints that we've seen put around sandboxes.
Chuin Hwei Ng:
So Ivo, I like the way you have conceptualized this in terms of the five design elements and how to interact with the threshold conditions. And also the safeguards that keep the whole structure in place and keeps it as an experiment.
And I want to talk about the exit from this experiment. Of course, it's not possible for players to play all the time without any time limits in the sandbox. What does exit from a sandbox mean? I guess there will be some exits that are successful and some exits that are failures?
Failures in the sense of not having met the objectives. But failures will, I guess, also give the regulator some information in and of itself. So I'm wondering, could you talk us through what exit means in the context of a sandbox? And what should regulators learn from these successful exits and not so successful exits?
Ivo Jenik:
Exit is very important. Although it comes last in the sandbox process, it is so important that it has to be thought through from the very beginning. And I'm afraid that sometimes this is overlooked, especially at the early stages of sandbox design.
Why exit is so important is because it determines the design, and it determines what design choices should be made because not all exit scenarios may be possible in all jurisdictions. So you rightly said that there are two major outcomes that can happen at the exit. One is that it's a failed test, and one is that it's a successful test.
There is something in between when a firm decides to discontinue the test or regulator decides to interrupt the test for a number of reasons. But I'd like to focus on the successful test scenario because that's really what is desired by regulators and by the testing firms.
And even if you look at this successful test exit scenario, there are four different outcomes or four different options of what may happen. A regulator may still decide to impose a cease and desist order or [inaudible 00:28:11] of it.
If, for example, while test has been successful, the innovation is simply deemed not fit for the market for a number of reasons. The other outcome might be that the test has been successful and a regulator decides to grant a license or other form of approval to innovation or innovator.
And in my view, that's probably the easiest, the smoothest outcome we can think of. Third option is that this has been successful. The innovation is fit for the market, but for it to operate in the market, a regulatory change is needed because it's so new that it would operate in regulatory vacuum, which is obviously not great.
And then the fourth outcome is that, again, test is successful but the regulator finds out that the innovation is outside of the regulatory perimeter, either because it's not a regulated financial service and it shouldn't be, or because it falls under the mandate of another regulatory agency.
So to me, successful test means that the test proved innovation is working, it's safe, it's desirable of the market, and should be now allowed to scale up. But I mentioned that there are some limitations that regulators may face.
And a lot of them come around that scenario of regulatory change, where innovation is great and should be allowed to scale up in the market. But there is this regulatory vacuum that needs to be filled. And it takes some time, especially if we're talking about changing the laws.
And so that's why some regulators actually decided to make the testing period relatively long. I've seen two to three years based on the assumption that if that happens and they need to make the regulatory change, they will simply allow a firm to test in the sandbox for a prolonged period of time.
And in the meantime, the regulatory change will happen. So this is how the threshold constraints, again, inform the design choices. Now you ask about the failed test and the successful test and the learning from it. And I think the very purpose of the sandbox is actually regulatory learning and collecting evidence.
So in either case, it's very useful input for the regulator because now they do have what they were initially missing, which is a deep understanding of how that specific innovation interacts with the marketplace, and whether it's fit for the market or where it's too risky or harmful. And that evidence is valuable input for that ultimate decision, what to do about that innovation.
Chuin Hwei Ng:
And I think in talking about success of the sandboxes, it will also be important to relate it to the stakeholders, those who have an interest in the experiment in the sandbox. So I'm wondering if you could talk us through the stakeholders, perhaps the owners of the sandbox. And who are the other stakeholders besides the owners of the sandbox?
Ivo Jenik:
Yes. And I know that Toronto Center has a great framework for stakeholder management and communication. So it's important to understand who the stakeholders are. There are two different types of stakeholders, obviously internal and external. So let me start with the external ones.
In many jurisdictions, there would be the most critical group of external stakeholders, other regulatory agencies, because we have many countries that have multiple financial sector regulators. And because a lot of innovations we see these days are cross cutting, cutting across mandates of multiple regulators.
It's very important to get those other regulators on board, either directly get them involved in the sandbox initiative and creating some joint effort, or just making sure that they understand the initiative and they are invited to observe what's happening in that sandbox so that they're comfortable. Especially if some of the innovation may be touching upon their own mandate.
The other important external stakeholder is obviously the industry, both the licensed industry, but also the aspiring new entrants. Again, it's very important to convince the incumbents that this initiative is beneficial to the market and should not be perceived as something that jeopardizes their position.
And then obviously consumers who, in many markets, may feel like this is relaxing the safeguards and consumer protection. But as I suggested in my previous answer, consumer protection is usually on the very top of the safeguards that are put in place.
Internally, the stakeholders are, again, also many because there are different departments within each agency that will be critical supporters or enablers of regulatory sandbox. Typically, it is a licensing department, regulatory department, supervisory department.
Very often, IT department comes useful because of their technological knowledge. And so all of these should be on board and should understand, again, the initiative and the role in the initiative.
I would generally say that for successful implementation of any regulatory sandbox, clearly defined ownership, responsibilities, and a broad stakeholder buy-in are critical elements, probably equal in their importance to well-defined objectives and design.
In our work, we've seen that a lot of sandboxes are placed at payments teams or payments departments, and that's probably because so far, a lot of innovation happens in that space. But to me, it's less important where exactly the sandbox is placed and who exactly owns it, as long as it's clear that somebody really owns it.
And as long as there is a widespread understanding throughout the agency why this initiative is happening, and how each department can support its success. But obviously, placing the sandbox is always a strategic decision and sometimes very political. So it would depend on each individual agency where to place it and who make the owner and ultimately, the champion of a sandbox.
Chuin Hwei Ng:
I'm interested in exploring a little bit more about what you said about who to place the sandbox with. And in particular, what you said about different departments within the financial regulator or the financial supervisor.
Many of the partner financial regulators that Toronto Center works with in developing economies, they have a dual mandate. Supervising financial firms, certainly, but also developing the financial sector.
And we usually find there's a healthy debate, maybe a little bit of tension between these two functions of supervision and market development. And there's a need to maintain the balance between the two.
So when it comes to the discourse on sandboxes, what is the nature of discussion that you have seen within the financial regulators among these departments? What are the main issues that you see crop up? And if there are any conflicts that crop up, how do you see these being resolved usually?
Ivo Jenik:
The role of supervisors in sandbox process is critical because they are the ones who will be ultimately responsible for ongoing supervision of whatever innovation comes out of the sandbox successfully. And that is why they should be bring on board and they should be comfortable with the innovation exiting sandbox to the marketplace.
But they also play a critical role during and throughout the sandbox process. I think they can very, very much help in deciding and designing the testing plan, defining what will be the ongoing monitoring practice, what will be the data points collected throughout the testing phase, helping with the ongoing monitoring of testing, and helping with the final evaluation.
So I agree that there is sometimes maybe tensions between those departments responsible for market development and supervisors. But this is not to say that supervisors should be excluded from market development initiatives, such as regulatory sandbox.
Now, I think that it's helpful though to separate the functions to a certain degree because the mindset of supervisors and sandbox teams, by definition, should be a little different. Supervisors are there to make sure that the rules are complied with and enforced. Whereas for the sandbox team, it's very important to be open-minded and less risk averse, let's say.
So the incentives are slightly different. And we've seen that, in some jurisdictions, sandbox teams are composed of rather junior people or people with a limited previous supervisory experience, which I think helps that open-mindedness. But that's also why the role of supervisors is critical throughout that process.
And so how to reconcile it is through a good governance and good internal processes. Governance where the decision-makers take into account the supervisor's perspective, processes where supervisors have their say at the critical stages of the sandbox process, as I mentioned earlier.
Chuin Hwei Ng:
Thank you, Ivo. I think this is a good place to conclude the conversation. It's fascinating. I've learned a lot about regulatory sandboxes. And we've covered a lot of ground today on the objectives, design, implementation, and also discussed some of the learning that regulators can do from adopting this as an option. And I'm wondering if you could just remind our listeners where they can find the guide and further guidance on regulatory sandboxes.
Ivo Jenik:
Well, thank you, Chuin Hwei, for having me. It's been great pleasure for me as well. I've been working with Toronto Center in different capacities for quite some time, and I've always enjoyed it. The technical guide is on cgap.org/sandbox where people can find not only the guide, but also the simplified version, the sweep, the survey that I refer to, many blog posts.
And also sandbox repository, which is basically a repository of documents from all around the world, that [inaudible 00:39:08] regulatory sandboxes. So I encourage your audience to go there and listen to it. And I'd like to take this opportunity to also thank too the CGAP team, my colleague Schan Duff, our CEO Greta Bull, Gregory Chen, Stefan Staschen, and others who helped to make this work happen.
Chuin Hwei Ng:
Thank you, Ivo. And thank you to you for being such a strong supporter of Toronto Center. We really appreciate it. I'm here today with Ivo Jenik, and you've been listening to a Toronto Center podcast on the go. Thank you for joining us.