. apple. pay, ” register, april 3, 2017, www. theregister. co. uk / 2017 / 04 / 03 / banking _ group _ denied _ access _ to _ iphones _ nfc _ chips _ for _ altapplepay / see, e. g., chance miller, apple maps now used 3x as often as google maps on ios, serving 5b requests per week, 9to5mac, december 7, 2015, https : / / 9to5mac. com / 2015 / 12 / 07 / apple - maps - usage - numbers /. for example, small business lender kabbage, inc. has entered agreements with large banks, where kabbage licenses its data analysis - heavy customer acquisition platform to banking partners who then go on to originate, fund, and service the underlying loans. see, e. g., kabbage inc., “ kabbage and santander uk partner to accelerate smb growth, ” press release, april 3, 2016, www. kabbage. com / blog / kabbage - santander - uk - partner - accelerate - smbgrowth /. - 13 - regulatory developments as regulators, we have a responsibility to ensure that the institutions subject to our supervision are operated safely and soundly and that they comply with applicable statutes and regulations. more broadly, we have a strong interest in permitting socially beneficial innovations to flourish, while ensuring the risks that they may present are appropriately managed, consistent with the legal requirements. we do not want to unnecessarily restrict innovations that can benefit consumers and small businesses through expanded access to financial services or greater efficiency, convenience, and reduced transaction costs. nor do we want to drive these activities away from regulated banks and toward less governed spaces in the financial system. regulators in the united kingdom and continental europe have recently outlined new approaches to facilitate connectivity in financial services, while attempting to mitigate the associated risks. in august 2016, the uk competition & markets authority ( cma ) released a package of mandates aimed at increasing competition for consumer and small business current accounts ( akin to u. s. checking accounts ). 27 this year nine of the country ’ s largest banks were required to create open apis to share nonsensitive, non - consumer - specific information, like pricing, fees, terms, and conditions as well as branch and automated teller machine locations. 28 uk competition & markets authority, “ cma paves the

current level. therefore, banks should not be surprised by the emphasis in the proposed cre guidance on concentrations and the importance of portfolio risk management. historically, cre has been a highly volatile asset class. in the past, problems in cre, even at wellmanaged banks, have generally come at times when the broader market was encountering difficulties. in an effort to generate cash flow, borrowers and bankers with properties in distress may disrupt their local real estate market by cutting rents or offering leasehold improvements and other incentives to attract or keep tenants. these actions can have a negative effect on the entire local real estate market, including good projects. in most years, cre credit losses are relatively low compared with many other types of bank loans. but in times of stress, the loss rate can jump considerably higher. because cre losses tend to be greater during times of stress, bankers must focus more intently on their risk appetite as their cre concentration grows. bankers must consider how much capital will be placed at risk if the cre portfolio hits a stress period and compare that loss exposure with the relative returns of cre lending. in other words, bankers need to practice risk management. while banks'underwriting standards are generally stronger than they were in the 1980s and 1990s, the agencies are proposing the guidance now to reinforce sound portfolio - management principles that a bank should have in place when pursuing a commercial real estate lending strategy. a bank should be monitoring performance both on an individual - loan basis as well as on a collective basis for loans collateralized by similar property types or in the same markets. some institutions'strategic - and capital - planning processes may not adequately acknowledge the risks from their cre concentrations. cre lending in recent years has occurred under fairly benign credit conditions, but those conditions are unlikely to continue indefinitely. the ability of banks with significant concentrations to weather difficult market conditions will depend heavily on their riskmanagement processes and their level of capitalization. from a risk - management and capital perspective, institutions should generally focus on the emerging conditions in their real estate markets and on the potential cumulative impact on their portfolios if conditions deteriorate ; they should also take other measures to help identify cre vulnerabilities. of course, these measures should vary according to the size of the organization and the level of the concentration. all of these steps are key elements of a sound strategy to manage concentrations. while supervisors continue to underscore the importance of having robust risk - management practices for