with privacy and data management rules and best practices. yet it is not merely a question of having this information, but also of having the capacity to take full advantage of it. in other words, being able to process it so as to measure risks properly, analyse profitability and costs on a case - by - case basis, offer quality services and compete on equal terms with the new players. banks ’ position has so far gone unscathed by the entry of competitors. however, this may change with psd2. specifically, authorised third parties have access to customers ’ bank data, yet banks are not afforded similar treatment. indeed, rather than banking business opportunities per se, these new operators are more interested in the data. the report rightly states that in order to compete with bigtech on equal terms, a broad exchange of data – and not just financial data – is required. in this connection, the european commission has already started on various lines of work that seek to improve the re - utilisation of information in the market. also, proposals such as the digital market act may somewhat mitigate some of the undesired consequences of bigtech ’ s advantages stemming from anti - competitive conduct. for example, i refer to matters related to data portability and the removal of potential impediments to banks and their customers accessing the information provided to or generated on digital platforms. the report describes how fintech ’ s relationship with banks has evolved over time. thus, they appear to have shifted from outright competing and defensive positions to others 3 / 5 bis central bankers'speeches more conducive to collaboration through various channels, albeit without putting competition entirely to one side. therefore, according to the report a “ competitive collaboration ” framework, from which both sides gain, seems to have emerged. fintech firms tend to be characterised, in both the report and public opinion, as small, agile and adaptable firms. therefore, the idea of allegiances with banks is presented as “ synergistic ”. thus, fintech firms would gain access to a much broader customer base and provide in exchange innovative technology solutions. this image of fintech is mostly correct, in particular if we look at the situation in spain and the collaboration frameworks observed to date. however, recent crises involving specialist digital payment and factoring companies serve as a counterpoint to this image. indeed, their corporate structures featured tail credit institutions. naturally, banks have been impacted by the crisis. this shows

that sometimes the bank, rather than fintech, is the small fish. fintech firms are fast - growing, high - tech groups that have a theoretically simple business model, but one shrouded in layers of operational and technological complexity, an opaque and complex corporate structure spread across several jurisdictions and no clear supervisor. the existence of fraud, perpetrated for some time, appears to have been demonstrated. consequently, high - tech firms participating in banking activities can pose risks similar to those entailed in banking. as has been proven, the technological complexity may actually hinder the detection of potential instances of fraud. furthermore, these examples suggest that the financial supervision and regulation architecture may not be up to addressing the risks that these emerging players pose. once again we should remember the “ same activity, same regulation ” principle, since they may entail equivalent risks. the volume of business and interconnectedness are other factors to bear in mind. these require us to adopt a global view. if companies grow too much, conduct significant cross - border business or have critical interdependencies, we must also consider the same systemic dimension as we already do for the banking sector. for decades we have been demanding that banks manage conflicts of interest, stressing the importance of appropriate governance arrangements, and requiring transparent corporate structures, compliance with legislation at consolidated level based on uniform criteria, coordination among supervisors focusing on the same corporate structure, etc. let us not therefore make the same mistakes as in the past. if a new crisis takes us by surprise, it should at least be original. allow me to clarify that we, the supervisors and regulators, are not against innovation or it being spearheaded by new players. innovation is what drives us forward. without it, the changes reflected in the report presented today wouldn ’ t be occurring. true, regulation often hinders the development of innovative solutions. it is frequently said that regulation always lags behind reality. yet you must admit that, for some time now, reality has been changing at an ever - increasing speed. believe me, producing “ flexible regulations ” is no mean feat. in fact, you might say that concept is practically an oxymoron. 4 / 5 bis central bankers'speeches this is precisely why a regulatory sandbox was recently created in spain. a sandbox is a closed environment for testing certain innovative projects that do not easily fit the current regulatory framework. this controlled environment allows us to analyse the effects of novel solutions on consumer protection, financial