telecommunications, media, transport, and electronic commerce and internet business firms who are managing touchpoints with a large - scale customer base. conversely, there are also financial institutions that actively adopt services of fintech providers. as for fintech as a service — the theme of this year ’ s fin / sum — there are cases where financial institutions utilize the advanced electronic know - your - customer ( e - kyc ) and fraud detection services of fintech providers in their applications. there is also a recent trend toward unbundling financial services that financial institutions used to provide as tightly coupled, thereby enabling componentized financial services to be combined with services of non - financial firms. this is referred to as “ banking as a service ” ( baas ), also known as embedded finance. it allows, for example, consumer firms issuing discount coupons 1 / 3 bis central bankers'speeches or providing loyalty points on their applications to enhance the usability of the coupons or points by plugging in cashless payment services provided as baas to their applications. there are also non - financial firms that seek to improve customer convenience and customer marketing by providing banking services under their own brands together with their businesses through baas. integrating information and financial systems in this way, a broad range of enterprises and entrepreneurs is creating new businesses through neue kombination ( new combinations ). the term neue kombination was originally introduced by schumpeter in his book the theory of economic development, and it was later interpreted as describing innovation. according to schumpeter, innovation is not necessarily about invention but is more about creating or changing combinations. needless to say, it is digitalization in various fields that is currently accelerating the creation of neue kombination. neue kombination 2. 0, brought about by digitalization, is reinforced by linking what were traditionally two separate systems : ( 1 ) the information systems assisting people ’ s livelihoods and business activities and ( 2 ) the systems supporting financial services. for example, most economic activities involve payments as financial activities. while commercial data such as billing and payments have been leveraged to improve the business efficiency of a supply chain, they have not been shared with financial services. this means that neue kombination, or innovation, could occur if the matching of commercial and payment data is enabled by linking commercial systems and payment services. for example, large volumes of invoice receipts could be automatically matched with payment records, thereby improving business efficiency, and potentially enabling real

we have seen a marginal shift from sovereign debt towards corporate debt11. in the search for yield, this is understandable. i would emphasise that the prudent person principle under solvency ii expect firms to consider the security, quality, liquidity and profitability of their portfolio when assessing their investment exposures. while the shifts we are seeing may increase the yield on investments, it is important that boards and executive management are ensuring that these changes are not at an undue cost to security, quality or liquidity. e ) individual accountability and the fitness and probity ( f & p ) regime the central bank continues to see significant shortcomings in compliance with f & p obligations and a lack of awareness in the industry regarding the scope of the f & p regime. this is concerning given firms are the first line of defence under the f & p regime, which is why derville rowland and i wrote to all firms12 early in april 2019 to highlight obligations and areas where compliance was found to be lacking. as you are aware the future ambition of the central bank is to introduce an individual accountability framework which will provide more powers to make senior management in regulated undertakings accountable for their actions. this would also see enhancements to the current f & p regime, with further obligations on firms. regulated firms can expect to see a continued supervisory focus on f & p. i expect that the boards and senior management of all firms to be fully aware of their f & p responsibilities and to ensure that all individuals within firms comply with f & p standards. f ) recovery planning internationally and in ireland, insurance is behind banking in recovery planning, both in terms of the regulatory framework and firms ’ preparedness. this needs to change. effective recovery planning, should include “ triggers ” for implementation, escalation processes, recovery options, and the identification of financial or operational impediments to recovery. i expect you to be formally considering recovery planning as part of strategy setting and capital planning, including consideration of the some of the issues i have discussed already – outsourcing, reinsurance, it resilience and so forth. i also expect firms to address impediments to resolution as they are identified. the central bank ’ s and eiopa ’ s focus on resolution planning will continue to increase. the 2020 review of solvency ii for example, which the central bank is taking an active role in, is wide ranging in scope covering many fundamental areas of the regime, including insurance