it has created hold regular competitive events like the hackathon to provide a channel for the fintech and start - up sector to showcase innovations. non - disruptive innovation 7. no regulator has the luxury of letting innovation disrupt the financial system in the hope that market might reach its own equilibrium eventually. for instance, we cannot afford to let loose defi technologies on the financial institutions with virtually no understanding of how a bank - less system would operate. apart from the unacceptable financial stability risks, this would amount to a regulator working towards its own irrelevance. it is necessary that a regulator controls the manner and pace of absorption of new technology. allowing disruptive technology without clarity on whether the alternative is even feasible, let alone desirable, would be an unacceptable gamble. a key element for smooth absorption of new technology is to ensure a level playing field. if offering credit cards requires a banking ( or similar ) licence, allowing a non - licensed entity to offer them would amount to undermining the banking system, as it would be placed at a competitive disadvantage. similarly, digital payments are essentially a banking service in the sense that they involve movement of funds from one deposit account to another. deposit accounts are a necessity, technology merely a tool ; deposit accounts can be used to make payments even without technology, but not the other way round. facilitating a non - bank to use its technology to move bank deposits would amount to creating a competitive edge for the non - bank. it may be argued that nonbanks could avoid use of bank deposits by maintaining deposit like funds, say, wallets. then non - banks would be deposit taking entities, that is, they would be effectively banks which would require a banking licence. a less disruptive and more efficient mechanism is to facilitate banks to collaborate ( or acquire ) the new technology. banks could also outsource or internalise the new technology. would it disincentivise innovation? not likely, if the non - bank technology is appropriately priced. 8. this brings us to the key issue of regulatory arbitrage. if we want to avoid the inefficiencies caused by differential regulations for similar activities, a non - bank undertaking banking functions, needs to be licensed and regulated like a bank. without the license, it should not be allowed to undertake banking activities. this for example, is what rbi did recently when it clarified that ppis ( prepaid payment instruments ) cannot be funded out of credit lines, because it enabled an

with other disclosures and written in small print and dense prose. consumer testing indicates that many consumers set the documents containing these disclosures aside without reading them. under the proposal, creditors must highlight critical changes in a summary table. creditors that enclose their notices with periodic statements must place this table on the periodic statement above the transactions list, where consumer testing suggests consumers are most likely to notice it. checks that access a credit card account many credit card issuers provide accountholders with checks that can be used to obtain cash, pay the outstanding balance on another account, or purchase goods and services directly from merchants. the solicitation letter accompanying the checks may emphasize a low introductory apr for these checks. the proposed revisions would require creditors to disclose other rates and fees that will apply if the checks are used, rather than simply suggest the consumer review the disclosures provided at account opening. to ensure the disclosures are conspicuous, creditors would be required to place the rates and fees in a table on the same page as the checks. right to dispute billing errors the board also has proposed several revisions to substantive and procedural protections tila provides consumers. four proposed revisions, in particular, would clarify regulation z in ways that strengthen consumers'rights to dispute billing errors on credit cards and other forms of revolving credit. first, if a creditor determined that no error occurred, the proposal would make clear that the creditor may not impose finance charges or other charges until the grace period ( if any ) in the credit agreement has elapsed. second, if a creditor credited a borrower's account for a disputed transaction, the proposal would make clear that the creditor may not reverse the credit after two billing cycles or ninety days, whichever period is shorter ; this clarification is meant to ensure finality. third, the proposal would make clear that the right to dispute billing errors covers check transactions that access open - end accounts. fourth, the proposal would make clear that the right to dispute errors applies to purchases of goods or services made using a third - party payment intermediary, such as a person - to - person internet payment service. attachments g - 10 ( c ) applications and solicitations sample ( credit cards ) g - 17 ( b ) account - opening sample g - 18 ( h ) periodic statement form