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March 12, 2020 – Rapid digital innovation in finance, such as artificial intelligence and open banking, can provide myriad benefits to both consumers and financial institutions, but poses risks to financial stability, says a new report from the C.D. Howe Institute.

In “The Era of Digital Financial Innovation: Lessons from Economic History on Regulation” David Longworth, former Deputy Governor of the Bank of Canada, focuses on the major macro-level risks arising from current and future digital financial innovation and what the implications are for Canadian regulators.

Longworth notes economic history gives us many examples of instances when financial innovations, rapid growth in credit supply and increased reliance on short-term financing have led to financial instability and crises. Therefore, at a time of rapid changes in the financial sector, it is important that regulators pay close attention to what is happening and take appropriate action.

The report documents the dominant influence of credit supply booms as precursors to crises, and the financial innovations that helped fuel them.

After discussing key areas of the concern for Canadian regulators, the report recommends requiring the use of Explainable AI (XAI), which employs techniques that allows human oversight of the AI’s decision-making process. As it is, artificial intelligence (AI) is being used in lending decisions at both regulated and largely unregulated institutions. If not properly examined by internal risk managers, it can lead to unsafe lending decisions.

The report also urges regulators to take care with open banking regulations, for example regarding money-moving apps that could increase the likelihood of bank runs in response to errors banks make in posting their interest rates or to errors the apps make in interpreting the information.

The report points out that Canadian macroprudential regulators need to take seriously the fact that they have little or no data on non-bank financial intermediaries (NBFIs), or shadow banks. It recommends regulators ensure that quarterly data on lending and short-term financing are gathered for each type of lender, whether regulated or not. Special attention should be paid to lending from Big Tech companies – such as Google and Amazon – especially to small and medium-sized businesses, as well as online, peer-to-peer lending for both households and businesses.

Finally, Longworth advocates for extending the coverage of stress tests to examine stresses related to rapid new borrowing from NBFIs that are not prudentially regulated. Such stress tests should take into account, for instance, substantial new financing in the form of uninsured mortgages from these institutions.

“The lessons I draw from historical experience about the likelihood that today’s digital financial innovation will cause financial instability are threefold,” said Longworth. “First, the risk will be higher if it leads to an easing of credit conditions overall that, in turn, leads to a credit supply boom. Based on previous experience, this is likely to be more problematic if the boom is in household mortgage credit. Moreover, it will likely be no less of a problem for the overall economy if it occurs in the NBFI sector.”

“Second, the risk will be higher if it leads to increased probability of runs on short-term funding from financial institutions. Third, it will be higher if digital financial innovations cause business to move away from banks to NBFIs, thus reducing bank charter value and earnings cushion. In all three cases, however, regulators need to examine the full context of what is happening.”

Read the Full Report

For more information contact: David Longworth, Term Adjunct Professor, Department of Economics, Queen’s University; or David Blackwood, Communications Officer, the C.D. Howe Institute, 416-865-1904 ext. 9997, email dblackwood@cdhowe.org.

The C.D. Howe Institute is an independent not-for-profit research institute whose mission is to raise living standards by fostering economically sound public policies. Widely considered to be Canada's most influential think tank, the Institute is a trusted source of essential policy intelligence, distinguished by research that is nonpartisan, evidence-based and subject to definitive expert review.