I recently did an article where I talked a bit about RBZ’s sandbox concept. I highlighted some of the implications of the concept. I also looked at the possibility of having a central bank digital currency. At that time, the full framework of the concept had not been made public. The framework is now out; the 1st of March had been cited as the launch date of the regulatory sandbox. I shall be going through the guidelines of the regulatory sandbox citing key areas.
A Bit Of Background
The regulatory sandbox concept was necessitated by the surge in the number of fintech startups looking to provide innovative digital financial products and services in Zimbabwe. This has obviously meant that these startups not only need support structures but also a smooth operating environment. It was with that in mind that the central bank, the Reserve Bank of Zimbabwe (Reserve Bank), decided to put together standard operating protocols. These essentially would inform and control the testing process of the respective tech in question. An operating environment that is regulated makes testing and rollout of fintech much easier. This would also ensure that only relevant fintech that is suited to existing problems gets approved. The concept also was a result of seeing the need for fintech to be in sync with the mainstream financial sector.
Scope Of The Regulatory Sandbox
The Fintech Regulatory Sandbox is intended for innovators in the financial services sector who have already developed their service, product or business model and are ready to undertake a proof of concept through monitored market testing. The sandbox activities which shall be tested are those which the Reserve Bank would be able to oversee in terms of the Reserve Bank of Zimbabwe Act, [Chapter 22:15]; Banking Act, [Chapter 24:20], The National Payment Systems Act, [Chapter 24:23]; The Money Laundering And Proceeds of Crime Act, [Chapter 9:24]; Exchange Control Act [Chapter 22:05] and any other relevant regulations. Accordingly, all activities to be tested should have the appropriate regulatory approval.
Who Is The Target Audience?
The Reserve Bank will consider participants in the financial services sector such as innovators, start-ups and financial institutions. Participants currently outside the sector with solutions for financial services may apply. The Reserve Bank will consider innovations that enhance financial services, improve consumer experience with financial products, promote competition and efficiency, or enhance financial inclusion. The innovation should provide a product that is unique or different from those existing in the market or offer new or different technology.
Overview Of The Process Involved
There will be broadly 4 key stages of the process namely, Pre-application, Application and Evaluation, Testing, and Exit and Deployment.
Pre-application
This stage simply means you should ascertain whether or not your product or service is eligible. Who is eligible? Well, the list of eligible financial products or services is as follows:
– APIs
– Mobile money services
– Retail payments
– Money transfer services
– Peer-to-peer/Marketplace lending
– Digital KYC
– Financial advisory services
– Wealth management services
– Digital identification services
– Smart contracts
– Financial inclusion products
– Cybersecurity products
– Equity crowdfunding
– Regulatory technology products
Some financial products or services have been categorically stated as non-eligible. They are as follows:
– Cryptocurrency
– Digital currency
– Central bank digital currency
Application And Evaluation
Applications are submitted to the RBZ and a decision is communicated to the applicant. That should tentatively happen within a period of 21 working days from the day of submission. Adjustments to the initial application may be made, where possible, during this stage.
What Are The Application Requirements?
Full details of the applicant’s organization, including its governance arrangements, financial standing, technical and business domain expertise; and authorised regulatory status if any under the Reserve Bank or any other regulator will be required. Full details of the financial service or product to be experimented on in the Sandbox will be needed. These are problem statement; proposed benefits; business model(s), including the target customer and specific use scenarios; the technical architecture of the solution, detailing the specific technology and innovations. You will also be required to provide full details of the proposed sandbox design, including a description of the tests to be conducted in the sandbox, including specific testing of the application of technology in the proposed financial service/product and the preferred length of the testing period not exceeding 24 months.
Testing
The maximum period this will take will be 24 months. This will of course be subject to extension if needed though of course, the RBZ will reserve the right to decide on applications for extensions. Approvals for testing may be revoked if a participant has failed to develop or implement safeguards, or breaches data security requirements, or is noted to have submitted misleading information or misrepresented the Reserve Bank, or goes into liquidation or has primary licence cancelled, or fails to address any technical defects.
Exit And Deployment
This will entail an exit plan which shall guarantee an orderly exit without disruption to financial systems and prejudice to customers. The participant will be obligated to avail of the RBZ with reports. Those reports will be the premise upon which the RBZ will determine whether or not the test succeeded or failed. In the event of success, further assessments will be done in pursuit of a smooth transition into full deployment.
For interested parties, enquiries can be directed to the Sandbox Team at fintech@rbz.co.zw.
Cryptocurrencies Excluded…
In closing, it is worth noting that cryptocurrencies, digital currencies, and a central bank digital currency have been excluded. Any financial products or services in those domains are non-eligible. Most proponents of cryptocurrencies were hoping they would be included. Personally, I was not quite confident they would be included so this came as not much of a surprise. Government institutions tend to be aversive to things they cannot have a total grip on and things they do not fully comprehend. That could be why they were not included.
