News Comments
- Today’s main news: Prosper launches HELOCs with BBVA. LendingClub beats profit estimates. Pennsylvania fines SoFi subsidiary $110,000. Kabbage partners with GoDaddy. Zopa makes banking debut. RateSetter rolls out investor self-certification.
- Today’s main analysis: LendingClub Q3 earnings. International P2P lending volumes.
- Today’s thought-provoking articles: The hot stuff at Money 2020. China’s slowing economy. International P2P lending volumes. Preview of LendIt Fintech’s Latin American conference. LendIt Fintech Europe 2019 slide presentations.
United States
- Prosper launches HELOCs with BBVA. This is one of the more prominent bank-fintech partnerships we’ve seen to date. It looks like a bow over the stern of Figure.
- LendingClub beats profit estimates. It looks like higher fees is paying off.
- LendingClub’s Q3 2019 earnings results review. An analysis from Lend Academy.
- Pennsylvania fines SoFi subsidiary $110,000. There seems to be more to this story. I can’t imagine a company like SoFi voluntarily missing a deadline like this.
- Money 2020 highlights. Interesting insights from PeerIQ.
- Kabbage, GoDaddy partner on providing capital to SMBs. This is an interesting partnership, and it should be a boon to Kabbage’s already thriving business. Partnerships, the right partnerships, have a way of propelling a business forward and Kabbage understands this.
- SoFi vs. Prosper.
- Ron Suber talks about digital banking.
- CrowdStreet raises $12 million from its own customers.
- CrowdStreet hires three executives.
- Inside Affirm’s ID verification and fraud prevention techniques.
- Max Levchin backs digital banking startup HMBradley.
- HMBradley launches challenger bank in Los Angeles.
- Building a challenger bank that challenges traditional banking.
- How Goldman Sachs plans to boost reputation with Marcus.
- OCC Fintech Charter is down but not out.
- Delays in fintech charter will impact competitive situation.
- Crypto APIs launches Trading APIs to facilitate crypto lending.
- Brex, Bank of the West team up on co-branded credit card.
- Washington flexes its muscles on small business lending.
- The U.S. is a top location for fintech events.
- Legitimate shoppers outpace fraud growth.
- Elevate Credit to attend the Stephens 2019 investment conference.
- Michigan AG sues online tribal lender.
United Kingdom
- Zopa makes banking debut.
- RateSetter begins rollout of investor self-certification.
- iwoca hits 1 billion GBP lending milestone.
China
- China’s economy is slowing. I can’t help but think a part of this is due to the crackdown on P2P lending, but there are other factors–such as the U.S. trade war. Will the economy go so low it crashes?
- China to transform remaining P2P platforms.
- China warned to avoid P2P lending mistakes with blockchain.
- Chinese fintechs want to do a Xiaomi in lending.
- Asset management arbitration cases.
Other
- International P2P lending volumes for October 2019.
- Europe: LendIt Fintech Europe 2019 slide presentations.
- Latin America: Preview of LendIt Fintech’s Latin American inauguration.
- China: Beijing may cull a U.S. unicorn stampede.
- Europe: Klarna’s buy now, pay later option.
- Vietnam: Validus expanding into Vietnam.
- South Korea: PeopleFund is shaking up P2P lending.
- Latin America: Temenos’ report tags financial inclusion as top priority for bankers.
- Vietnam: Keep an eye on fintech.
- Indonesia: Fintechs help banks broaden customer base.
- Europe: Klarna to be down for maintenance.
News Summary
- United States
- Prosper Officially Launches HELOCs with First Bank Partner BBVA (Lend Academy), Rated: AAA
- LendingClub beats profit estimates on higher fees, loans (Reuters), Rated: AAA
- LendingClub Q3 2019 Earnings Results Review (Lend Academy), Rated: AAA
- Pennsylvania regulators hit SoFi with enforcement action (American Banker), Rated: AAA
- SoFi vs. Prosper: Which Personal Loan Lender Is Right for You? (credible), Rated: A
- Money 2020 Highlights, Jobs Report, Markets Doubt Fed (PeerIQ), Rated: AAA
- Kabbage partners with GoDaddy to offer capital to entrepreneurs and SMBs (Tearsheet), Rated: AAA
- Ron Suber Shares Perspective on Fintech (Crowdfund Insider), Rated: A
- Real estate crowdfunding startup CrowdStreet turns to its customers to raise $ 12M round (GeekWire), Rated: A
- CrowdStreet lands $ 12M in financing, hires execs (The Real Deal), Rated: B
- Inside Affirm’s ID Verification And Fraud Prevention Techniques (PYMNTS), Rated: A
- Max Levchin backs digital banking startup built to reward savers (Finextra), Rated: A
- LA is fast becoming a fintech hub as HMBradley launches another West Coast challenger bank (TechCrunch), Rated: B
- Building A Challenger Bank That Actually Challenges Traditional Banking (PYMNTS), Rated: A
- How Goldman Sachs plans to boost its reputation with online bank Marcus (Yahoo! Finance), Rated: A
- The OCC Fintech Charter Is Down, but Maybe Not Out (Lexology), Rated: A
- Troubled Fintech Charter: How More Delays Impact Competitive Situation (The Financial Brand), Rated: A
- Crypto APIs Launches Trading APIs, Allowing Users to Leverage Multiple Crypto Exchange Accounts (Cryptovest), Rated: A
- Brex And Bank Of The West Team On Co-Branded Credit Card (Forbes), Rated: A
- Washington flexes its muscles on small-business lending (American Banker), Rated: A
- USA Continues to be a Top Location for Fintech Events (Fintech News), Rated: A
- Legitimate Shoppers Take Advantage of Deals, Outpacing Seasonal Growth in Fraudsters (Riskified Email), Rated: A
- Elevate Credit to Attend the Stephens 2019 Investment Conference (BusinessWire), Rated: B
- Michigan AG sues online tribal lender (Lexology), Rated: B
- United Kingdom
- Peer-to-peer lender Zopa makes banking debut as pressure mounts (City A.M.), Rated: AAA
- RateSetter begins roll-out of investor self-certification (P2P Finance News), Rated: AAA
- iwoca hits £1bn lending milestone as headcount soars (AltFi), Rated: A
- China
- China has a steady hand on its slowing economy, but can it prevent a crash landing? (SCMP), Rated: AAA
- China to Transform Remaining P2P Platforms (Finews.Asia), Rated: A
- China warned to avoid P2P lending mistakes in blockchain push (Tech in Asia), Rated: A
- Chinese fintech players want to do a Xiaomi in lending. Caution: regulatory glare ahead (India Times), Rated: A
- Asset management arbitration cases in China (Vantage Asia), Rated: A
- European Union
- Marks & Spencer Buy Now, Pay Later Option (The National Law Review), Rated: AAA
- Upcoming maintenance affecting ability to view orders (Klarna), Rated: A
- LendIt Fintech Europe 2019 Slide Presentations Now Live (LendIt), Rated: AAA
- International
- Beijing may cull a stateside unicorn stampede (Reuters), Rated: AAA
- International P2P Lending Volumes October 2019 (P2P-Banking), Rated: AAA
- Asia
- P2P lending platform Validus expands into Vietnam (Business Times), Rated: AAA
- How South Korea’s PeopleFund Is Shaking Up P2P Lending (Yahoo! Finance), Rated: A
- Vietnam’s IT Sector: 5 Industries to Watch (Vietnam Briefing), Rated: A
- Fintech help banks broaden customer base (The Jakarta Post), Rated: A
- Latin America
- Preview of LendIt Fintech’s inaugural LatAm conference (LendIt), Rated: AAA
- Temenos’ report tags financial inclusion as LatAm bankers’ priority (IBS Intelligence), Rated: A
United States
Prosper Officially Launches HELOCs with First Bank Partner BBVA (Lend Academy), Rated: AAA
It was last November when we first heard that Prosper had plans to expand their offerings from personal loans into HELOCs. In 2018 David Kimball noted that they would be partnering with banks on the new product and loans would be available both directly through Prosper.com and also as a white-labeled offering. Now we know their first bank partner is BBVA.
LendingClub beats profit estimates on higher fees, loans (Reuters), Rated: AAA
Online lending pioneer LendingClub Corp (LC.N) beat analysts’ estimates for third-quarter profit on Tuesday and forecast current-quarter largely above estimates, sending its shares up 4% in after-hours trading.
Transaction fees jumped 17% at the company, which helps connect customers looking for loans to individuals or institutional investors, such as banks, through its online marketplace.
Loan originations soared 16% to $3.35 billion in the third quarter, with total revenue rising 11% to $204.9 million.
LendingClub Q3 2019 Earnings Results Review (Lend Academy), Rated: AAA
Revenue also topped records at $204.9 million, up 11% year over year. Losses narrowed to a GAAP net loss of just $400,000 compared to the prior year period where they lost $22.8 million. Adjusted net income came in at $8 million, up from a loss of $7.3 million in the prior year period.

Pennsylvania regulators hit SoFi with enforcement action (American Banker), Rated: AAA
A subsidiary of Social Finance Inc. has agreed to pay a $110,000 fine in Pennsylvania after operating as a mortgage servicer for nearly a year without the required state licensing.
SoFi Lending Corp. is one of several mortgage companies that has been hit recently with enforcement actions in Pennsylvania after a change in state law in December 2017.
The new law required mortgage servicers that were operating in Pennsylvania to be licensed. Companies had until June 30, 2018, to apply without being penalized for unlicensed activity.
SoFi vs. Prosper: Which Personal Loan Lender Is Right for You? (credible), Rated: A
SoFi and Prosper are two companies that offer personal loans with competitive interest rates and no prepayment penalties. However, there are some major differences between the companies that could affect your decision on which one to choose.
Money 2020 Highlights, Jobs Report, Markets Doubt Fed (PeerIQ), Rated: AAA
What’s Hot and What’s Not at Money 2020?
Attendance was at record levels. Here’s our view on the areas attracting the most attention at Money 2020:
- Lending-as-a-Service: lenders that enable non-banks, banks and credit unions originate loans (e.g., loan origination software, digital experience, bank workflow software, etc.). Examples: Better, nCino, Happy Money (backed by CUNA Mutual), Alchemy, Splash Financial, Blend, Roostify
- International Lending: Non-banks expanding access to credit, particularly in the LatAm markets. Examples: CrediJusto (Mexico SME), Addi (Colombia POS), Nova Credit
- Underwriting infrastructure: Reducing OPEX or fraud risk thru automation. Examples: Ocrolus, Feedzai
The healthy Friday jobs report supports the ‘wait and see’ Fed view (although it is a backward looking indicator). The report indicated growth in employment of 128K in October and a tick-up in unemployment to 3.6%.

Kabbage partners with GoDaddy to offer capital to entrepreneurs and SMBs (Tearsheet), Rated: AAA
The partnership: Kabbage’s online lending platform is now available to GoDaddy’s U.S. customers to access a business line of credit in minutes.
- Customers can access flexible lines of credit of up to $250,000 in minutes after filling out a short application.
- Existing GoDaddy customers can get $100 off their first month’s fees
- “We know that a lack of capital for marketing and other core activities remains a major roadblock to accelerate growth. Our partnership with Kabbage is key in our ongoing mission to empower our customers and provide them with the resources they need to fuel their business needs,” said Melissa Schneider, GoDaddy’s vice president of global marketing operations.
Ron Suber Shares Perspective on Fintech (Crowdfund Insider), Rated: A
Ron Suber is one of the better-known names in the Fintech sector. Originally, Suber’s role as the President of the marketplace lending platform Prosper Marketplace brought Suber’s name to prominence as the Fintech emerged as an early leader in the US online lending market. Since departing Prosper’s management team several years ago, Suber has been associated with multiple Fintech’s as an investor, advisor or, perhaps, a board member. Today, Suber has invested in more than a dozen Fintech companies
Real estate crowdfunding startup CrowdStreet turns to its customers to raise $ 12M round (GeekWire), Rated: A
CrowdStreet, a Portland-based commercial real estate crowdfunding startup, has raised a big new funding round, with a twist. Instead of relying solely on venture capital investors, the startup turned to its own community of real estate investors and developers to raise the bulk of the money for its Series C round.
The result: CrowdStreet this morning announced it has raised $12 million, primarily from the users of its platform, bringing lifetime funding to $25 million.
CrowdStreet lands $ 12M in financing, hires execs (The Real Deal), Rated: B
Robert Stiles, former chief financial officer at LendingHome, joined as CFO/COO. Londa Quisling was named chief technology officer, after serving as chief product officer at Treehouse. And John Havens, previously of BNY Mellon, joined as vice president of capital markets.
Inside Affirm’s ID Verification And Fraud Prevention Techniques (PYMNTS), Rated: A
Many consumers do not have funds readily on hand to make big purchases like electronics or furniture and prefer turning to instant loan apps like Affirm, a point-of-sale installment lender established in 2013, rather than going into debt with a bank or credit card provider. Customers may feel thankful to be able to pay off a purchase over a year, but not at the cost of losing their identities to fraudsters or scammers.
Max Levchin backs digital banking startup built to reward savers (Finextra), Rated: A
A new digital banking platform promising to help reward people for positive financial behaviour has closed a $3.5 million seed round led by Accomplice Ventures and Walkabout Ventures nd joined by PayPal founder Max Levchin’s startup studio.
LA is fast becoming a fintech hub as HMBradley launches another West Coast challenger bank (TechCrunch), Rated: B
Add HMBradley to the list of Los Angeles-based startups looking to shake up the world of high finance typically dominated by East Coast giants with names like JPMorgan Chase, Citigroup, Morgan Stanley and Goldman Sachs.
Building A Challenger Bank That Actually Challenges Traditional Banking (PYMNTS), Rated: A
Minus the CEOs at the top-10 largest banks in the U.S., whose main concern is probably figuring how to deal with their trillions of dollars’ worth of assets, nearly the entirety of bank CEOs outside that tier have one primary concern, according to Bruhnke: How do they grow deposits? Meanwhile, he noted, bank customers also have a singular desire: How do they make the most money on the funds they have deposited?
How Goldman Sachs plans to boost its reputation with online bank Marcus (Yahoo! Finance), Rated: A
Goldman Sachs’ upstart digital consumer bank, Marcus by Goldman Sachs, will help boost the reputation of its parent company, one of its leaders told Yahoo Finance recently.
The OCC Fintech Charter Is Down, but Maybe Not Out (Lexology), Rated: A
The Office of the Comptroller of the Currency (OCC) recently faced another setback in its attempt to issue a special purpose national bank charter tailored to fintech companies (fintech charter). A federal district court in New York held that the OCC does not have the authority to grant charters to companies that do not accept deposits. The ruling is a blow to the OCC’s efforts to provide new avenues for innovation in financial services. The fintech charter would allow fintech companies, which do not accept deposits like traditional banks, to benefit from the same preemption of state laws and licensing requirements as national banks.
Troubled Fintech Charter: How More Delays Impact Competitive Situation (The Financial Brand), Rated: A
The other is Varo, which initially considered going for an OCC special purpose charter but then decided to apply for a full-service charter. Varo has preliminary approval from OCC and awaits approval of its FDIC deposit insurance application. Below, we look at how Lending Club, the online marketplace consumer loan platform, is exploring chartering options.
Crypto APIs Launches Trading APIs, Allowing Users to Leverage Multiple Crypto Exchange Accounts (Cryptovest), Rated: A
The Trading APIs service provides one Unified API that has integrated multiple crypto exchanges. Thus, users will now be able to link multiple exchange accounts to their profile, collect data and execute their portfolio management trades from a single point.
Crypto APIs is used by thousands of developers to create products like Crypto exchanges, Crypto wallets, Trading bots, Crypto PSP, Arbitrage solutions, Crypto Lending solutions and many more.
Brex And Bank Of The West Team On Co-Branded Credit Card (Forbes), Rated: A
Brex, the fintech credit card startup, is teaming up with Bank of the West, the subsidiary of BNP Paribas, to roll out a co-branded credit card. It marks the first co-branded credit card to come out of Brex which caters to startups and entrepreneurs.
Washington flexes its muscles on small-business lending (American Banker), Rated: A
In one instance, the Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency angered borrower advocates by siding in court with a high-cost business lender. In the other, the Consumer Financial Protection Bureau signaled its intention to move forward with a small-business lending rule that has languished for nine years amid sharp disagreements over its proper scope.
USA Continues to be a Top Location for Fintech Events (Fintech News), Rated: A
On the global fintech scene, the US has been amongst the top leaders, accounting for 57% of the fintech market in 2018, according to a Mordor Intelligence research.
Fintech continues its momentum this year, with investment in US fintech companies surging to US$12.7 billion in the first half of 2019. That represents a 60% increase in value of deals and signals a trend of larger deals in already the world’s biggest and most active fintech market, according to data from Accenture.
Legitimate Shoppers Take Advantage of Deals, Outpacing Seasonal Growth in Fraudsters (Riskified Email), Rated: A
A new report from Riskified, the payments and fraud-prevention solutions provider, reveals that the full holiday shopping season is substantially safer for eCommerce merchants, as the increase in sales volume from legitimate shoppers far outpaces growth in fraud attempts. In addition, the report shows that purchases via mobile apps are significantly safer for merchants during the holiday season than at other times of the year. And it cautions merchants against assuming that typical indicators of risk are actual fraud during the holiday season.
“Unwrapping Holiday Fraud: Insights to Protect Your Business & Drive eCommerce Revenue” emphasizes that shopping behaviors during the holiday season are different than during the rest of the year – and not just in terms of volume. It explains that consumer behaviors and fraud trends are not consistent throughout the year, or even the holiday season. It breaks down holiday shopping into six key sub-seasons – each with its own unique considerations.
Elevate Credit to Attend the Stephens 2019 Investment Conference (BusinessWire), Rated: B
Elevate Credit, Inc. (NYSE: ELVT) today announced that its Interim Chief Executive Officer, Jason Harvison, and Chief Financial Officer, Chris Lutes, will attend the Stephens 2019 Nashville Investment Conference on November 14th at the Omni Nashville Hotel. Mr. Harvison and Mr. Lutes will be available for 1×1 meetings with investors.
Michigan AG sues online tribal lender (Lexology), Rated: B
On October 31, the Michigan attorney general announced it filed a lawsuit against an online lender alleging the lender violated the CFPA and Michigan…
United Kingdom
Peer-to-peer lender Zopa makes banking debut as pressure mounts (City A.M.), Rated: AAA
Zopa, one of the UK’s three largest names in peer-to-peer lending, is to launch its first foray into banking after receiving partial authorisation last year.
RateSetter begins roll-out of investor self-certification (P2P Finance News), Rated: AAA
RATESETTER has begun asking its customers to confirm their investor status ahead of the Financial Conduct Authority’s (FCA) new marketing and disclosure rules that come into effect on 9 December.
iwoca hits £1bn lending milestone as headcount soars (AltFi), Rated: A
UK business lender nearly doubled its lending last year to £330m, helping the startup announce it has now reached a cumulative lending milestone of over £1bn.
The news comes as iwoca’s headcount has jumped 50% in the last 12 months, boosted further by the £10m BCR grant which the company secured in August to further expand its customer base.
China
China has a steady hand on its slowing economy, but can it prevent a crash landing? (SCMP), Rated: AAA
Year-on-year growth has fallen by 0.2 percentage points per quarter this year, from 6.4 per cent in the first quarter to 6.2 per cent in the second quarter and to 6 per cent in the most recent quarter.
China to Transform Remaining P2P Platforms (Finews.Asia), Rated: A
Recent data showed that the number of online P2P platforms plummeted to just 427 – a 59 percent drop compared to 2018-end. The total outstanding loan value and the number of borrowers also dropped correspondingly by 49 percent and 55 percent, respectively.
China is making rapid inroads towards reducing peer-to-peer lending risk to meet the 2020 target deadline but expects to keep alive the few remaining with strong fintech expertise and shareholder support.
China warned to avoid P2P lending mistakes in blockchain push (Tech in Asia), Rated: A
China has been warned to avoid the same mistakes with blockchain that it made with its peer-to-peer lending, as the government vowed a “thorough revamping” of the controversial lending platforms as part of a continuing battle against financial risk amid the domestic economic slowdown and the trade war with the US.
Chinese fintech players want to do a Xiaomi in lending. Caution: regulatory glare ahead (India Times), Rated: A
Asset management arbitration cases in China (Vantage Asia), Rated: A
The wave of closures of P2P platforms in China in the summer of 2018 garnered national attention. The latest blacklist for P2P lending published by “P2PEYE.COM” (https://www.p2peye.com/platform/wenti) shows that as of the end of March 2019, the number of problematic P2P platforms reached 5,388.
European Union
Marks & Spencer Buy Now, Pay Later Option (The National Law Review), Rated: AAA
Klarna, a popular BNPL provider used by over 4,000 UK retailers, offers three types of BNPL service:
- delayed payment up to 30 days after purchase. This incurs no interest or fees, providing the payment is made within the timeframe.
- instalment options whereby the purchaser can pay in three equal, interest-free payments every 30 days.
- flexible financing, which spreads the cost of larger purchases into manageable monthly payments. The term for this repayment option ranges from six to 36 months.
Upcoming maintenance affecting ability to view orders (Klarna), Rated: A
On Wednesday 6th November at 05:00 CEST, we will perform an important technical maintenance which will prevent customers from seeing some order details within the Klarna app for a short time. We expect this maintenance to take approximately 15 minutes, after which time full details of orders will become accessible again.
LendIt Fintech Europe 2019 Slide Presentations Now Live (LendIt), Rated: AAA
Below, you can find the presentations from keynote speakers at the event, as well as the different track presentations.
Lending Innovations
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- The Evolution of New and Alternative Data Sources – Sam Coe, Experian
- Thomas Bull – Auditorium – Tom Bull, Ernest & Young
More presentations here.
International
Beijing may cull a stateside unicorn stampede (Reuters), Rated: AAA
Chinese firms have raised just $3 billion from American exchanges so far this year, less than a third of the 2018 total. In the last week of October, however, half a dozen companies filed for initial public offerings in New York, bringing the total backlog of Chinese floats to 24, according to data from Refinitiv. Rising trade uncertainties, tougher listing requirements on the NASDAQ and an upcoming U.S. presidential election have sparked fears that 2020 may prove even more volatile for debutants.
International P2P Lending Volumes October 2019 (P2P-Banking), Rated: AAA
Mintos leads ahead of Zopa and Ratesetter. The total volume for the reported marketplaces in the table adds up to 703 million Euro.
Milestones in cumulative volume lent crossed this month:
- Ablrate: 50M GBP
- Crowdproperty: 50M GBP
- Grupeer: 50M EUR
Asia
P2P lending platform Validus expands into Vietnam (Business Times), Rated: AAA
SMEs make up 97 per cent of Vietnam’s enterprises, but only account for 22 per cent of total bank lending. To meet a US$21 billion SME financing gap in the country, Validus Vietnam will partner corporates to provide SME growth financing to their vendors and subcontractors.
How South Korea’s PeopleFund Is Shaking Up P2P Lending (Yahoo! Finance), Rated: A
Joey Kim, chief executive officer at PeopleFund, discusses what his company does, the growth drivers for his company, his latest funding round, P2P lending in South Korea, regulation, the possibility of consolidation in the industry and how the Korean economic headwinds are impacting his business. He speaks exclusively on “Bloomberg Daybreak: Asia.”
Vietnam’s IT Sector: 5 Industries to Watch (Vietnam Briefing), Rated: A
Vietnam’s fintech industry is expected to reach US$7.8 billion in revenue by 2020. A rising middle class, growing internet usage, and a young population present a great combination for the fintech sector to thrive. An estimated 120 companies and brands cover a wide range of services, from digital payments to wealth management and blockchain.
Fintech help banks broaden customer base (The Jakarta Post), Rated: A
Instead of competing against each other, banks and financial technology (fintech) companies are joining hands and combining their resources to tap into the country’s growing financial services market.In an effort to keep up-to-date with recent technology and stay relevant amid the latest changes in financial services, many banks have signed partnership deals or bought into nimble start-ups as an alternative to building costly technology projects.For the banks, the logic behind a partnership with fintech companies is simple: It gives them the opportunity to reach a wider customer base, unlock their technological capabilities without having to buy one of their own and penetrate the country’s unbanked population — all without having to spend too much money.“We are partnering with 12 fintech companies from peer-to-peer [P2P] lending and payment apps to SME [small, middle, enterprise]…
Latin America
Preview of LendIt Fintech’s inaugural LatAm conference (LendIt), Rated: AAA
Temenos’ report tags financial inclusion as LatAm bankers’ priority (IBS Intelligence), Rated: A
Temenos has concluded the LatAm results for its annual retail banking survey, conducted by the Economist Intelligence Unit (EIU). The survey titled ‘A whole new world: How technology is driving the evolution of intelligent banking in Latin America’ stated that 35% of retail bankers prioritize investments in digital technologies along with cost-cutting or margin improvement for furthering their financial inclusion goal.
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