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Embedded finance: Dear CEO
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In March (2023) 3 JIBFL 190, we discussed some of the challenges in providing sustainable finance products to consumers from the perspective of revenue-based finance; an embedded finance offering. Namely, there is a balance to strike between: (i) speed and automation; and (ii) positive customer outcomes. On 16 March 2023, the Financial Conduct Authority (FCA) issued a Dear CEO letter (Letter), addressed to payment firms supervised by the FCA within its payments portfolio, highlighting concerns that certain payment firms are not currently striking this balance. For embedded finance, the Letter will primarily impact providers that offer embedded banking services (if they are supervised payment firms), but it may have a wider impact across the industry.
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