Six Predictions for 2023: Me vs. ChatGPT
Crypto Catchup: Coinbase Consent Order, BankProv Exec Shuffle, NY AG Sues Celsius Founder, Silvergate's Bank Run & more
Hey all, Jason here.
Happy New Year! Welcome to 2023. It was nice to take a couple weeks off (more or less anyway) — probably the longest holiday I’ve had in at least five years! Got to spend some time in México and the US before returning to the Netherlands earlier this week.
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Six Fintech, Banking & Crypto Predictions for 2023: Me vs. ChatGPT
I set myself a pretty high bar with my predictions for 2022, with five out of six more or less coming to pass (and, frankly, Monzo should’ve quit the US, but that’s another story altogether.)
I’m kicking off this year with six predictions for the year, but, this time, it’s a head-to-head match up with AI-generated predictions from ChatGPT (turns out AI is ‘reluctant’ to predict the future — go figure.)
If you’re not familiar, ChatGPT is an AI language model for generating dialogue — you may have noticed screenshots of copy it generated flooding social media late last year. If you haven’t played around with it, it’s worth spending some time and considering the implications on customer service (chatbots/voicebots), UI/UX, marketing (AI-generated copy), and so on.
1. Crypto Fallout Continues, But Prices Stay In A Narrow Range
2022 was, no doubt, a tough year for crypto. While true believers tend to put on a brave face and describe the rout as a “healthy clearing out” and crypto winter as being “the best time to build,” I’m not sure that’s a realistic, clear-eyed reading of where the industry and market are.
For one, there are still more dominoes to fall. Late last year, rumors about Binance, the world’s largest crypto exchange, proliferated, though the company was able to meet demands for some $5 billion in withdrawals. Winklevoss-founded Gemini has $900 million of assets trapped with Genesis, which, in turn, froze withdrawals in November after FTX collapsed. Details about the problematic, unethical, and likely illegal conduct at FTX continue to drip, drip, drip out in its bankruptcy proceeding and criminal cases.
In the wake of FTX, reputable auditors increasingly are shying away from working with crypto-related firms, designating them “high-risk” or ceasing to work with firms in the industry altogether — as Mazars did late last year, when it quit working with Binance on so-called “proof-of-reserves” audits.
Further, the pain in crypto has metastasized to a small number of traditional banks that went all-in on crypto. Players like Silvergate, Signature Bank, Customer, Metropolitan, and Provident Bancorp (BankProv), have experienced significant knock-on impacts from the crypto meltdown, in the form of deposit flight and, in some cases, significant credit exposure to crypto-related firms.
The Wall Street Journal characterized the deposit run on Silvergate, which revealed last week that $8.1 billion in deposits left the bank in the fourth quarter, as “worse than Great Depression-era runs.”
In a strange twist of fate, it seems crypto’s last-best hope of a recovery may lie in hoping for more regulation and new legislation. After the wildly irresponsible risk management that has led to numerous bankruptcies, not to mention outright frauds and Ponzi schemes, crypto is desperately in need of an external boost to its legitimacy.
That, however, may not be forthcoming. With a divided Congress, the prospect of new legislation, for instance laying down rules for “stablecoins” or handing new authority to the CFTC or SEC, seems less likely than ever. Meanwhile, SEC chair Gary Gensler is of the opinion that most tokens are securities and should be regulated by the SEC.
One place where more regulation is likely: the banks that crypto firms rely on as a bridge to the traditional financial system. Just days into the new year, the Fed, FDIC, and OCC issued joint guidance warning banks on the risks of crypto asset exposure.
Still, the likelihood of crypto disappearing completely seems extremely low. More than a financial instrument, for many, crypto has become an identity. Like Occupy Wall Street protestors or “gold bugs” of the past, some in the ecosystem embrace and advocate crypto as an ideology, rather than as an investment.
Despite significant turmoil since the collapse of FTX, since then, bitcoin has traded in a fairly tight range between about $15,000 - $18,000.
My prediction:
I expect the tumult from 2022 to continue — there will be more failures and bankruptcies as hidden leverage and opaque interlinkages between crypto exchanges, lenders, and investors continue to unwind. Crypto-focused banks like Silvergate and BankProv are likely to incur some kind of regulatory action. Increasing interest rates will continue to put pressure on crypto prices, but “true believers” will keep bitcoin trading in a narrow range around where it started the year — $16,605.
ChatGPT’s prediction:
It is difficult to accurately predict what will happen in the cryptocurrency market in the coming year. Cryptocurrency values are highly volatile and can be influenced by a wide range of factors, such as government regulations, market conditions, and global economic trends. It is important for investors to carefully research and consider their options before making any investments. It is also important to keep in mind that investing in cryptocurrency carries a high level of risk and may not be suitable for everyone.
2. Goldman Kills Off Marcus Brand
Given recent events, this feels like a pretty low-risk prediction to make.
Last October, the firm announced a major reorganization, with Marcus being absorbed into a newly created wealth and asset management division. Apple and GM cobrand partnerships and POS lender GreenSky went into a newly-formed “Platform Solutions” division.
In December, news broke that Goldman would cease making unsecured personal loans and cut a significant number of jobs from the consumer business.
Finally, at the start of this year (bonus season and all), the news broke that Goldman’s head of its Marcus business, former Stripe and PayPal exec Swati Bhatia, would be stepping down.
However, consumer business alum Zeeshan Razzaqui has moved to the new Platform Solutions division, helmed by Stephanie Cohen, and named co-head of GreenSky — suggesting the GreenSky business will stick around (for now, at least.)
My prediction:
At this point, it seems the writing is on the wall for Marcus. I expect that Goldman will wind down the Marcus brand sooner rather than later and transition any remaining general market consumer products, like its high-yield savings accounts, to the Goldman Sachs brand.
ChatGPT’s prediction:
I am not aware of any plans for Goldman Sachs to get rid of its Marcus brand. Marcus is a digital banking platform that was launched by Goldman Sachs in 2016. It offers a range of financial products, including savings accounts, personal loans, and home improvement loans. It is possible that Goldman Sachs may make changes to its Marcus brand or product offerings in the future, but I do not have any information on this.
3. Apple Continues Push Into Financial Services, Identity
Apple, the most valuable company in the world by market cap, can afford to play the long game in a way virtually no other company can. The company launched Passbook, which became Apple Wallet, in 2012.
In the subsequent decade, Apple has slowly but surely expanded Wallet’s functionality, most notably with Apple Pay in 2014 and Apple Card, with bank sponsor Goldman, in 2019.
And Apple has slowly but surely made progress in encouraging adoption: it’s estimated that some 75% of US iPhone users have “activated” Apple Pay, though in-person usage remains low, with surveys showing as few as 6% of US iPhone owners use it for in-store transactions. Still, Apple Pay is expected to generate nearly $4 billion in revenue for the company this year.
Further, announcements from Apple and reporting indicate the company is moving to in-source more of its financial services capabilities, potentially including payment processing, credit risk underwriting, fraud analysis, and customer service functions.
While Apple’s buy now, pay later feature, dubbed Apple Pay Later, was unexpectedly delayed, it presumably will launch some time this year. In the meantime, the company has also announced plans to launch a savings feature within Apple Wallet, powered by Goldman — though it will initially only be available to existing Apple Card holders.
The company has also been aggressive in pushing for Apple Wallet to house identity credentials like driver’s licenses. Through contracts with state DMVs and a secret research agreement with the US Department of Homeland Security, Apple is pushing to make its devices even more central to its users’ lives by becoming a storehouse of trusted identity credentials.
My prediction:
It’s a safe bet that Apple Pay Later will finally launch, probably in the first half of the year. The savings account feature will also launch and, I expect, expand from Apple Card users only to a general market offering. Also a possibility that Apple Card and the Wallet savings feature launch in the UK.
Low but possible that Apple announces plans to expand its identity offerings to include US passports or identity credentials in a foreign jurisdiction.
ChatGPT’s prediction:
Apple has not announced any plans to become a traditional bank. However, the company does offer a number of financial services through its Apple Card, which is a credit card that is linked to the Apple Pay digital payment system. Apple Card users can make purchases, track their spending, and pay their balance using the Wallet app on their Apple devices.
In addition, Apple has also launched the Apple Cash service, which allows users to send and receive money through iMessage. While these services allow Apple to play a role in the financial lives of its customers, the company is not licensed to operate as a bank in the traditional sense.
4. Banking-as-a-Service Matures, Consolidates
Will 2023 be an inflection point for banking-as-a-service? There are numerous cross currents in play that will shape how the industry evolves this year.
On the one hand, more regulatory action seems to be imminent. Throughout 2022, government entities, particularly the OCC, CFPB, and Treasury, have been increasingly explicit about perceived risks in fintech/banking partnerships.
But despite a lot of talk and speculation last year, we only know of one BaaS-related regulatory action so far: the consent order Blue Ridge entered into with the OCC.
That said, as the FTX fallout spread, partner banks’ ties to crypto-related startups, particularly through middleware platforms like Synapse and Solid, came under the spotlight.
As 2022 headed toward a close, “Bank for the Metaverse” ZELF publicly launched, touting “anonymous” bank accounts for users anywhere in the world. Within a day of launching, ZELF’s bank partner Evolve pulled the plug, but that ZELF was running live in production for months reveals critical flaws in how banks and middleware platforms have been approaching due diligence and compliance.
The explosion in partner banks and BaaS platforms has been powered by an ever-increasing number of new fintechs that need banking services. The creation and growth of these fintechs, in turn, has been powered by plentiful venture capital.
As the tide of money has receded, it’s reasonable to assume fewer new fintechs will be founded, existing fintechs will spend less on customer acquisition marketing (meaning fewer new account openings), and some fintechs will fail altogether.
Macroeconomic factors are likely to impact the demand for and profitability of banking-as-a-service arrangements as well.
While interchange-driven business models have a built-in hedge for inflation, lending-driven models don’t. Rising interest rates can make deposits more valuable as NIM expands, but also will squeeze lower-income and lower credit score consumers as the cost of servicing their debt increases.
Combined, this could mean moderating demand for services from partner banks and BaaS middleware platforms.
My prediction:
I expect at least two prominent partner banks to get hit with some type of regulatory action. Partner banks and middleware platforms become increasingly selective about the clients they’ll take on.
Amidst increasing oversight and thus rising compliance costs and decreasing demand from crypto and fintechs, the number of banks pursuing BaaS business models declines. At least one BaaS platform is acquired or fails outright.
Startups focused on providing automated and scalable compliance capabilities, particularly around BSA/AML compliance, become increasingly must-have vendors.
ChatGPT’s prediction:
It is difficult to predict exactly what will happen in the banking-as-a-service (BaaS) sector in the coming year. The BaaS market is rapidly evolving, and a variety of factors, including changes in technology, customer demand, and regulatory environment, could impact the sector. It is possible that we will see continued growth and innovation in the BaaS market, as well as increased competition among BaaS providers. It is also possible that we will see changes in regulation of the sector, although it is difficult to predict exactly what form these changes may take. It is important for companies operating in the BaaS sector to stay up-to-date on developments and be prepared to adapt to changes in the market.
5. Neobanks Face Trying Times
2022 was already a difficult year for neobanks. After strong tailwinds and booming valuations during the pandemic, companies in the space began to fall back to earth last year.
Neobanks have had to quickly pivot from a growth-above-all-else mindset, powered by plentiful VC funding, to trying to make their unit economics work.
It’s been a struggle.
Dave and MoneyLion, arguably closer to payday lenders than true neobanks, have seen their share prices languish and legal woes mount, including a potential class action suit against Dave regarding its claims of having “no hidden fees.”
LendUp sold its neobank, Ahead, to Kinly as part of its liquidation — though an apparently botched transition left some users frustrated and unable to access their funds.
Varo, arguably the only true US “neobank” that has become a bank, has laid off employees and drastically cut marketing spending, but still posted a $42 million loss in Q3 2022, the last quarter for which information is available.
Things haven’t necessarily been better outside the US. Though Starling has achieved profitability, that was powered in large part by its temporary role helping to facilitate the UK’s Bounce Back Loan Scheme. And, like US fintechs that cashed in on PPP, Starling is also facing accusations of elevated fraud rates vs. traditional bank lenders.
Revolut, by far the most ambitious neobank (superapp?), is facing its own challenges. Despite repeated claims from CEO Nikolay Storonsky that the company is “profitable,” it has repeatedly delayed filing its 2021 accounts, and UK regulators have criticized the auditing of Revolut’s accounts as “inadequate.”
My prediction:
All signs indicate the macro environment will continue to be challenging: inflation is likely to remain elevated, and interest rate hikes will continue. Rate hikes quickly pulled the rug out from under asset valuations and put the mortgage and housing markets into a deep freeze. While employment so far has proven resilient, it’s unlikely that central banks can tame inflation without inducing a recession and unemployment rising.
Any recession is likely to hit US neobanks disproportionately hard, as their customers are overwhelmingly lower income and lower credit score. Neobanks have not been successful in lending to this segment, and macro headwinds may reduce interchange income and encourage user churn; losses from overdraft, small-dollar loans, and credit builder cards are likely to increase.
The upshot? I expect to see Varo continue to struggle, though it will survive 2023. Chime may be forced to fundraise at a substantially lower valuation than its last $25 billion round. And Monzo just might finally cut its losses and exit the US market.
ChatGPT’s prediction:
Neobanks, also known as digital banks or online-only banks, are a type of financial institution that offer banking services exclusively through a digital platform. These banks do not have physical branches and customers interact with them through a website or mobile app.
Neobanks have gained popularity in recent years due to their convenience and the ability to offer services at lower costs than traditional banks. However, it is difficult to predict the future of any specific industry or business. Some neobanks have been successful and have attracted a large number of customers, while others have struggled.
Overall, it is likely that neobanks will continue to be a part of the financial landscape in the future, although it is possible that some individual neobanks may not be successful. The success of a neobank will depend on a variety of factors, such as its business model, the quality of its products and services, and its ability to adapt to changing market conditions.
6. CFPB Continues Focus on “Junk Fees,” Open Banking
The CFPB was plenty active in 2022 — yes, in terms of enforcement actions and rule making, but even more so in Director Chopra’s use of the bully pulpit. The agency published 20 enforcement actions last year, hitting companies from small fintechs, like Digit and MoneyLion, to huge banks, like Bank of America and Wells Fargo.
Director Chopra appeared at October’s Money20/20 conference, pledging to advance 1033 rulemaking to codify customer data portability rights (“open banking”) called for by 2010’s Dodd-Frank.
Last year also saw amped up rhetoric from the agency, particularly around topics like “junk fees,” big tech, competition, and “data harvesting,” and the promise the agency would activate its “dormant” authority to examine nonbank entities that “pose a risk” to consumers. The agency also sought to expand the definition of UDAAP to include a broad definition of discriminatory practices in products beyond credit — something industry trade groups are pushing back against.
Toward the end of the year, the agency also revealed its first-ever inquiry into a crypto company, Nexo.
My prediction:
Like other government agencies, the CFPB publishes information about its rulemaking agenda, which gives us decent insight into the agency’s plans for next year. Yes, “Required Rulemaking on Personal Financial Data Rights” is there in the “Prerule Stage,” but so are items about overdraft fees and NSF fees (Prerule) and credit card penalty fees (Proposed rule).
I think it’s safe to predict the bureau’s war on fees will continue, as will its quasi-antitrust obsession with big tech’s push into financial services and “data harvesting.”
Given the broad and continuing fallout in the crypto sector, I suspect more CFPB inquiries into crypto companies will commence or come to light.
Low probability but a possibility is the bureau designating a major nonbank entity as “posing a risk” to consumers to justify bringing it under the CFPB’s examination authority — potentially a “big tech” player, like Apple, or a fintech infrastructure company, like Plaid.
This may be more wishcasting than a likely-to-happen prediction, but perhaps the CFPB will take meaningful action, through enforcement or rulemaking, clarifying how “tips,” “expedited funding fees,” and membership fees should be treated for the purposes of TILA and APR calculations.
Finally, and a near-certainty, is the grilling of Director Chopra by the House Financial Services Committee, now under Republican control. House Republicans may also seek to choke off funding to the bureau, depending on how an ongoing legal challenge turns out.
ChatGPT’s prediction:
The Consumer Financial Protection Bureau (CFPB) is an independent agency of the United States government that was created in 2010 to protect consumers in the financial sector. The CFPB is responsible for enforcing federal consumer financial laws, regulating financial institutions and products, and educating consumers about their financial options.
It is not possible for me to predict what specific actions the CFPB will take this year, as the agency's activities are dependent on a variety of factors, including the current state of the financial industry, the priorities of the agency's leadership, and developments in consumer protection laws and regulations.
However, the CFPB's mission is to promote fairness and transparency in the financial marketplace and to protect consumers from harmful or deceptive financial practices. As such, it is likely that the CFPB will continue to focus on issues such as preventing financial fraud, regulating financial products and services, and enforcing consumer protection laws.
Crypto Grab Bag: BankProv’s Christmas News Dump, Coinbase’s $100m Consent Order, Silvergate’s Bank Run & More
The holiday season didn’t prove to be any slower in terms of crypto news. The FTX saga continued, with Alameda CEO Caroline Ellison and Alameda/FTX co-founder Gary Wang pleading guilty and agreeing to cooperate with authorities. Sam Bankman-Fried agreed to be extradited from the Bahamas and was released on bail, though he is confined to his parent’s Palo Alto home.
While legal wrangling in the FTX case may have been some of the most dramatic crypto news over the holiday break, there were plenty of other recent developments worth taking note of.
BankProv’s Christmas Exec Shuffle
Troubled BankProv, the bank subsidiary of Provident Bancorp, whose risky crypto industry strategy we covered last month, announced its CEO behind the strategy would step down after reaching that “mutual decision” with the board.
The timing of the announcement — Friday, December 23rd, at 4:15pm — seems like an attempt to bury coverage of the news. Meanwhile, the company still hasn’t filed its third quarter 10-Q — the delay of which has already caused the BankProv to receive a delinquency notification from the Nasdaq’s listing qualification department.
Coinbase Reaches $100 Million Settlement with NYDFS
Coinbase reached a $100 million settlement with the NYDFS, of which $50 million must be invested in improving Coinbase’s deficient compliance systems. NYDFS has authority here as Coinbase holds a New York “BitLicense” and state money transmitter license.
The consent order paints a picture of a rapidly growing company that, unsurprisingly, prioritized increasing its number of users, transaction volume, and revenue over fulfilling its legally required compliance obligations.
NYDFS found “wide-ranging and long-standing failures” in Coinbase’s anti-money-laundering program, including in its customer due diligence (CDD) and know-your-customer (KYC) practices, transaction monitoring, and suspicious activity report (SAR) filing.
Coinbase “historically did the bare minimum to verify customer due diligence information for customers,” failed to conduct enhanced due diligence (EDD) in a timely manner with, at one point, a backlog of over 10,000 cases, failed to review transaction monitoring alerts with, at one point, over 100,000 unreviewed alerts, and failed to file SAR reports in a timely manner, among other problems.
According to NYDFS, “[t]hese failures made the Coinbase platform vulnerable to serious criminal conduct, including, among other things, examples of fraud, possible money laundering, suspected child sexual abuse material-related activity, and potential narcotics trafficking.”
FRB, FDIC & OCC Joint Regulatory Guidance On Crypto Risks
With crypto fallout hitting banks like Silvergate, Signature, and BankProv, bank regulators joined forces last week to issue guidance on crypto-asset risks to banking organizations.
The brief statement begins:
“The events of the past year have been marked by significant volatility and the exposure of vulnerabilities in the crypto-asset sector. These events highlight a number of key risks associated with crypto-assets and crypto-asset sector participants that banking organizations should be aware of”
before highlighting a laundry list of potential risks crypto asset participants could pose to banking organizations, including:
fraud and scams
legal uncertainty around custody practices and ownership rights
inaccurate or misleading representations from crypto companies, including regarding federal deposit insurance
volatility in crypto markets, which could impact deposit flows
susceptibility of stablecoins to run risk
contagion risk within crypto, which could also present unknown concentration risk
the “lack of maturity and robustness” of risk management and governance in the crypto sector
heightened risks of open, public and/or decentralized networks
Perhaps the most important paragraph in the guidance seems to explicitly rule out banks issuing or holding any public-blockchain-based asset (emphasis added):
“Based on the agencies’ current understanding and experience to date, the agencies believe that issuing or holding as principal crypto-assets that are issued, stored, or transferred on an open, public, and/or decentralized network, or similar system is highly likely to be inconsistent with safe and sound banking practices.
Further, the agencies have significant safety and soundness concerns with business models that are concentrated in crypto-asset-related activities or have concentrated exposures to the crypto-asset sector.”
Silvergate’s Bank Run Led to Asset Fire Sale
New details emerged last week about how FTX’s collapse caused a run on its banking partner, Silvergate — and required the bank to quickly dump debt on its balance sheet to meet some $8.1 billion in withdrawals during the fourth quarter — making it worse than Great Depression-era bank runs.
According to the Wall Street Journal, Silvergate lost $718 million in the rapid liquidations, more than swamping the bank’s total profit since 2013.
FTX: Dave, Robinhood Clawbacks Possible
More information emerged about where FTX’s allegedly stolen customer funds went — and $100 million of it seems to have been used to fund an investment in struggling neobank Dave. Another $100 million went to Web3 startup Mysten Labs.
Based on previous comments John Ray, the new CEO managing FTX’s bankruptcy, has made, the company could seek to clawback those funds. Dave CEO Jason Wilk says FTX’s investment in the company is scheduled to be repaid, with interest, by 2026.
Meanwhile, the dispute over who controls some $460 million in Robinhood shares continues to become more convoluted. Bankman-Fried and his cofounder Gary Wang set up a company, Emergent Fidelity Technologies, that they personally owned; that company borrowed more than $546 million from Alameda to buy the Robinhood shares.
FTX is seeking to clawback the shares, the Justice Department has moved to seize them, and, whoops, they were also pledged by Alameda to now-bankrupt BlockFi as collateral.
And now, Bankman-Fried’s lawyers are arguing he should keep the shares, because he needs the funds to pay for his legal defense.
Wyre to Shutdown
Wyre, a fiat/crypto on ramp once worth $1.5 billion, is shutting down, the company told employees last week, according to reporting from Axios. The news comes about three months after Bolt’s planned acquisition of the company was called off.
Though the reporting is being accepted at face value as true, company CEO Ioannis Giannaros told Axios, “We’re still operating but will be scaling back to plan our next steps.”
Celsius Bankruptcy: Users Don’t Own Assets in “Earn” Accounts; NY AG Files Fraud Case Against Former CEO Mashinsky
Last but not least, there have been a couple of recent developments regarding bankrupt crypto lender/Ponzi scheme Celsius.
A judge in the bankruptcy case ruled that users of Celsius’ “Earn” product, which allowed users to ‘deposit’ crypto assets on the platform in order to earn a return, effectively gave control of their assets to Celsius.
According to the court opinion (emphasis added):
“The Court concludes, based on Celsius’s unambiguous Terms of Use, and subject to any reserved defenses, that when the cryptocurrency assets (including stablecoins, discussed in detail below) were deposited in Earn Accounts, the cryptocurrency assets became Celsius’s property; and the cryptocurrency assets remaining in the Earn Accounts on the Petition Date became property of the Debtors’ bankruptcy estates (the 'Estates')”
The result is that users who had about $4.2 billion in assets in Celsius Earn accounts will be considered unsecured creditors in its bankruptcy proceedings — and are likely to get back just pennies on the dollar of what they had invested with the company.
Given the above, perhaps it’s not too surprising that Celsius founder and CEO Alex Mashinsky has been hit with a civil suit from New York’s attorney general. The suit accuses Mashinsky of defrauding hundreds of thousands of investors, including more than 26,000 New Yorkers, and violating state securities laws.
According to the suit (emphasis added):
“Mashinsky repeatedly made false and misleading statements about Celsius’s safety to encourage investors to deposit billions of dollars in digital assets onto the platform. As Celsius lost hundreds of millions of dollars of assets in risky investments, Mashinsky misrepresented and concealed Celsius’s deteriorating financial condition.”
Other Good Reads
Artificial Intelligence and Fintech (Chaos Engineering)
P2P Payments: Fintech’s Vision Board (Fintech Takes)
The Downsides of Using “Buy Now, Pay Later” (NYTimes)
Crypto Is Money Without a Purpose (Todd Baker/WSJ)
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