1/20: Jamie Dimon. Love him or hate him it’s difficult to deny that he’s one of the most talented Bankers of our era. In his recent shareholder letter he points out what he perceives as an unfair playing field between Banks and Fintechs. A quick response to Jamie:
2/20: Dear Mr. Dimon. I read your recent shareholder letter (twice!) and have to admit that it’s a great read. I found myself agreeing with many critical points you made and positions you were taking, but I also found myself wanting to share a slightly different perspective.
3/20: Boiling the ocean, I think the main point that you’re making is that there should be an even playing field between players. It’s clear that you welcome sensible regulation and believe that everyone in the system benefits when the rule system is designed thoughtfully.
4/20: You’ve (rightly so) been a champion of good policy and a critic of bad policy. You embrace regulation that systemically eliminates potential harm by instituting protective guardrails that are understandable and cost effective to implement.
5/20: You challenge regulations that protect against perceived but unquantifiable risks and you abhor regulations that lead to unintended outcomes (e.g. – The liquidity rules that caused the squeeze in repo rates prior to the COVID crisis).
6/20: The world is better with heroes who stand up for truth and justice and I’m happy to know that you’re out there fighting the good fight on behalf of us all. But I don’t recall ever seeing Superman ask for rule changes. He just focuses on winning.
7/20: A major “look in the mirror” opportunity you have is to internalize that you’ve created an environment where your decision makers are incentivized to minimize regulatory risk vs. manage regulatory risk. There’s a difference and it’s profound.
8/20: Paranoia around what Regulators MIGHT do is running rampant throughout the traditional Banking ecosystem. JPM is no exception. Fear is driving internal policies and decisions around how to test (and eventually launch) new value propositions, products and services.
9/20: Perceived regulation is self-imposed and that’s on you. You’ve created the environment and incentive system that’s created the problem. Your teams fear the Regulators. Your teams don’t want to get challenged. You need to own and solve this
10/20: You’ve set up a system where your Executives earn their bonuses one year at a time and set the goals such that a typical Executive can earn 90% of his/her bonus by saying “no” to everything new.
11/20: You’ve set up a system where the vast majority of your employees aren’t rewarded for pushing the envelope but they are punished if they go too far. It’s a system with zero upside and unlimited downside (getting fired).
12/20: You’ve set up a system where when you or someone on your Operating Committee wants something done, all the people who were saying “no” figure out how to say “yes”. Once accountability has been transferred they’re ready to get on the bus.
13/20: You’ve set up a system where all the “control” parties (risk, legal, compliance) have an unlimited number of black balls and ultimately oversee what gets released into the market. The business is forced to let the tail wag the dog and has sadly accepted this as sacrosanct.
14/20: Contrast this to a startup where getting to “no” is equivalent to shutting their doors. It has to string together enough “yes” answers over a multi-year period to earn the right to survive. Yes does not mean cheating or avoiding rules. Yes means finding a way that works.
15/20: Fintechs start with market gaps and unsolved customer problems. They believe that reward ultimately accrues to companies that solve these problems and delight customers. They live in the world of “how” instead of in the world of “no”.
16/20: So while there might be some truth to your comments that the Regulatory environment hasn’t created a “like to like” playing field, it’s more than a little stretch to claim that this is the root cause of Fintechs out-innovating the traditional Banking giants.
17/20: What’s stopping you from allowing your customers to access deposits with the same speed that Neo-Banks do? What’s stopping you from creating a “push button borrow $100” product for your customers? If Fintechs can do these things surely your Bank can.
18/20: You need to start asking “what products do my customers want” instead of “what products can I offer so as to not get asked questions by Regulators”. That's what's important. That's how value is created. That's how you continue to win.
19/20: And lest you forget, you sit in a truly powerful seat with advantages that can’t be copied. Many Fintechs exist simply to take more risk than incumbents. They’ll get it wrong most of the time but when they get it right you can copy them or buy them. Problem solved.
20/20: So Mr. Dimon, I applaud you for the company you’ve built, the complexity you’ve navigated, and what you stand for. My suggestion from the cheap seats would be to turn your energy internally because you can move the needle in a way that will directly benefit your customers.
You can follow @fintechjunkie.
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