All in all, the FSIA would have created a federal oversight regime comprised of twelve FSIOs and a FSIO Liaison Committee to supervise the operation of the proposed regulatory sandbox.
(131) By requiring the FSIO to disclose the "A" that stands to benefit from the "D's" absence in the sandbox, the FSIA makes a good faith effort to require regulators to be transparent and impartial to the "As, Bs, Cs, and Ds" of the fintech ecosystem.
[section][section] 2-6 (discussing the creation of FSIOs and the FSIO Liaison Committee).
The second prong of the FSIA establishes the sandbox itself, allowing a "covered person" (a fintech firm "that offers or intends to offer a financial innovation") to petition one or more FSIOs for an "alternative compliance plan under an 'enforceable compliance agreement.'" (104) In submitting a petition for an alternative compliance plan, a fintech firm must first delineate the regulatory waivers or modifications sought, and subsequently demonstrate that the firm's proposed financial innovation would satisfy the following conditions: (1) serve the public interest; (2) improve access to financial products or services; (3) present no systemic risk to the United States financial system; and (4) promote consumer protection.
(120) To counteract the flexibility of reduced regulation, fintech companies operating within either sandbox are closely supervised by their respective regulatory agencies--the FSIOs of the FSIA and the FCA's sandbox units--to ensure safety to consumers and the respective nations' financial system.
6118 [section][section] 2-6 (discussing the establishment of FSIOs at federal agencies and the ability of a covered person to petition the federal agencies for an enforceable compliance agreement).
[section][section] 2-6 (comprising the oversight regime prong by establishing FSIOs at twelve federal agencies which receive petitions from fintechs).