What is the AFM's opinion on disintermediation in the context of innovation?

Disintermediation is a frequently used concept in FinTech publications. Parties are increasingly focusing on a very specific section of the value chain with the aim of digitally innovating this particular section. The AFM and DNB observe this in actual practice and the activities of these parties often involve intermediation. For example:  A financial enterprise engages the services of a FinTech company to collect relevant data for extending a mortgage loan. The FinTech company collects the data for the consumer at the financial enterprise's request and delivers it – with the consumer's consent – to the mortgage loan provider. This involves professional intermediation activities with the objective of establishing an agreement. Please consult the AFM's website for more information.

In addition to contributing to the establishment of an agreement, assisting in managing and executing the agreement are also considered intermediation activities.  We realise that this substantially broadens the definition of intermediation. The question is which FinTech activities are included in the definition and which are not. This is currently a "grey" area, as the legislature has so far not regulated such activities. The AFM is looking into this and will issue more information on its website in due course.

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