Recommendation 119

ClearBank noted that the experience of supervisory staff has created difficulties for the regulators understanding and adapting supervisory processes to account for novel business models: “specifically for Embedded Banking, 190 regulators have struggled to understand how to best [oversee] the model.” 191 Improving the quality of supervision for new business models can provide the clarity firms need to grow, as ClearBank noted: “Regulators devoting the resource to fully embrace newer business models will improve standards of supervision, facilitate growth and help the UK to remain internationally competitive.” 192 Rigid supervisory practices