A Review of Fintech Regulations in China, Singapore, and Hong Kong

The world has transformed from traditional business model into digitalised business model, financial services as well. As financial sector is strictly regulated by worldwide regulator in the past, there’s the dilemma on the regulation in the combination of Financial Technology (“Fintech”). This paper has selected three samples of emerging countries in Asia to examine the current regulations development. In the end of the paper, there is a comparison of regulatory framework between the samples of countries in order to have more understanding on how the regulator had been working on the Fintech industry to overcome the uncertainty. “Banking service is necessary, but not banks.” Bill gates The world economy has been transforming from traditional banking to digital ecosystem. Internet based services have become the most powerful distribution channel tools for businesses environment as well as changing of consumer behaviour nowadays. Following with rapid development in technology and application around the world, there are more opportunities created for businesses. There are many empirical studies on how does internet has changed the business environment and customer’s behaviour (Elena-Iulia 2014, Glova, Sabol and Vajda 2014, Muzellec, Ronteau and Lamkin 2015). Majority of world’s retail banks dominating the financial landscape through providing deposit, payment and credit services, however, they are no longer the only players in the industries. In the recent year, there are increasing of alternative finance gains tractions with customers. Nowadays, the financial services required convenience, fast and data collation. Fintech is the combination of “financial” and “technology”. The raising of Fintech companies, who are coming into the industries through internet-based services such as online funding, lending service, online payment systems, asset management as well as new money capabilities e.g. Bitcoin and block chain technology. However, how would financial institutions look into this disruption? Collaboration or Competition For decades, traditional banking service are competing with other competitor bank among the industry but the banks have to compete with technology based Fintech companies nowadays. In view of early disruptive Fintech Asian Institute of Research Journal of Economics and Business Vol.1, No.1, 2018 44 companies around the world such as Alibaba Group & Tencent, Paypal, M-PESA etc., the communities such as government, investors, entrepreneurs and consumers around the world started to grant attention to the Fintech services. The global investment in Fintech companies raised to USD3.2 billion in the first quarter year 2017 across 260 deals (KPMG International Cooperative 2017). Here’s come with the question with collaboration or competition? While the developing countries has lack of chances deal with financial services, the only way to get them into financial inclusion is the infrastructures. There are believes in Fintech solutions could generate more options than banking options for poor infrastructures developing countries such as India and Pakistan (Kendall 2017). On the other hand, McKinsey (2016) also pointed that the offers from Fintech such as low cost driver and innovative uses of data could be a threat to the banks’ revenues. The collaboration between banks and Fintech companies is better off as banking sector could easier get customer acquisition with collaborate with the advanced technology offering from Fintech companies. There’s no doubt on the traditional financial services are moving into digital era, banks and Fintech companies believe that financial technology is not only able to provide products opportunities growth but also build a new architecture which are faster, efficient and more secured across border to another country. In the report of World Payment Report (2016), the volume of global non-cash transaction have accelerated and growth by 10.1 % which up to USD426.3 billion in year 2015. Therefore, Fintech companies seized the opportunities by reaching their customers more easily and less initiative costs during engaging on mobile technology (Kiem, et al. 2016). Despite Fintech provided an exciting landscape to the community, however, there are challenges on whether Fintech’s products are fail to be trusted, fail to be secured or fail to comply to local regulatory framework. According to the survey of White & Case Fintech M&A (2016), 59% do not think that Fintech subject to tighter regulations as this may stifle new innovative ideas (Kiem et al., 2016). In order to maintain financial and economy stability, financial sectors are well regulated by worldwide regulator (domestic and international regulator). In the existing regulatory frameworks are not structured and incompetent to supervise the rapid growth in Fintech industries [ Kiem et al. (2016)]. The government’s support is the key growth in Fintech industry which are contributing by the entry barriers, funding, infrastructure and regulatory support. In the US, there is complex regulator and state-level structure to oversee the financial services provider, hence created entry barrier to Fintech companies where UK has more friendly regulation to welcome Fintech start-up (Desai 2015). As Fintech promises to provide better customer experience, the Fintech companies must consider on how to use the regulation for advantage their further growth and development. Therefore, the regulatory have crucial responsibility to ensure the customers are protected. For an instance of international body, New York’s Financial Stability Board (“FSB”) has been requested from national authorities to assess a supervisory and regulation framework on the cyber risk issue of Fintech from financial stability perspective such as concern on the security of customer’s database being available to Fintech third party companies (Financial Stability Board 2017). On the other hand, there is no clear declaration from deposit insurance scheme if customers are refundable when hijacked by third party Fintech companies. Moreover, there are investment risk caused the lack of investor’s confident while there are case studies on fallen of POWA TAG, a UK mobile payments companies as well as a high profile crowd funding company, ZANO (Cellan Jones 2016a, Cellan-Jones 2016b). Furthermore, different regulatory approaches across jurisdictions are also the challenges in Fintech. However, this may not be able to achieve due the existence of Cyber threats and Cyber risk. Therefore, the world financial service regulators such as United States and United Kingdom getting more involving as Cyber risk is the threat to financial operating activities (Deloitte & Touche LLP 2016). In the report, they also highlighted the cultures of Fintech companies are distinctly different from financial institutions. For example, regulators are more concerning on risk management framework and would prefer banks to maintain their relationship with their customers, hence transform more slowly while comparing to Fintech companies which operate their business in rapid growth of innovation. On the other hand, “big data analysis” is also the one of the new technology paradigm in Fintech industry. There are some of the studies revealed the challenges and technical issues on how big data could accelerates the developments of Fintech industries in near future (In 2017). In the section below, the recent developments of Fintech regulation will be conducted by selecting three countries who initiated in Fintech investment and regulations: China, Hong Kong and Singapore. Asian Institute of Research Journal of Economics and Business Vol.1, No.1, 2018

companies around the world such as Alibaba Group & Tencent, Paypal, M-PESA etc., the communities such as government, investors, entrepreneurs and consumers around the world started to grant attention to the Fintech services. The global investment in Fintech companies raised to USD3.2 billion in the first quarter year 2017 across 260 deals (KPMG International Cooperative 2017). Here's come with the question with collaboration or competition? While the developing countries has lack of chances deal with financial services, the only way to get them into financial inclusion is the infrastructures. There are believes in Fintech solutions could generate more options than banking options for poor infrastructures developing countries such as India and Pakistan (Kendall 2017). On the other hand,  also pointed that the offers from Fintech such as low cost driver and innovative uses of data could be a threat to the banks' revenues.
The collaboration between banks and Fintech companies is better off as banking sector could easier get customer acquisition with collaborate with the advanced technology offering from Fintech companies. There's no doubt on the traditional financial services are moving into digital era, banks and Fintech companies believe that financial technology is not only able to provide products opportunities growth but also build a new architecture which are faster, efficient and more secured across border to another country. In the report of World Payment Report (2016), the volume of global non-cash transaction have accelerated and growth by 10.1 % which up to USD426.3 billion in year 2015. Therefore, Fintech companies seized the opportunities by reaching their customers more easily and less initiative costs during engaging on mobile technology (Kiem, et al. 2016). Despite Fintech provided an exciting landscape to the community, however, there are challenges on whether Fintech's products are fail to be trusted, fail to be secured or fail to comply to local regulatory framework.
According to the survey of White & Case Fintech M&A (2016), 59% do not think that Fintech subject to tighter regulations as this may stifle new innovative ideas (Kiem et al., 2016). In order to maintain financial and economy stability, financial sectors are well regulated by worldwide regulator (domestic and international regulator). In the existing regulatory frameworks are not structured and incompetent to supervise the rapid growth in Fintech industries [ Kiem et al. (2016)]. The government's support is the key growth in Fintech industry which are contributing by the entry barriers, funding, infrastructure and regulatory support. In the US, there is complex regulator and state-level structure to oversee the financial services provider, hence created entry barrier to Fintech companies where UK has more friendly regulation to welcome Fintech start-up (Desai 2015). As Fintech promises to provide better customer experience, the Fintech companies must consider on how to use the regulation for advantage their further growth and development. Therefore, the regulatory have crucial responsibility to ensure the customers are protected. For an instance of international body, New York's Financial Stability Board ("FSB") has been requested from national authorities to assess a supervisory and regulation framework on the cyber risk issue of Fintech from financial stability perspective such as concern on the security of customer's database being available to Fintech third party companies (Financial Stability Board 2017). On the other hand, there is no clear declaration from deposit insurance scheme if customers are refundable when hijacked by third party Fintech companies. Moreover, there are investment risk caused the lack of investor's confident while there are case studies on fallen of POWA TAG, a UK mobile payments companies as well as a high profile crowd funding company, ZANO (Cellan Jones 2016a, Cellan-Jones 2016b).
Furthermore, different regulatory approaches across jurisdictions are also the challenges in Fintech. However, this may not be able to achieve due the existence of Cyber threats and Cyber risk. Therefore, the world financial service regulators such as United States and United Kingdom getting more involving as Cyber risk is the threat to financial operating activities (Deloitte & Touche LLP 2016). In the report, they also highlighted the cultures of Fintech companies are distinctly different from financial institutions. For example, regulators are more concerning on risk management framework and would prefer banks to maintain their relationship with their customers, hence transform more slowly while comparing to Fintech companies which operate their business in rapid growth of innovation. On the other hand, "big data analysis" is also the one of the new technology paradigm in Fintech industry. There are some of the studies revealed the challenges and technical issues on how big data could accelerates the developments of Fintech industries in near future ).
In the section below, the recent developments of Fintech regulation will be conducted by selecting three countries who initiated in Fintech investment and regulations: China, Hong Kong and Singapore.

CHINA
China, is the home of operating mobile payment and global Fintech services leader by recorded USD1.8 trillion in internet finance sector of the market size of country in year 2015 . Among the internet finance, third party payment ("TPP") is one of the well-known Fintech development in China, which also the core transformation of China's e-commerce industries (Miao and Jayakar 2016). According to EY survey report (The Rise of Fintech In China 2016), there are several factors contributing to disintermediation in China with the raising of digital connectivity. In an instance of Alibaba Group, which affiliated with Ant Financial and Tencent becomes global leader in Fintech industries with their TPP in e-commerce business. As a global Fintech player in the world, the central bank People's Bank of China ("PBC") has set up Fintech committee to study the impacts of financial technology on monetary policy, stability and clearing mechanisms in order to seek ways to mitigate the risks (Angier 2017). In the past, the financial services industries in China is highly state ownership and controls which had been nationalised under regulation of PBC (Yongwoon and Dong-Hee 2016). There are several largest Chinese Bank presence in China such as the Bank of China ("BOC"), the China Construction Bank ("CCB"), the Agricultural Bank of China ("ABC"), and the Industrial and Commercial Bank of China ("ICBC") owned by Chinese central government, which carry commercial banking operation (Kumaravadivel 2013). Nonetheless, the abovementioned China's banks are heavily regulated by the China Banking Regulatory Commission ("CBRC"), which established in 2003 and took over supervisory and regulatory framework from PBC.
In China's e-commerce service industries, Elinor and Xia (2011) stated that there are five regulator departments presence to oversee and focus on the growth of e-commerce industries which including PBC, the Ministry of Commerce ("MOFCOM"), the State Administration of Industry & Commerce ("SAIC"), the Ministry of Industry and Information Technology ("MIIT"), and the State Administration of Taxation ("SAT"). According to Yongwoon and Dong-Hee (2016), most of the Fintech companies which providing in TPP are unregulated before year 2010. Therefore, the Chinese government, PBC established a new regulation on granting payment license for those non-financial institutions (Fintech companies) to operate on TPP services (TransAsia Lawyers 2010). Under the new government regulatory regime published, PBC had brought 27 Fintech companies, which included Alibaba Group officially legalised on the TPP payment services through granted license.
Subsequently, Alibaba Group extended its finance business to Small-Medium Enterprise ("SME") lending segment through collaborate with financial institutions in China (Meng Jing 2014). Moreover, the risen of mobile phone payment increasing rapidly also boost the China's e-commerce business, which benefit TPP providers. However, the rapid growth of Fintech businesses in China caused the dilemma of banks (Yongwoon and Dong-Hee 2016). In year 2014, the Fintech industry in China is no longer restricted in TPP and mobile payment services, which reform the financial industries in China by allowing Fintech companies to set up private banking services such as investment platform by Tescent and fund lending services (Yongwoon and Dong-Hee 2016). As such, the Fintech companies grow strong and rapidly through government's supporting in the field innovations.
In the aggressive growth pace of China's Fintech industries, the regulator has established a series of regulatory framework to restrict the online services to maintain financial stability and country growth. For example, PBC and CBRC will be regulating online lending fund depository business; Equity-based crowdfunding and sales of financial products will go under regulation of the China Securities Regulatory Commission ("CSRC"); and online insurance will be going under regulation of the China Insurance Regulatory Commission ("CIRC") (Han Kun Law Offices 2015). Under the Guiding Opinions on Promoting the Healthy Development of Internet Finance ("the regulation"), China regulatory created a more focus regulatory approach transparency since year 2015 (Jiamin 2015).
In China, there are financial inclusions through internet based services as aforementioned. Due to Fintech services booming in China in the recent several years, the regulator has endeavoured the potential risks in the disruptors. The authorities in China have established a series of guideline in order to promoting healthy development of internet finance (Jiamin 2015). Under the new regulation, all the non-bank account would be required to use real name for registration in order to classify the services provider according to security levels (Barbara 2015). Moreover, the online payment limited the amount in range of RMB1,000 to RMB200,000 in a year. Meanwhile, the regulations don't apply to those transactions which make through banking online payment platforms as banking sector in China is strictly guided by the authorities (The State Council -The People's Republic of China 2015). The new regulation issued in online payment mainly for avoid the large amounts of fund transfer to third party account as beyond of insurance deposit scheme if any fraud as well as to comply with Anti Money Laundering framework.
As China differentiated with rural and urban are in the country, most of the rural areas have difficulties to have financial inclusion and hence lack of chances to contact with traditional financial services. P2P always linked to one term of financial awareness called as "Shadow Banking". In year 2013, there are survey report on 65% respondents agreed on the "Shadow Banking" would generate another crisis in China (Caixin Survey 2013). In an instance of high profile scandal of internet lender Ezubo alleged defrauded USD7.6 million from 900,000 peoples, which exposed the biggest Ponzi scheme (Bloomberg 2016). On the other hand, there is reported of 1,263 out of 3,853 Chinese P2P lenders were having financial difficulties and 266 P2P lender fled away in year 2015 (The Economist 2016). As such, Chinese government has finalised a series of rules and regulation to tighten the P2P lending platform in year 2016. Shen Wei (2015) conducted an investigation on potential risk in China's P2P lending platform and suggested options to regulator to tackle the issues in earlier year. After the P2P tighten regulation been released on 24 August 2016, there are expected more than 2,400 lending platform has been which doesn't comply with new regulations (Reuters 2016). Under the new rules, the regulator seems turning P2P into supplement of banking industries where risk compliance applies (Weinland, Don;. For an instance, P2P companies are restricted to sell management products and issue asset-backed security. Also, those Fintech companies who providing P2P services will be limiting to have third party custodian to manage the funds (Reuters 2016). In order to ensure the P2P lending platform in China remain transparency, the Chinese government also set up the National Internet Finance Association, which run by PBOC to oversee the risk in sector as well as supervise Fintech companies in China (QuanLin 2016). Among the new regulations imposed, there are credit limits cap on individual of RMB200,000 and RMB1,000,000 on lending companies (Lockett 2017). In the result of new regulation applied, there is reported the P2P growth rate in China slows amid which consequence nearly half dropped in the transaction in year 2016 (Xueqing 2017). Nonetheless, there are still the risk exists despite the new regulations imposed such as no capital requirement to start up the lending services and do not need to be licensed (China Banking Regulatory Commission 2017). "The P2P business are not strictly regulated, but the regulator is taking step forward," Xu Hongwei says (Bloomberg 2016).
Equity crowdfunding is referring to a financing method which raise fund from public to offer equity as investment thorough internet technology. Belleframme et al. (2015) described the types of crowdfunding platform in the sectors and the challenges. On the other hand, there are potential risks involved money laundering and fraud etc. (Shen Wei 2015). The Chinese regulator came up regulations to tackle the issues. For examples, a qualified individual investor must able to meet one of the following criteria: invest at least RMB1 million in a single project; obtaining net assets of RMB10 million or RMB3 million net worth with average annual income of RMB500, 000 over the past 3 years (Andrew 2015). Moreover, there are also the regulations on the requirements of setting up crowdfunding platform and the platform doesn't allow offering P2P lending services at the same time. Meanwhile, the sales of financial products through online, there is no any specific regulation but Chinese government encouraged the collaboration between banks and Fintech companies to deliver their services to customers (Nicholas 2015). In order to tackle the possible illegal activity, the Chinese regulatory are still working on specific regulatory which believe there are more specific requirement to be published soon (Erdenebileg 2016).
Although China's financial services heavily regulated by multiple of Chinese regulator, but there are still lack of specific supervision and guideline in coordinate scheme. In China, MIIT and CIRC are in charge of supervision and regulatory work of online insurance. Following by the rapid growth of online platform such as offering financial products and online insurance, CIRC has issued an interim measure in supervisory of online insurance business (Martin 2015). Under the interim measure report, the insurance institutions may not need to have physical presence but have to fulfil the insurance service requirement (Middle East Insurance Review 2015). Furthermore, the insurance products also have been limited to offer to public through online insurance business.

HONG KONG
Hong Kong has the honour of leading financial centres with its unique location in the heart of Asia Pacific region. Although Singapore have been widely recognised as leading premier Fintech hub in Asia currently but Hong Kong has confident to catch up the progress (Bermingham 2017). In past several years, Hong Kong has been working on Fintech landscape to accelerate the industry in order to become Fintech hub in Asia Pacific region (Barberis 2014). As China's mainland financial centre, Hong Kong also the largest offshore financial centre, which ideal financial service centre for asset management and capital formation centre. Although there are USD300 million invested in Fintech industries but the regulations are restricted the Fintech innovations (Strait Times 2016). Indeed, Hong Kong financial services are strictly regulated by the authority, which this explained Hong Kong is world's leading financial centre. However, Hong Kong is urged to focus on establishing their payment technology and cybersecurity in order to compete with its international rivals (Barreto 2017 (Weiting 2016). As Fintech growth rapidly in the recent year, therefore there are recent concern raise from the Hong Kong authority such as distribution ledger technology ("Blockchain"). HKMA believe the new technology -Blockchain could have potential money laundering potential risk (The Business Times 2016). As such full of uncertainty in the process of financial innovation, Hong Kong government has been urged to establish Fintech office to better address on issue of regulatory and risk management areas (Zen 2017).
Following by China has strong presence of digital payment system but not been regulated in past several years, HKMA has established online payment of stored value facilities ("SVF") and retail payment system ("RPS") in year 2014 (Securities and Futures Commission 2014). The following regime of SVF and RP are amended from consultation paper 2013 (Securities and Futures Commission 2013). Hong Kong Lawyer (2015) has pointed the consultation paper in year 2013 received the criticism from respondents due to different on competitive advantages between non-bank entities and banking industries and some of requirements issues. However, the new regime has been finalised and followed by a number of respondents. For an instance the well-known smart card payment company, Octopus, who are authorised by HKMA as deposit taking company to operate multipurpose SVF. Under the new regulation, SVF operator must be able to fulfil the requirements such as licensing, capital requirements, business plan and maximum store value of different SVF (Securities and Futures Commission 2014). However, for RPS regulation, there are no specific criteria currently as long as there is no impact to the public confidence, financial stability and public confidence day-to-day commercial activities.
Due to lesson learned from global financial crisis in 2008, HKMA has strictly restricted bank and deposit taking companies to approve loan application. As result, there is increasing of non-bank money lender over the year due to easier obtain the mortgage loan from market in borrowers' point of view (HKEXnews 2013). According to the report, there is approximately HKD30.5 billion of market scale of money lenders and HKD6.6 billion in mortgage market in year 2013. Following by the rapid growth of financial technology, P2P platform could be easier to access the market place by providing lower interest rate. Although the money lenders in Hong Kong are regulated by Companies Registry by license issuing (Companies Registry 2016), however, there are reported of increasing of illegal loans (Nikki 2016). According to the Legislative Council (2016), there are the cases on how borrowers are being induced to apply for loan and high fees applies in the process, which is prohibited form current regime. In order to maintain financial stability and health economy in Hong Kong, the Legislative Council urged the government to impose more stringent regulation to restrict P2P service platforms (Legislative Council 2017).
The crowdfunding services is considered a new field in Hong Kong. In year 2015, the SFC had issued a notice in relation of crowdfunding (Secrities and Futures Commission 2014). Under the notices, there are the series of risks and types of crowdfunding are imposed to the existing regulatory regime. Currently, there are no specific regulations on equity crowdfunding and sales of financial products. However, for those companies who want to operate in equity crowdfunding must able to fulfil the requirements under Securities and Futures Ordinance Act and the Companies Winding Up and Miscellaneous Provisions Ordinance Act. In order to better address the crowding issues, the Financial Services Development Council has released a proposal on the regulatory framework for equity crowding funding in 2016 (FInancial Services Development Council 2016). However, the proposal is still under discussion on the execution.
The insurance business in Hong Kong are fall under Insurance Companies Ordinance currently. There was a report of the current authority OCI to be replaced by new regulatory body -Independent Insurance Authority ("AII") to supervise the insurance companies and regulation in Hong Kong (Norton Rose Fulbright 2010). There is a report shown that wearable devices in Hong Kong, which enabled the insurer able to accumulate information of customers' behaviour (Computer World 2016). However, there are concerns on the data privacy and technology risks raised when dealing with internet based of insurance services. To overcome such risk, the OCI has issued "Guidance Note on the Use of Internet for Insurance Activities" in year 2001 to minimise the risk exposure (Office of the Commissioner of Insurance, Guidance Note On The Use of Internet for Insurance Activities 2001). Under the guideline, the insurance provider must obtain the advanced Internet security technologies.

SINGAPORE
Singapore, which is a country pushing itself into invention of Fintech industries and aim to be Asian Fintech Hub. The central bank, Monetary Authority of Singapore ("MAS") continued to lead and support Fintech activities in the country among Asia following by Hong Kong (Strait Times 2016). Singapore has been more aggressive in pursuing Fintech investment over the past years, however, Singapore faced the immigration law on giving priorities to local Singaporean, which created an obstacle to foreign talents in the Fintech Industries. In an instance of Singaporean complaint on the foreigner taking of their job opportunity in the country, the authority Ministry of Manpower ("MOM") has working in tighten the criteria of foreign employment over the years (Startup Decisions 2016). Moreover, Singapore as an offshore private financial centre also exposed to the risk from the threaten by multibillion dollars' money laundering scandal from its neighbourhood country as well as tax amnesty to recall the funds from low tax rate countries. In view of Fintech businesses such as Airbnb and Uber etc. growth rapidly over the island, Singapore foresee that uncertainty and risks when Fintech industries are not being regulated.
In Singapore, there are several authorities overseeing and regulating the regime. The major regulators in Singapore of course is the Monetary Authority of Singapore (MAS) who supervising financial institutions which including insurance companies, capital markets intermediation, financial markets infrastructure and money lenders. The other regulator involved in Fintech industry such as the Info-Communications Media Development Authority of Singapore ("IMDA") in charge the regulations of information and communication media sectors and taking over the responsibility of personal data protection after merging of the Infocomm Development Authority of Singapore ("IDA") and the Media Development Authority of Singapore ("MDA") in year 2016 (Strait Times, Singapore's media and infocomm authorities IDA and MDA will merge to form IMDA 2016).
As Singapore aiming to be promoted as Fintech Hub, MAS and National Reserve Foundation ("NRF") has established Fintech office as one-stop service department to serve all the matters related to Fintech (Monetary Authority of Singapore 2016). Further in the budget 2017, Singapore introduced the "SMEs go digital Programme" in order to strengthen their core business economies to integrate with digital economy (Ministry of Finance 2017). Under the programme, there are SGD80 million set aside to help the local SMEs to adopt the digital solutions.
Moreover, there is regulatory framework established in recent year to support and encourage the Fintech innovation, the central bank has issued Fintech regulatory sandbox to supervise and ensure the innovative product comply to the financial requirements in year 2016 (Monetary Authority of Singapore, MAS FinTech Regulatory Sandbox 2017). Under the sandbox regulatory environment, MAS aims the financial innovation products could increase efficiency, manage risk better, open up new opportunities as well as improve lifestyle of Singaporeans (Monetary Authority of Singapore 2016). To tackle the uncertainty over innovation process yet not to stifle the opportunity on testing new technology, MAS allowed the Fintech products supported by more relaxing regulations and compliances. For example, the sandbox entities are provided 6 months to define the experiment is not replicated in the market scale. Upon a series of evaluation requirements, the sandbox entity must fully comply with the relevant regulatory requirements (Monetary Authority of Singapore 2017). In order to have better experiment space for the Fintech innovative products, Singapore regulatory also emphasises in the framework of enabling the growth and innovation for Fintech companies (Ministry of Finance 2017).
MAS collaborated with international financial bodies to come up a series of Fintech landscape. For an instance, MAS collaborated with International Financial Corporation ("IFC") to establish Asean Financial Innovation Network ("Afin") which focus on the standardizing compliance duties, cross border connectivity, increase financial inclusion and remove some inappropriate national restrictions over Fintech industries (Ainger 2017).Following by the increase of cashless payment linked through advanced digital devices in the past several years, MAS aimed to cashless countries in the future (Hardasmalani 2016). According to KPMG report (2016), there are several of e-payment platforms which promote faster and convenient to the consumers. As Singapore aware that online settlement is the main component in Fintech industries in the future, hence, MAS issued new regulatory on payment framework and established National Payment Council (Monetay Authority of Singapore 2016). Under the new regulation, MAS able to better envisage and address the issues on e-payment ecosystem regulation such as accessibility, customer data protection and corporate governance. Moreover, the regulatory framework helps the authority to have better understanding on risks and risk management such as cyber security risk, technology risk, money-laundering and terrorism financing risk. In Singapore, there are also the presence of regulation on SVF (Monetary Authority of Singapore, Stored Value Facility Guidelines 2006). For wide accepted SVF such as EZ-Link and NETS, the holders required an approval from MAS if the aggregate amount more than SGD30 million. Despite there are no licensing and capital base requirement as Hong Kong as aforementioned, but the regulatory framework still have restrictions guideline to prevent money laundering.
In Singapore, there are many P2P platforms such as MoolahSense and Validus who lending money to SMEs and investors. The P2P lending platform is strictly regulated by Securities and Futures Act and Financial Advisers Act in Singapore. The lender and borrower subjected to a series of lending and borrowing requirements (Monetary Authority of Singapore 2016). Moreover, the operator of P2P lending services must obtain Capital Market Services license issued by MAS. Under the regulation, there is a statement stated that the P2P lending businesses which used promissory notes to issue to borrower previously need to be licensed for their further lending business services. Under the Fintech activities which involved in money lending is guided by the Moneylender Acts.
Crowdfunding or online crowdfunding platform considered is a new phenomenon in Singapore in recent year. For an instance, the reward based crowdfunding and donation based crowdfunding. In order to support and encourage SMEs business start-up in Singapore, the central bank announced the regulatory framework for security based crowdfunding in 2016 (Monetary Authority of Singapore 2016).
Under the regulation (essentially are Securities and Futures Act and Financial Advisers Act), the company who wants to offer its shares through crowdfunding platform has required to register with MAS (Monetary Authority of Singapore 2016). Moreover, there are two ways for SMEs access into equity-crowdfunding platforms. First, MAS will make this platform rely on current regulatory framework with "small offer" for those SMEs who wish to raise their fund less than SGD5 million within 12 months from retail investors. The another way is accredited institution and investors will be required a base capital requirement to start up their business at least SGD50,000 which reduced from SGD250,000 previously (Monetary Authority of Singapore 2016). On the other hand, the firm who duel with retail investors have to apply for Capital Market Services license and minimum capital of SGD500,000 to set aside before business operation (Yahya 2016).
In Singapore, all the activities which involving in insurance businesses, foreign insurer or insurance intermediaries are subjected to regulate by Insurance Act (Singapore Statues Online 2015). For those insurance intermediaries would like to start up their business through internet service based must be able to comply with the Insurance Act and doesn't breach any terms in existing license condition. In order to have better supervision the risk during innovation process and support the online based insurance services, MAS has urged the insurance intermediaries to avail themselves in Regulatory sandbox (Monetary Authority of Singapore 2017). For overseas registered insurance provider subjected to seek for MAS's approval before operating domestic business in Singapore (Monetary Authority of Singapre 2016). This action had provided the unregistered insurer places the customer at risk.

DISCUSSIONS
An integration of financial and technology have become a popular topic and exciting areas for exploration in the recent year. From the literature review, there are proactive investment made in Fintech industries around the world, according to the report of KPMG (KPMG International Cooperative 2017). However, the business challenges and issues are still bugging the start-up of the Fintech industries which including the regulatory framework and entry barriers. Due to the world had been changed to digital ecosystem and the changes of business model over the business industries, the regulatory framework have become more challenges as the current legislative is ill-equipped (Kiem, et al. 2016). The challenges could be more wide range over the uncertainty in Fintech industry such as data privacy protection and cyber security (Shen Wei 2015). Positively, the regulatory around the world had been working very hard to understanding the risks could be aroused in the industries and findings solutions to mitigate the risks.
China is the global Fintech player in the early century but the regulations are too lax (Yongwoon and Dong-Hee 2016). In view of China's internet finance activities proactive in year 2014, as well as the high profiled scandal of Ezubo, PBC had been worked with others authorities on the regulation framework in year 2016. Compared to financial leading centre in Hong Kong and Singapore, HKMA and MAS had been working and amending the regulatory framework over the time. In most of the comparison areas, there are different of regulatory approach among the samples countries. For an instance, digital payment services in China required business operating license but no specific regulation SVF; while Hong Kong issued the new SVF regime in year 2014 to prevent money laundering through Multi-purpose SVF (Hong Kong Lawyer;. Under the regime, license and minimum capital of HKD25 million is required. In Singapore, there are no specific regulations in SVF but the holders subjected to approval if the holder has aggregate sum of SGD30 million. China has the biggest P2P lending platform and equity crowdfunding compared to Hong Kong and Singapore, according to the report of EY and DBS (Sachin and Lloyd 2016). Therefore, China has more specific regulations in term of licensing and minimum capital requirements for business operator. For Hong Kong, there is no specific regulations under P2P and equity crowdfunding services as this is considered a new phenomenon in the country. For Singapore, the capital market license is required for business operator but the requirements of base capital requirement reduced for institutional investors in order to fostering SMEs start-up. In insurance sector, China required insurance providers must have obtained insurance license but no license is required through if the sales of insurance third party platform. Although there is no specific regulation on overseas registered internet financial services, but Singapore still giving advises to investors who wants to invest through internet platform. For an instance, Singapore warned investors in unregulated platform of binary options trading platform (Nicole 2017). Going forward, Singapore would have more specific legislative framework for online financial services.
As Hong Kong and Singapore in the competition to become Fintech Hub in Asia, there will be more regulatory framework to be issued in near future. For an instance, the regulatory sandbox published in Hong Kong and Singapore to supervise the innovative process in order to mitigate the risks before enter into large scale market. In the comparison of the regulatory sandbox between Hong Kong and Singapore, the purpose is the same approach to mitigate the possible risks but there are different views in the innovative process. For an instance, HKMA has no intention to relax the possible regulation but MAS do. Moreover, there has no details on HKMA's supervisory sandbox but MAS had given all the details for the application and evaluation process. However, the capital is required for the start-up Fintech activities in the competition of Fintech hub. According to a report conducted by KPMG (Fintech in India -The Global Growth Story 2016), Singapore has higher government incentives and funding in Fintech start-up compared to Hong Kong. Although Singapore has lead in front of Hong Kong currently but Hong Kong has confident to catch up with the trend.