The types of entities that may be affected include consumer finance companies, mortgage originators and servicers, installment lenders, marketplace lenders and alternative investment managers and funds, among others. Many regulators are balancing their risk oversight responsibilities with ensuring the availability of credit to consumers and commercial enterprises. Shadow banks broadly perform credit intermediation outside of the traditional banking framework, sometimes filling voids banks are unwilling or unable to fill.
Fitch expects traditional banks to continue their collaborative approach with shadow banks, at least in the near term, partnering with or lending to them, as a means of participating in their success and gaining technological and strategic intelligence. While this facilitates the growth of a competitor, it allows traditional banks to participate in a potential growth opportunity without attracting the same levels of typical regulatory scrutiny. These partnerships could also provide traditional banks with valuable intelligence on the evolving "fintech" landscape, which could inform their competitive responses over the longer term.
Fitch also thinks that banks will lobby for increased regulation of shadow banks, either overtly or discreetly, based on their growing size, interconnectedness and, in certain instances, consumer-facing nature. This would be a relatively basic way for banks to potentially chip away at shadow banks' competitive advantages.
With or without the prodding of banks, Fitch expects regulators to continue to sharpen their focus on shadow banking in 2016, if for no other reason than that shadow banks are increasingly large, rapidly growing and demonstrate less transparency than their bank peers, all of which are historical red flags for potential systemic risk.
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