superior customer service. The current unbundling of financial products has created a fragmented landscape that is expected to gradually shift towards trusted, centralized and digitally-enabled
financial services platforms. The following principles have an imperative role in building the banks of the future:
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Best-in-class customer experience is
digital and requires continuous investment in innovative technologies: mobile banking has succeeded in providing greater flexibility for customers to bank at home, at work or while socializing, in enhancing the financial awareness of its users
and in retaining the client base due to user experience.
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Rich data enables more personalized customer experience: customer experience is expected to overtake price and
product as the key brand differentiator in the near future. In addition to being more likely to do business with a company that offers a personalized experience, consumers expect companies to anticipate their needs and make relevant suggestions
before first contact and will not have issues with sharing personal data in exchange for that.
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Security, exceptional customer service and transparency strengthen trustworthy relationships: trust surpasses
convenience, reliability, value and time as the key attribute in the decision to adopt innovative payment and banking solutions, thus being indispensable when acquiring and retaining customers at scale. It is critical to secure the vast amounts of
data and the consumers digital identity, and to constantly delight customers, while receiving high net promoter scores, engagement and retention in return. Equally important is companies ability to convincingly communicate their added
value, align the timeline of consumer costs and value received and emphasize the many steps taken, special assets used, time saved and complexity eliminated throughout the customer journey.
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Regulation of the Payments Industry in Brazil
Our activities in Brazil are subject to Brazilian laws and regulations relating to payments industry. Law No. 12,865/2013, which
took effect on October 9, 2013, sets forth the first set of rules regulating the payments industry within the overall Brazilian Payment System (the Sistema de Pagamentos Brasileiro, or SPB), which refers to all the entities, systems
and procedures related to the clearing and settlement of funds transfer, including operations in foreign currency in Brazil. This law created the concepts of payment schemes (arranjos de pagamento), payment scheme owners (instituidores de arranjos
de pagamento) and payment institutions (instituições de pagamento).
Law No. 12,865/2013 gave the Central Bank
and the CMN powers to regulate entities involved in the payments industry, including those operating in digital environments. These powers cover matters such as the incorporation and operation of these entities, risk management, the opening and
managing of payment accounts, and the transfer of funds to and from payment accounts. After enactment of Law No. 12,865/2013, the CMN and the Central Bank created a regulatory framework regulating the operation of payment schemes and payment
institutions. Currently, the main rules of this framework consist of Resolution No. 4,282/2013, Resolution No. 4,283/2013, Circular No. 3,680/2013, Circular No. 3,681/2013, Circular No. 3,682/2013, Circular
No. 3,704/2014, Circular No. 3,705/2014, Circular No. 3,721/2014, Circular No. 3,735/2014, Circular No. 3,765/2015, Circular No. 3,815/2016, Circular No. 3,842/2017, Circular No. 3,843/2017, Circular
No. 3,854/2017, Circular No. 3,885/2018 and Circular No. 3,886/2018, among others.
Circular Nos. 3,885/2018,
3,886/2018 and 3,887/2018, all issued on March 26, 2018, introduced several changes relevant to the payment schemes and payment institutions. Such measures include, among others: (i) revocation of Circular No. 3,683/2013 and
introduction of a simplified process for the licensing of payment institutions by the Central Bank, including exemption to apply for a license for payment institutions operating below a certain volume of payment transactions
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