Disclaimer: I'm seriously considering investing in this. There was a very good talk about their back end infrastructure at NDC London that makes me confident in their tech chops. Some of the value add concepts on their website look really useful for attracting customers.
Crucially I'm aware of just how much legacy cruft is holding back more established retail banks. In the same way that things like newer airlines can offer much better customer service at cheaper rates than the established competition Mondo seems to have real potential to disrupt and innovate. Plus there is a still a significant anti-banker mood where being a retail only operation could be of significant benefit.
Finally banking has a pretty high barrier to entry, Mondo seems to have the backing and management experience to get a licence. However it isn't something that loads of Uber for X types or Samwer-esque clones can spring up overnight.
> Plus there is a still a significant anti-banker mood where being a retail only operation could be of significant benefit.
If they are operating as a retail bank they will have the same regulatory constraints. I recall a previous attempt to create a bank was dropped after a basic set up of the legal framework to meet the regulatory requirments was estimated at £50million
To encourage competition in the space, the UK recently reduced certain capital requirements in relation to banking start-ups, compared to established banks. This article has some good background:
> However it isn't something that loads of Uber for X types or Samwer-esque clones can spring up overnight.
they are springing up overnight, there's already 5 or so in the same exact category (Atom, Starling come directly to mind).
the first few are taking on all the risk, once it's seen that the FCA will approve a project like this then you'll get a load more springing up overnight
To me this seems like an opportunity to skip the waiting line of 30,000 people for a payment of £10. In terms of the investment opportunity, it seems that - like most of CrowdCube investments - it is hard to tell if and how this could turn into anything profitable:
>We estimate we’ll raise another £10m to launch as a bank in Q4 2016, although this may vary,
and further capital raises will be necessary as the bank expands its balance sheet
E.g. in further investment rounds could the crowd investors be able to sell of their shares? Do we even get shares for this investment? I will probably invest, and probably a small amount, to understand more on how this crowd funding really works (and to see if I can get a return in the next 10 years).
It's unclear from the blog, but will Mondo be using Crowdcube's A/B shares?
A lot of Crowdcube investments issue two types of share depending on the investment size. At the higher end the A shares are regular shares, but smaller investors usually get B shares that are not equal and grant fewer rights.
The very simple question for Mondo, are all of the shares that you'll be offering via Crowdcube on the same terms as the shares that Passion have for their GBP 5m in the same round?
[I work at Mondo!] Investment will be at the same valuation as our VC investor - £24m pre-money.
We'll be releasing details of terms & share-class next week before the investment goes live. There are a few regulatory questions we need to settle first.
Right now it's backed by some prepaid card provider. Once they get a banking license, bank accounts will be protected under government regulations, so afaik as secure as any other UK bank.
Specifically UK bank deposits are protected up to £75,000 under the Financial Services Compensation Scheme. If you've got so much money that you have > £75k in a single bank for any length of time (house purchase etc aside) then you have a different order of problems.
I work at Mondo. We will be a member of the Financial Services Compensation Scheme (FSCS) and all customer deposits will be insured up to £75k per person.
During our current alpha test (and before we have a banking license), your funds are actually held by our partner bank Wirecard.
Edit: The internet beat me to it. My work here is done :)
This answer doesn't say anything about being better. Or even different. If someone asks the question "What are the risks of using this service?" and the response is "Here's the legal minimum we have to do" then that doesn't really fill me with confidence that you're trying to be better than my current bank.
That isn't to say you won't be better. Maybe you will be. It's just that your answer here gives no indication.
that legislation also only covers insolvency, what about IT failures (operational risk)?
what if your system messes up and a load of my payments suddenly disappear? or your IT staff didn't completely understand how, say Cassandra treats transactions?
As usual with these things: What about app/server security. Simple token verification is prone to abuse (malware) and spoofing is becoming a bigger issue on mobile only platforms than ever before.
Server abuse is difficult, but not impossible and since getting a banking licence usually does not verify any security measures, I'm wondering what they already did (or didn't) do.
(I'm well aware of the state-of-the-art, and the usual less than so, security of banking apps).
I wonder why you got downvoted for this, for me security is a key concern for the challenger banks.
What Mondo is (from my reading) trying to do is very cool but quite ambitious. A new bank in 2016 will be a serious target for quite sophisticated attackers so they're going to have to do app/inf/ops security very well do avoid damage.
On the flip-side they have the once in a lifetime golden opportunity of a green-field deployment to actually get security baked into their systems before they're live without a load of legacy cruft holding them back.
I would really like to get an account but don't live in the UK unfortunately.
They talk about the card revocation/freeze in the app in the talk posted earlier, which is a really nice idea (next to the metadata collection).
The reason most 'normal' banks have limitations on their apps is that either they will not (or can not) guarantee the safety of their apps or want to place the responsibility at the users end. This means the limits in place (usually ~750/1000 euros max per day/week on mobile platforms) are there to make sure they won't loose too much money if people start saying "I didn't make that transfer". Banks pay out anyway (at least here in the Netherlands) because the customer dissatisfaction is of greater importance than actual tracing the problem of either a hack, an abusive spouse or simply mistyping the IBAN number. Since they collect a huge amount of metadata, this problem gets easier but won't be eliminated and can be managed by good app security and user informing the user.
This limitation is the same for card revocation (not freezing, that has other issues; namely concurrency).
I do hope they get a group of 'non HN people' to test it out, as they are more likely to get into the 'I didn't make that transfer' problem.
The problem with freezing cards is that transfers are not direct: freezing the card on the banks end might work, but some ATMs or other systems might have a sufficient delay to allow (some) abuse while the card was 'frozen' by the user. The question will be who will pay for the delay.
I definitely will support these ideas as they stir up a broken market, but please make sure you have you proof-of-possession and concurrency issues well sorted out.
Yep the customer fraud guarantee is a thing in the UK as well (at the moment), and to an extent that minimizes the loss where it's one customer's app. that gets compromised.
Where I was thinking that a lot of their security challenges will lie is things like internal money processing systems. An attacker with access to a bank's internal systems could make a right mess of things...
> The problem with freezing cards is that transfers are not direct: freezing the card on the banks end might work, but some ATMs or other systems might have a sufficient delay to allow (some) abuse while the card was 'frozen' by the user. The question will be who will pay for the delay.
This is part of why their cards are online-only, every* transaction has to be verified with them before it can complete at the reader - so transactions are slower, but there is no grace period after the freeze.
* as I understand it, certain merchants are white-listed on-card for offline transactions - namely TfL.
[I work at Mondo] You raise a good point, indeed. Security is something we take very seriously. As others have stated already on this thread, groups that target banks are incredibly sophisticated and well capitalised. All other banks face the same issues, of course, but unlike them we can't afford to simply write off losses to cybercrime.
We see Mondo as an opportunity to build a great security culture from the ground up. We're currently hiring a Head of Security role in London: https://getmondo.co.uk/careers
If you know anyone that
- is an excellent communicator
- likes to code and does so regularly
- can think like a black hat (CVEs and PoCs please!)
- doesn't mind writing the occasional policy document
please send them my way: jonas@getmondo.co.uk
BTW, at the moment we are not holding customer balances or approving transactions so we're not a particularly juicy target, yet. That said, we've already conducted pen tests and invited a number of security firms to come and break our software :)
FWIW, I saw that ad. Looks very interesting, but I think you may have a challenge getting someone who is a Vuln researcher/pen tester type (who most commonly have CVEs, PoCs to their name) who also has a decent knowledge of banking security, policies etc and also is looking to graduate out of technical work into team management...
Most of the pentesters/vuln researchers I know aren't huge fans of writing ISO2700x style policies documents (actually thinking about it there aren't many people who are fans of that kind of thing!)
I'd rather hire a CISO that understands security and teach them how to think like a regulator than vice versa! Heck, I have long hair myself and didn't have any contact with policy documents until just over a year ago. And both our CTO and CEO like to write code.
Basically, we're looking for our Alex Stamos. Any more ideas you have how we might find somebody like that and avoid the stigma of the "Bank CISO" job would be much appreciated.
[rant mode]
From personal experience I can say that true crypto knowledge is not needed as a Bank CISO. Just keep repeating 'hardware token only, hardware token only' and everyone will trust you opinion at the expense customer experience and true security. The reason that most banks use the identifier+card method is because they don't want to change. (or don't see the benefit of an improved customer journey without actual loss of security and improved/lowered cost)
[/rant mode]
>at the expense customer experience and true security
I always call this "lazy security"[1] and it's what you get when you hire some security professionals to "make it secure". It's a mistake to separate security from product design, the two should inform each other to come up with a compelling product that remains secure. Separating them misaligns interests, the security team will push for a change that improves security irrespective of any impact it may have on user experience.
I think Touch ID is a great example of how a novel solution can improve both security and usability.
At Mondo we are committed to investing time and energy into finding these solutions, security at the expense of user experience is a last resort.
I have to comment on touch ID: Biometrics are in no way an authoritative option for the simple fact that they cannot be replaced. You can identify the user with it, sure. But you should never use them to authorize anything because if stolen or compromised, the user cannot change it. While you might say the scanner + data storage is secure, this is just temporal and can change over time. As revocation of the biometrics is identical to revoking the user, this is to be avoided for authorizing transactions.
You can, however, identify the user with something like biometrics, and afterwards request an authorization of the transaction with something else (possession of key (good), +pin (better), or easiest a simple 'yes'(less than good)).
well whilst hardware tokens are not always the right answer, there are good reasons to resist their replacement with things like "SMS 2FA" which isn't really 2FA at all ,as you have no control over the receiving device, leading to it becoming 1+1FA in a lot of circumstances (e.g. apple continuity, skype account etc)
I've actually been disappointed to see the opposite (companies moving away from providing hardware 2FA) as other options are perceived as cheaper, despite potential weaknesses in the security model.
Very interesting. As far as Mondo goes, it's great so far - am on the alpha program and have been using it for almost a month now and very impressed by it. Using it abroad was the main selling point, as that's always a mess otherwise.
Basically how banking should be in a modern day and age, even though it's only with a prepaid debit card at the moment.
Can you or anyone else using the alpha give a bit more detail about what you love about it?
How is the app compared to say Barclays or some other mainstream bank? Is everything via the app rather than the website?
They have an API I think which is pretty cool for a bank, and I'm seriously interested. Disappointed to hear they won't be doing business accounts too, but I guess they want to stay focussed for now.
Using a debit card just seems like throwing away what should easily be 1%+ in terms of possible rewards value by using a credit card instead? Not to mention stronger protections.
On the other hand though (at least in my experience in the UK) there are still retailers such as airlines/hotels/transport companies that will penalise you for using a credit card.
I've even seen in small shops signs that say they only accept debit cards.
On the other hand most UK current accounts at the moment are giving decent rates on balances (my bank gives me 3% on balances between £3000-£20,000 as well as direct debit cashback on bills and utilities).
The fact that Mondo does not yet currently have a banking license in the UK is a big risk. If you're thinking of investing consider the value of that investment should the licence application fail.
It is unlikely to fail irrevocably because, as some of the background articles explain, there is evidence that UK regulators are actively trying to foster competition at the moment, "the Prudential Regulation Authority’s fast-track licensing regime"[0], partly in response to past abuse of trust by the incumbents. I was impressed with UK response to recent crises, issuing reports detailing very concrete measures to resolve institutional problems. As so much of the UK economy relies upon finance, they do have a bit of a reputation to uphold and cannot simply say one thing and do another indefinitely. At some point they have to give... it's a license, not exactly Elgin's marbles.
The value will drop to almost zero, which is all part of the fun. The opposite scenario will see a large increase in value. The game, as ever, is assessing the probability of these events and judging the value (or lack thereof) of the bet.
Like any bank we will have an anti-fraud engine that proactively declines transactions that have a high risk of fraud. We are going to work very hard to ensure the false positive rate is very low.
That being said, the system will never be perfect and I'm sure you can appreciate that it may be common for fraudsters to purchase bitcoin which could cause some legitimate transactions get blocked.
If you have any questions feel free to email me daniel@getmondo.co.uk
>We aren’t a bank yet, but we are applying to the Prudential Regulation Authority (PRA)
and Financial Conduct Authority (FCA) for authorisation to become one.
I don't want to be negative, but this is a huge consideration.
After 2008, unfortunately, regulations have made it much more difficult to incorporate a bank and comply with the law. Is a million enough for that?
>After 2008, unfortunately, regulations have made it much more difficult to incorporate a bank
The capital requirements to launch a bank have actually been relaxed since the financial crash. The government wants more competition in the industry and the regulator has been working to make that happen.
Other way round. UK have regulators have realised there is a lack of competition in banking arena and have made it much easier to start new banks. Several challenger banks have already received their licenses under the new rules
With Simple, the banking services are provided by a third party bank, so Simple provides a usability layer on top of an existing bank's services.
With Mondo, they are looking to actually become a bank.
So on a usability level, you may not actually see much difference, but on another, it would seem like Mondo are fundamentally different as they will have a level of flexibility to decide which banking services to provide to customers. Although that's not so say that Simple couldn't use third party services, they may not have the same level of independence which Mondo wants/will have.
Simple were quite different, they weren't actually a bank, they were essentially a nice front-end on an existing bank (from a regulatory perspective), and onto traditional banking software (from a tech perspective). The Mondo pitch deck available on their investor page explains some of these differences.
I'm really excited about this. I can understand why they've started with iOS, but I've not been able to find anything about their plans for Android, which is a bit disappointing.
I wouldn't give my bank credentials fora 3rd party app. Even if you forgo trust, what happens when something goes wrong and the bank doesn't take responsibility for the 3rd party app?
At the very least it won't be nearly as bad as some of the existing 3rd party apps which need all of your credentials to work properly. Mondo uses OAuth and can just shut off the application really easily.
I know the whole 3rd party thing is a little dodgy sounding, but at the very least Mondo could end up taking on a good 3rd party one and making it an official app (like Reddit did)
I must admit i'm considering investing, depending on what other details are announced when they are announced.
What i'd really like to see is a London centric bank (or perhaps building society), one that understands the rental market and the ownership market. It's insane that people (myself) pay more to rent somewhere than to buy somewhere, yet are hamstrung by the fact that either they don't earn enough to afford to buy, or don't have a deposit to afford to buy.
I thought Metro Bank might be that, but i think they're more focussed on expanding outside of London.
Unfortunately I don't think I'm well read enough to give a proper answer.
However, the housing market in London is all over the place, and there isn't a bank that has a direct interest in helping people on to the housing ladder in London. I think if you had a London centric bank that understood the housing situation and it's customers needs well, you'd capture a great sample of the capital.
That was me ;) Atom's great until you save and goimports locks up the whole UI. Think that is the protobuf interface used by the client and server in our tracing tool, so handy having them all open! https://github.com/mondough/phosphor
I know, I used atom for a couple months until I found VSCode, it's lightning fast compared to Atom and has a great go plugin I contributed to a couple of times :)
Oh, and goimports/goreturns don't lock anything, and the editor even highlights their changes :)
I wanted to invest in Mondo when I first heard about it 6 months ago and was disappointed. This has brightened my day, I just wish I could use it in the US. I know it's coming, and I can't wait for the future.
69 comments
[ 2.2 ms ] story [ 142 ms ] threadCrucially I'm aware of just how much legacy cruft is holding back more established retail banks. In the same way that things like newer airlines can offer much better customer service at cheaper rates than the established competition Mondo seems to have real potential to disrupt and innovate. Plus there is a still a significant anti-banker mood where being a retail only operation could be of significant benefit.
Finally banking has a pretty high barrier to entry, Mondo seems to have the backing and management experience to get a licence. However it isn't something that loads of Uber for X types or Samwer-esque clones can spring up overnight.
If they are operating as a retail bank they will have the same regulatory constraints. I recall a previous attempt to create a bank was dropped after a basic set up of the legal framework to meet the regulatory requirments was estimated at £50million
http://www.bloomberg.com/news/articles/2015-08-18/mondo-s-ce...
they are springing up overnight, there's already 5 or so in the same exact category (Atom, Starling come directly to mind).
the first few are taking on all the risk, once it's seen that the FCA will approve a project like this then you'll get a load more springing up overnight
>We estimate we’ll raise another £10m to launch as a bank in Q4 2016, although this may vary, and further capital raises will be necessary as the bank expands its balance sheet
E.g. in further investment rounds could the crowd investors be able to sell of their shares? Do we even get shares for this investment? I will probably invest, and probably a small amount, to understand more on how this crowd funding really works (and to see if I can get a return in the next 10 years).
A lot of Crowdcube investments issue two types of share depending on the investment size. At the higher end the A shares are regular shares, but smaller investors usually get B shares that are not equal and grant fewer rights.
The very simple question for Mondo, are all of the shares that you'll be offering via Crowdcube on the same terms as the shares that Passion have for their GBP 5m in the same round?
We'll be releasing details of terms & share-class next week before the investment goes live. There are a few regulatory questions we need to settle first.
I really like the idea but can't shake the worry of a huge financial loss is it actually possible?
http://www.fscs.org.uk/what-we-cover/eligibility-rules/compe...
During our current alpha test (and before we have a banking license), your funds are actually held by our partner bank Wirecard.
Edit: The internet beat me to it. My work here is done :)
That isn't to say you won't be better. Maybe you will be. It's just that your answer here gives no indication.
what if your system messes up and a load of my payments suddenly disappear? or your IT staff didn't completely understand how, say Cassandra treats transactions?
I like my paper bank statements...
Server abuse is difficult, but not impossible and since getting a banking licence usually does not verify any security measures, I'm wondering what they already did (or didn't) do.
(I'm well aware of the state-of-the-art, and the usual less than so, security of banking apps).
What Mondo is (from my reading) trying to do is very cool but quite ambitious. A new bank in 2016 will be a serious target for quite sophisticated attackers so they're going to have to do app/inf/ops security very well do avoid damage.
On the flip-side they have the once in a lifetime golden opportunity of a green-field deployment to actually get security baked into their systems before they're live without a load of legacy cruft holding them back.
They talk about the card revocation/freeze in the app in the talk posted earlier, which is a really nice idea (next to the metadata collection). The reason most 'normal' banks have limitations on their apps is that either they will not (or can not) guarantee the safety of their apps or want to place the responsibility at the users end. This means the limits in place (usually ~750/1000 euros max per day/week on mobile platforms) are there to make sure they won't loose too much money if people start saying "I didn't make that transfer". Banks pay out anyway (at least here in the Netherlands) because the customer dissatisfaction is of greater importance than actual tracing the problem of either a hack, an abusive spouse or simply mistyping the IBAN number. Since they collect a huge amount of metadata, this problem gets easier but won't be eliminated and can be managed by good app security and user informing the user. This limitation is the same for card revocation (not freezing, that has other issues; namely concurrency).
I do hope they get a group of 'non HN people' to test it out, as they are more likely to get into the 'I didn't make that transfer' problem.
The problem with freezing cards is that transfers are not direct: freezing the card on the banks end might work, but some ATMs or other systems might have a sufficient delay to allow (some) abuse while the card was 'frozen' by the user. The question will be who will pay for the delay.
I definitely will support these ideas as they stir up a broken market, but please make sure you have you proof-of-possession and concurrency issues well sorted out.
Where I was thinking that a lot of their security challenges will lie is things like internal money processing systems. An attacker with access to a bank's internal systems could make a right mess of things...
This is part of why their cards are online-only, every* transaction has to be verified with them before it can complete at the reader - so transactions are slower, but there is no grace period after the freeze.
* as I understand it, certain merchants are white-listed on-card for offline transactions - namely TfL.
We see Mondo as an opportunity to build a great security culture from the ground up. We're currently hiring a Head of Security role in London: https://getmondo.co.uk/careers
If you know anyone that
- is an excellent communicator
- likes to code and does so regularly
- can think like a black hat (CVEs and PoCs please!)
- doesn't mind writing the occasional policy document
please send them my way: jonas@getmondo.co.uk
BTW, at the moment we are not holding customer balances or approving transactions so we're not a particularly juicy target, yet. That said, we've already conducted pen tests and invited a number of security firms to come and break our software :)
Most of the pentesters/vuln researchers I know aren't huge fans of writing ISO2700x style policies documents (actually thinking about it there aren't many people who are fans of that kind of thing!)
if you're looking for non-traditional advertising routes for this you might want to post on /r/netsec's hiring thread https://www.reddit.com/r/netsec/comments/3zfj6v/rnetsecs_q1_...
I'd rather hire a CISO that understands security and teach them how to think like a regulator than vice versa! Heck, I have long hair myself and didn't have any contact with policy documents until just over a year ago. And both our CTO and CEO like to write code.
Basically, we're looking for our Alex Stamos. Any more ideas you have how we might find somebody like that and avoid the stigma of the "Bank CISO" job would be much appreciated.
>at the expense customer experience and true security
I always call this "lazy security"[1] and it's what you get when you hire some security professionals to "make it secure". It's a mistake to separate security from product design, the two should inform each other to come up with a compelling product that remains secure. Separating them misaligns interests, the security team will push for a change that improves security irrespective of any impact it may have on user experience.
I think Touch ID is a great example of how a novel solution can improve both security and usability.
At Mondo we are committed to investing time and energy into finding these solutions, security at the expense of user experience is a last resort.
[1]https://medium.com/@danielchatfield/lazy-security-32acc31fbd...
You can, however, identify the user with something like biometrics, and afterwards request an authorization of the transaction with something else (possession of key (good), +pin (better), or easiest a simple 'yes'(less than good)).
I've actually been disappointed to see the opposite (companies moving away from providing hardware 2FA) as other options are perceived as cheaper, despite potential weaknesses in the security model.
How is the app compared to say Barclays or some other mainstream bank? Is everything via the app rather than the website?
They have an API I think which is pretty cool for a bank, and I'm seriously interested. Disappointed to hear they won't be doing business accounts too, but I guess they want to stay focussed for now.
I've even seen in small shops signs that say they only accept debit cards.
On the other hand most UK current accounts at the moment are giving decent rates on balances (my bank gives me 3% on balances between £3000-£20,000 as well as direct debit cashback on bills and utilities).
I don't use it for all my transactions but the reporting of balance/spending history is a really nice feature, as well as the instant notifications.
[0] http://www.independent.co.uk/news/business/news/first-direct...
Like any bank we will have an anti-fraud engine that proactively declines transactions that have a high risk of fraud. We are going to work very hard to ensure the false positive rate is very low.
That being said, the system will never be perfect and I'm sure you can appreciate that it may be common for fraudsters to purchase bitcoin which could cause some legitimate transactions get blocked.
If you have any questions feel free to email me daniel@getmondo.co.uk
I don't want to be negative, but this is a huge consideration.
After 2008, unfortunately, regulations have made it much more difficult to incorporate a bank and comply with the law. Is a million enough for that?
The capital requirements to launch a bank have actually been relaxed since the financial crash. The government wants more competition in the industry and the regulator has been working to make that happen.
With Mondo, they are looking to actually become a bank.
So on a usability level, you may not actually see much difference, but on another, it would seem like Mondo are fundamentally different as they will have a level of flexibility to decide which banking services to provide to customers. Although that's not so say that Simple couldn't use third party services, they may not have the same level of independence which Mondo wants/will have.
Why do you ask this? I'm keen to hear what you'd like to see from us :)
During our current alpha test we don't invest your money at all. It's just kept in cash with our partner bank Wirecard.
I wonder how they're getting on? Anybody got any metrics?
I know the whole 3rd party thing is a little dodgy sounding, but at the very least Mondo could end up taking on a good 3rd party one and making it an official app (like Reddit did)
What i'd really like to see is a London centric bank (or perhaps building society), one that understands the rental market and the ownership market. It's insane that people (myself) pay more to rent somewhere than to buy somewhere, yet are hamstrung by the fact that either they don't earn enough to afford to buy, or don't have a deposit to afford to buy.
I thought Metro Bank might be that, but i think they're more focussed on expanding outside of London.
However, the housing market in London is all over the place, and there isn't a bank that has a direct interest in helping people on to the housing ladder in London. I think if you had a London centric bank that understood the housing situation and it's customers needs well, you'd capture a great sample of the capital.
[0] https://marketplace.visualstudio.com/items?itemName=lukehoba...