The Dutch regulator and DNB as financial supervisor are a tough cookie to deal with. In essence they hyperregulate EU-rules into goldplated Dutch rules which go beyond what is prescribed in Europe.

All NL-customers at British banks may thus be kicked out on brexit.

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If we start with the capital requirements directive, it says attracting deposits is forbidden. In article 9.

https://t.co/RYl7SXligC
Now the translation of that rule into Dutch law is slightly expanded to not only prohibit attracting deposits, but to also prohibit, having those deposits under custody ('ter beschikking hebben').

That's not in EU law, but it is in our Dutch law.

https://t.co/PsbWfNY3PA
So if you wonder how this would work out for UK banks and Payment institutions servicing Dutch customers. Have a read at the technical explanation of DNB, the financial supervisor and their summarising table.

https://t.co/LL0fAnYkRJ

Passive servicing of Dutch is not allowed!
Any bank or PSP in the UK that continues to serve Dutch customers (as in retail customers, professional players are excepted) can thus be subject to fines and policing under Dutch law.

Meaning we not only have Accidental American issues in payments, but also Accidental Dutchies
The problem does not exist for other countries, as is apparent from this ECB-explanation. Passive servicing would be allowed, but customers should note that their deposit guarantuee rules may change.

https://t.co/zNyzPPE2vl
Two things change. Some payment technicalities when doing payments from/to UK. And the rules for deposit guarantuee. As EBA (not ECB, my misstake) outlines here..
So we can see that the result of our Ministry of Finance blindly upgrading and goldplating Dutch rules no request of DNB comes with a price. The price is that it limits freedom of services and constrain the local business environment and consumers.

But they seem to like that.
In the area of digital money, the central bank/financial supervisor DNB incorrectly interprets that PSP's and e-money operators cannot hold e-money (which does not qualify as e-money), while a statement in the WFT and EU-directives states otherwise.

https://t.co/WzYvLdCz3o
To make the circle round: 'Deposits' is the equivalent of 'opvorderbare gelden' in the Dutch law on financial supervision. So if UK entities were offering e-money instead of deposits, the whole accidental Dutchies problem can be solved.

What about deposit guarantuee?
Well, the UK leaving means that the deposit guarantuee is gone anyway, so the fact that it doesn't apply to e-money products doesn't mean anything for the consumer.

Bottom line is that UK entities may want to relabel their payment accounts for Dutch citizens into e-money.
Which brings us back to square 1; Goldplating Dutch regulator/supervisor bring about extra costs for private sector, without the merit of its position being sufficiently overseen/challenged or audited.

As is clear from the way in which crypto is treated

https://t.co/Ur1l72AgXo
We now even have a Christmas song, last last Christmas, dedicated to this Dutch overregulation of crypto ...

Enjoy !

‘LASTLASTXMAS2020.WAV’ on #SoundCloud

#np https://t.co/7jmBKkOe6c

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Ok here is the explanation. Grab a cup of coffee and read on. If you have not read/noticed this, you will see intraday options movement in a new light.


Say we have two options, one 50 delta ATM options and another 30 delta OTM option. Normally for a 100 point move, the ATM option will move 50 points and the OTM option will move 30 points. But in a high volatile environment, the OTM option will also move nearly 50 points

To understand why this happens, first understand why an ATM option is 50 delta. An ATM option has the probability of 50% of expiring as ITM. The price just has to close a rupee above the strike for the CE to be ITM and vice versa for PEs

Now think of a highly volatile day like today. If someone is asked where the BNF will close for the day or expiry, no one can answer. BNF can close freakin anywhere, That makes every option of an equal probability of being ITM. So all options have a 50% probability of being ITM

Hence, when a huge volatile move starts, all OTM options behave like ATM options. This phenomenon was first observed in the Black Monday crash of 1987 at Wall Street, which also gave rise to the volatility skew/smirk

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Recently, the @CNIL issued a decision regarding the GDPR compliance of an unknown French adtech company named "Vectaury". It may seem like small fry, but the decision has potential wide-ranging impacts for Google, the IAB framework, and today's adtech. It's thread time! 👇

It's all in French, but if you're up for it you can read:
• Their blog post (lacks the most interesting details):
https://t.co/PHkDcOT1hy
• Their high-level legal decision: https://t.co/hwpiEvjodt
• The full notification: https://t.co/QQB7rfynha

I've read it so you needn't!

Vectaury was collecting geolocation data in order to create profiles (eg. people who often go to this or that type of shop) so as to power ad targeting. They operate through embedded SDKs and ad bidding, making them invisible to users.

The @CNIL notes that profiling based off of geolocation presents particular risks since it reveals people's movements and habits. As risky, the processing requires consent — this will be the heart of their assessment.

Interesting point: they justify the decision in part because of how many people COULD be targeted in this way (rather than how many have — though they note that too). Because it's on a phone, and many have phones, it is considered large-scale processing no matter what.