#6

a payday loan by any other name would smell as sweet 🌹

Apr 14, 2020

This is a newsletter about regulatory hacking featuring (mostly) Canadian startups.

Because all start-ups need a regulatory strategy to succeed.

Most of all, we need more startups to embed policy thinking into their product design processes and more policymakers to take an entrepreneurial, experimental approach to regulation.

spotlight: moves  
 
policy leadership: Google + Amazon on contact tracing  
 
legislative pages: how to run a city like amazon  

space policy: spaceports as rural economic development 

tune: witches by waxahatchee

Roxi Horror 💀🌸 @roxiqt

THERAPIST: [over the phone] How have you been passing the time? ME: [mixing 4 types of cereal together to create a stronger, more delicious super cereal] I'm learning to cook

*what if I want to click around on a non-COVID policy report?

Then get amped about a summary document from the Canadian Institute for Advanced Research (CIFAR, which is pronounced see-far [not ki-far] and it literally took me years to learn that, making it the ‘Queen’s Quay’ of research hubs). The final report highlights the focal themes and recommendations from the conversations that took place over the course of a Symposium this past January. There’s a one-page workshop brief, summarizing key insights and next steps.

I am most excited about the potential for more policy sandboxes. I’ll write more about those in the future.

Policy sandboxes, simulated environments for experimentation, are one approach to testing regulatory mechanisms safely. This approach could identify risks and problems before moving forward with formal regulation. Sandboxing can also be used to test products and services before they are deployed, particularly by public bodies.

quick case study: moves

I came across this company via The Logic’s newsletter. Fintech startup “Moves” offers loans for gig workers. Right now they have a narrow definition of this work, and are limiting the loaning to people engaged in ride hailing or food delivery. Given that gig work seems to be further eroding during the pandemic, this offering appears to be a novel intervention.

Moves will loan gig workers as much as $2500, requiring no payments for the first 12 weeks, after which the company will withdraw $70 a week for 40 weeks. Over a one-year period, people will pay back $2,800 in total, an interest rate of about 12 per cent.

The company has accelerated its planned autumn launch and has started to offer loans to Ontario-based ride-share drivers and food-delivery workers.

Does a payday loan by any other name smell as sweet? 🌹 JK. I think this is a neat company that solves for a real problem that many gig workers face in a fair way. Intriguing: the firm is awarding loans without assessing credit scores. It seems their key indicator of the viability of lending is whether an applicant has a history of having insufficient funds (NSF) in their account. Something different than other loan schemes: they start paying themselves back via pre-authorized debit.

Moves is backed by The Open Application Network (OAN). The OAN is a public infrastructure that creates a new design space for Open Applications. Open Apps are programs that put users back in control and are universally accessible across online platforms.

I think it’s useful to consider that the data doesn’t differentiate very well between people that engage in “gig” work for their core income (main gig) or complementary income (side hustle). That could complicate this loan scheme - for example, if someone is an occasional Uber driver but also has a full-time role working at a bakery, and their ride-share income is compromised but their other role isn’t, should or will they qualify? And if you want to get anchored in the data that Canada does have, see this StatsCan report from late 2019: Measuring the Gig Economy in Canada Using Administrative Data.

Where do regs fit in? A payday loan is a small, unsecured loan. In Ontario, the Payday Loans Act, 2008 is the main law governing payday loans. The General Regulation and Administrative Penalties Regulation contain additional rules. It doesn’t seem that “Moves” quite fits this designation.

All loan and trust corporations must be federally incorporated in order to register to conduct business in Ontario. The Financial Services Commission of Ontario (FSCO) is responsible for the registration of federally incorporated loan and trust corporations that wish to conduct business in Ontario. I did’t find “Moves” or “2748838 Ontario Inc” listed as a loan company in Ontario.

Back to sandboxes for a sec - Moves might benefit from participating in the Ontario Securities Commission’s Launchpad program, which creates a regulatory sandbox of sorts for innovation in the fintech space.

BTW, Sunil Johal has a piece in First Policy Response about rethinking supports for non-standard workers in Canada, “The Gig is Up.”

leadership: Apple + Google on contact tracing

Just when you thought 2020 couldn’t get any more surreal, Apple + Google announced a partnership whereby they’re building a contact tracing technology that would rely on bluetooth signals to let smartphone users know when they’ve come into contact with someone who has COVID-19.

Tim Cook @tim_cook

Contact tracing can help slow the spread of COVID-19 and can be done without compromising user privacy. We’re working with @sundarpichai & @Google to help health officials harness Bluetooth technology in a way that also respects transparency & consent.

Apple and Google partner on COVID-19 contact tracing technologyApple and Google announce a joint effort to help governments and health agencies reduce the spread of the virus, with user privacy central to the design.apple.com

Contact tracing is something that is traditionally done by humans - it’s basically the process of figuring out how many people a sick person came into contact with so that you can alert them and reduce transmission.

Francesca Bria @francesca_bria

10 requirements for "Contact Tracing" apps: must have epidemiological purpose, be voluntary to download, follow privacy by design principles, guarantee anonymity & security of user data, the source code must be freely available. Great work @chaosupdates

CCC | 10 requirements for the evaluation of “Contact Tracing” appsccc.de

Toby Walsh @TobyWalsh

We must call out bullshit when we see it, and must not give policymakers the false hope that techno-magic might let them avoid the hard decisions

Contact Tracing in the Real WorldThere have recently been several proposals for pseudonymous contact tracing, including from Apple and Google. To both cryptographers and privacy advocates, this might seem the obvious way to protect public health and privacy at the same time. Meanwhile other cryptographers have been pointing out som…lightbluetouchpaper.org

I need to learn more about this, and I’m looking forward to learning from experts. I haven’t spent enough time with all the material to form an opinion worth typing and I’m going to this webinar later today to mull more (P.S. all university programming in the future should be virtual).

Learn more:

The Electronic Frontier Foundation - The Challenge of Proximity Apps For COVID-19 Contact Tracing
The Verge - Why Bluetooth apps are bad at discovering new cases of COVID-19
Wired - Clever Cryptography Could Protect Privacy in Covid-19 Contact-Tracing Apps

legislative pages: how to run a city like amazon

Remember when Naborly made a “blacklist” of tenants that missed April 1st’s rent? Or how the feds signed a big procurement deal w/ Amazon (Government of Canada partners with Amazon to help get personal protective equipment to front‑line healthcare workers)? And how you can’t comfortably chill at a park right now? More tech + government teaming up in uncomfortable ways.

This week I’m suggesting an imaginative and subversive read from meatspace press. The chapters are short and perf for a COVID-limited attention span. The idea behind the book is to ask what would it be like to live in a city administered using the business model of Amazon (or Apple, IKEA, Pornhub, Spotify, Tinder, Uber, and more), or a city where critical public services are delivered by these companies?

There is currently a petition claiming that “Amazon is failing to protect our health,” that you can consider signing. Maybe we are on the brink of cyberpunk, after all.

Can the New Space Race Save Small Towns?

Amazing article by Matthew Halliday in The Walrus. I had not considered the economic geography of space ports.

*illustration by Aimée Henny Brown.

In the years since, the promise of economic salvation has appeared every so often in the form of ambitious—though uncertain—megaproject proposals. There’s been talk of a gold mine, a liquid–natural gas terminal, and a granite quarry, though none have come to pass. Then, in October 2016, a company called Maritime Launch Services (MLS) appeared in Halifax with an idea that sounded like the longest Hail Mary of them all: Canso, it said, is the ideal site for Canada’s first commercial spaceport.

Things I learned:

MLS = “Maritime Launch Services,” but the acronym evokes “Municipal Licensing and Standards” for me;
“smallsats” = smaller, less expensive satellites. I love this casual slang for satellites;
The charm of the phrase “modern space economy,” not like that OLD space economy!
The University of British Columbia has an Outer Space Institute;
Northern Sky Research is “the global market leader in the satellite and space industry;”
Unsymmetrical dimethylhydrazine (UDMH);
“Hydrazine is so twentieth century;”
The United States has eleven licensed commercial spaceports, but only six have actually seen a launch.

Kristy Milland, MA ⁷ @TurkerNational

Low-orbit internet banking fraud claim alleged to be a load of space junk • The Register

Low-orbit internet banking fraud claim alleged to be a load of space junkThis is what comes of mixing the International Space Station, a relationship breakdown, and banking recordstheregister.co.uk

tune: witches by waxahatchee

You can't bluff or outsmart
All reason falls apart
Yeah, the myth without struggle, babe
It can't fill your heart

Vass Bednar writes “regs to riches” and is a public policy solopreneur.

She can be reached at vasiliki.bednar@gmail.com or follow her (er, me) on Twitter @VassB.

Archives available via regstoriches.substack.com

#6