e believe that dominant incumbent operators have a wide sustainable economic moatcharacterised by: (1) an extensive database that is difficult to replicate, (2) strong brand andloyal customer following, (3) strict regulatory requirements that afford them unique access toimportant data for credit risk verification purposes, and (4) deeper pockets to build capabilityand safeguard against data breaches. The long term dominance of the three listed ASEANCRAs (namely CTOS, BOL, and CBA), who have maintained leading market positions in theirrespective countries, is a strong testament that dominant incumbent operators have anunassailable lead given their strong competitive advantage and high barriers to entry.