The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’ management of third-party relationships, albeit with a new level of intensity that reflects rapid changes in the provision of financial services. This concern has been punctuated by last year’s bank failures and the recent bankruptcy of banking fintech partner Synapse and is reflected in recent enforcement actions, including against Evolve Bank and Trust and Green Dot Bank. Bank partnerships with fintechs have grown increasingly complex in recent years, as have business models relying on banking-as-a-service (BaaS) arrangements in which financial institutions are sometimes “junior partners” (i.e., smaller in assets/revenue than fintechs and/or less sophisticated or complex).
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