News & Analysis as of

FinTech Risk Management

Ankura

Banking as a Service: How Strong Is Your Financial Crime Compliance Partnership?

Ankura on

The growth in partnerships between banks and Fintech companies through Banking as a Service (BaaS) models presents significant opportunities for innovation across the financial services sector. However, these collaborations...more

Arnall Golden Gregory LLP

Preparing for the Digital Operational Resilience Act (“DORA”): Key Steps for Payments and Fintech Clients

The Digital Operational Resilience Act (“DORA”), an EU regulation designed to bolster the resilience of financial entities against Information and Communications Technology (“ICT”) risks, entered into force on January 16,...more

Troutman Pepper

Where the F(BO) is the Money? Part 2 — Adopting the Right Lessons from Synapse

Troutman Pepper on

This is the second of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Conyers

The Importance of Sound Corporate Governance for Virtual Asset Service Providers: Lessons from Past Failures

Conyers on

In recent years, the virtual asset industry has experienced exponential growth, bringing about innovations in digital payments, tokenisation and decentralised finance (Defi). While highly innovative, the volatile nature of...more

Conyers

Navigating the Future: Highlights from CIMA’s Outreach Session on the Virtual Asset Service Provider Regime

Conyers on

As the global financial landscape continues to evolve, the rapid growth of virtual assets and use of blockchain technology has prompted governments worldwide to reassess their legal and regulatory frameworks. The emergence of...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Regulators Escalate Focus on the Risks of Bank Relationships with Fintechs and Other...

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On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Developments Could Facilitate Greater Bank and Broker-Dealer Involvement in Cryptoasset Services

On September 9, 2024, the Chief Accountant of the U.S. Securities and Exchange Commission (SEC), Paul Munter, delivered remarks describing circumstances in which, in the SEC staff’s view, entities may engage in cryptoasset...more

Fenwick & West LLP

FDIC Proposes More Oversight on Custodial Deposit Accounts

Fenwick & West LLP on

On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more

Troutman Pepper

Where the F(BO) Is the Money? Part 1 – Synapse’s Clarion Call for Standards

Troutman Pepper on

This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Informed Board - Summer 2024

Across industries, companies are facing new and uncertain regulatory pressures and demands in areas including artificial intelligence, sustainability, algorithmic pricing and fintech-bank relations. In this issue of The...more

Sheppard Mullin Richter & Hampton LLP

Fed Issues Cease and Desist Order for Crypto-Related Compliance and Risk Management Deficiencies

On September 4, the Federal Reserve Board (Fed) released enforcement actions against a Texas-based bank, addressing regulatory violations and compliance lapses. The Fed, joined by the Texas Department of Banking (TDB),...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Why do Fintechs Want to Become Banks?

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A great number of fintechs are contemplating owning a bank or obtaining a banking charter—either a national bank charter, a state bank charter or a special purpose charter. In this episode, we are joined by our special guest...more

Mayer Brown

Interview with Jason Cave, Former Regulator Turned Industry Adviser

Mayer Brown on

Matt Bisanz interviews former financial regulator Jason Cave to discuss developments in resolution and recovery planning, as well as trends in third-party risk management....more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Alston & Bird

Regulators Focus on Bank-Fintech Arrangements

Alston & Bird on

Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more

Goodwin

Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

Goodwin on

This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

Troutman Pepper

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

Troutman Pepper on

“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more

WilmerHale

Interagency Issuances on Bank-Fintech Partnerships Highlights Risks, Opportunities, Importance of Industry Participant Engagement

WilmerHale on

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’...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

Ballard Spahr LLP on

The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Ballard Spahr LLP

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

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The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

Venable LLP

Federal Banking Agencies Highlight Bank-Fintech Partnership Risks and Invite Comment

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On July 25, 2024, the federal banking agencies issued a joint statement flagging potential risks in bank-fintech arrangements, along with a request for public information (RFI) on the benefits, risks, and risk management...more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Troutman Pepper on

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

Goodwin on

As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

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