Summer Regulatory Summit eBook

Internal Use Only

FinTech Relationships & BaaS • 13 consent orders ~3.5 years related to fintech partnerships • Can BaaS be done effectively? • How do you track your partners partner? • Key point: Fintechs are mostly startups • What does the winddown look like? • How do you untangle a multimillion-dollar partnership?

Internal Use Only

FinTech Relationships & BaaS • The Evolve C&D is the most detailed action to date. • Asks for extensive procedures and documentation from the bank (which has over 100 fintech partnerships) • Covers: • Board oversight • BSA/AML and OFAC compliance for third-party partnerships • Clearly defining roles • Independent and experienced decision makers

• Ongoing due diligence of partners • Fintech impacts on capital planning • And much more…