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New frontiers in compliance automation that can strengthen FinTech – Partner Bank relationships under fire

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By Kim Gerhardt

Money 20/20 is one of the biggest events in financial services, blending all things digital across banking and FinTech. Despite economic and market uncertainty, this year’s event held last week in Las Vegas, brought energy and optimism that could only be described as infectious.  

Over 11,500 registered attendees convened at the Venetian to explore new developments in the industry and challenge the status quo.  A major theme of the conference was the need for the industry to strengthen and prove the governance function between FinTechs and their Bank partners, coupled with the availability of automated tools and techniques to support these relationships and their overall risk management functions that benefit FinTechs and Bank partners alike.

Here are some takeaways related to this theme from Money 20/20 this year: 

  1. FinTechs continue to need access to a Bank’s charter to move money and/or provide financial services under the watchful eyes of regulators who monitor compliance with KYC, AML, BSA, fraud monitoring, OFAC screening, UDAAP, fair lending, and other requirements.  While some FinTechs obtain their Charters through their own applications (Varo Bank) or through bank acquisition (Lending Club, SoFi), a more common approach is to form a relationship with a Bank that has experience in partnering with FinTech providers.
  2. There was an increased focus and discussion on the governance between FinTechs and their Partner Banks, and the coordinated compliance programs that need to be in place to protect industry stakeholders including FinTechs, Partner Banks, investors, and consumers.  The growth of BaaS and the number of FinTech partnerships has increased regulatory scrutiny in this sector, as evidenced by the recent order by the OCC against Blue Ridge Bank relating to third-party risk management, BSA/AML risk management, suspicious activity reporting, and information technology control and risk governance.
  3. Given a backdrop of economic uncertainty and rising interest rates, FinTechs must now justify their business models and business practices, including complying with numerous regulations.
  4. Partner Banks must demonstrate to regulators that they are monitoring FinTech activities and the overall relationship. FinTechs, meanwhile, need to stand up their practices to many constituents – to regulators, their Partner Banks, and investors.  Money 20/20’s agenda included panels where banks, FinTechs, and industry experts discussed the requirements for successful partnerships. These include strategic and product alignment, organizational resources and commitment, technology integration and formalized governance programs and frameworks to ensure ongoing regulatory compliance and consumer protection. Such programs are crucial since FinTechs are an extension of the Banks that they partner with, and introduce financial and reputational risk to Bank partners.
  5. Kareem Saleh, CEO of FairPlay, took the stage to discuss how FairPlay works with its bank and FinTech customers to debias data and automate fairness testing and compliance (back-end reporting as well as front-end model development) of algorithmic models used across the customer lifecycle (e.g., marketing, credit decisioning, pricing, fraud screening, servicing).  FairPlay also optimizes decisioning systems for fairness and creates Second Look programs.  Through these analytics, FairPlay has been able to help its customers reduce their cost of compliance, increase confidence when dealing with regulators by evidencing commitment to fairness, increase application approvals, and ultimately provide fairer products and solutions to their customers.

Over time we expect to see governance models between FinTechs and Partner Banks continue to evolve and strengthen.  Forward-looking Partner Banks and FinTechs will invest in automated tools and in their compliance, legal, and oversight functions to support this evolution and create a competitive advantage.