In the wake of recent high-profile cases (e.g., Synapse) in which consumers have been put at acute risk, the banking agencies have both reiterated current policy and sought comment on how best to govern relationships that might have an adverse impact on both consumers and affected banks.  Relationships involving deposit products are in the agencies’ immediate sights because they have had the clearest adverse impact when it comes to both fintech and cryptoasset counterparties.  However, the agencies are considering a new framework for bank/fintech relationships that would also affect bigtech and tech-platform companies that have partnered with some of the largest banks to provide payment, credit-card, and other financial services.

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.