Bank Partnership Programs and the Regulatory Response

Summer 2018

Member Robert Savoie authored an article titled “Bank Partnership Programs and the Regulatory Response” for the Civic Research Institute’s Summer 2018 Journal of Taxation and Regulation of Financial Institutions.

The article discussed the growing popularity of bank partnership programs with FinTech companies and the corresponding growth in attention from both federal and state regulators. On the federal side, the OCC has proposed to issue a FinTech charter (now challenged by lawsuits) and clarified the vendor management obligations of depository institutions. On the state side, responses have been varied, with some states ignoring the programs while others have brought enforcement actions to preclude them.