Bank/Fintech Partnerships—Solving for a Nationwide Product and Service
Author: Jedd Bellman.; Daniel Bellovin.
Source: Volume 39, Number 09, September 2023 , pp.111-118(8)
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Abstract:
This article explores the regulatory landscape facing banks that partner with Fintechs to offer a wide range of credit products to consumers on a nationwide basis. In particular, this article discusses the provisions under federal law that enable banks to offer products and services on a nationwide basis, the impacts of federalism on these partnerships, including navigating disparate laws and regulations, and how they are enforced by government actors under their respective authorities.Keywords: Dual Banking System; Partnerships Engaged in the Extension of Credit; State Licensing Considerations; “True Lender”; Usury Limits; DIDMCA Opt-Out; CFPB Oversight
Affiliations:
1: Orrick Herrington & Sutcliffe LLP; 2: Orrick Herrington.