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Thread Bank Responds to FDIC Enforcement Action
2024: The Summer of Consent Orders for Smaller Banks
The summer of 2024 is seeing a surge in consent orders for smaller banks. On June 28, Tennessee-based Thread Bancorp became the latest financial institution to come under the Federal Deposit Insurance Corporation’s (FDIC) scrutiny. This highlights the growing importance of managing operational, compliance, and strategic risks associated with third-party partnerships for banks and their FinTech collaborators.
Typically, the FDIC announces enforcement actions on the last Friday of each month. The recent order for Thread, a popular partner bank for numerous FinTechs, is notable for explicitly addressing the bank’s Banking-as-a-Service (BaaS) and Loan-as-a-Service (LaaS) programs.
Dated May 21, the order mandates Thread Bank to implement several corrective measures without admitting or denying any unsafe or unsound banking practices. These measures include establishing a comprehensive third-party risk management program and enhancing due diligence, monitoring, and exit planning for Thread’s FinTech partners. This requirement underscores the regulator’s increasing focus on banks’ relationships with technology firms.
“Within 120 days of the effective date of this ORDER, the Bank’s BaaS and LaaS program policies and procedures must be thoroughly documented, covering, at a minimum, third-party partner and customer approval requirements, due diligence processes, growth and stress modeling, ongoing AML/CFT compliance monitoring, and steps to unwind third-party business lines, including FinTech partners,” the FDIC stated.
Thread’s FinTech and BaaS partners include Unit, which provides services for Relay, Toolbox, Sequin, Currence, Arpari, and several other platforms.
“When vetting potential fintech clients, both Thread and Unit prioritize maintaining a strong focus on compliance and oversight,” Unit wrote in a 2023 blog post.
“We remain steadfastly committed to collaborating with regulators at the state and federal levels because we believe the regulatory framework is necessary and can help create a strong banking system for consumers and small businesses,” Chris Black, CEO of Thread Bancorp, Inc. and Thread Bank, said in a statement to PYMNTS.
Black added, “We are dedicated to meeting all obligations and have made substantial investments to improve our policies, processes, procedures, and controls over the past three years in collaboration with the FDIC and the Tennessee Department of Financial Institutions (TDFI). We will continue to invest in our teams and services to ensure we meet the needs of, and provide strong protection for, our customers and partners as we move forward.”
FinTech Risk in Financial Supply Chains
Navigating the complex web of financial regulations is a daunting task, especially for FinTech startups with limited resources. Partnering with established banks allows FinTech companies to leverage their partners’ robust regulatory frameworks, reducing the compliance burden.
The BaaS model aimed to create a shared compliance environment where FinTechs could operate within regulatory bounds while focusing on innovation and growth. However, the reality has been more challenging.
A year ago, on June 6, 2023, the FDIC, the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) issued final guidance on managing risks associated with third-party relationships.
Since then, the collapse of Synapse’s bankruptcy has tested the interconnected BaaS and FinTech landscape. Adding to the turmoil, Synapse’s primary banking partner, Evolve, suffered a significant cyberattack on June 26, putting its risk controls under scrutiny.
“The regulators are now awake,” Thredd CEO Jim McCarthy told PYMNTS. “Too many people focus on the ‘as a service’ part but neglect the banking part. If you fail at banking, the service piece doesn’t matter.”
The Middle Falls out of Middleware
A PYMNTS Intelligence report found that 65% of banks and credit unions have formed at least one FinTech partnership in the past three years, with 76% viewing these partnerships as essential to meeting customer expectations. Additionally, 95% of banks aim to use partnerships to enhance their digital product offerings.
Thread Bancorp, previously known as Civis, has a history of regulatory actions. Its recent FinTech partnerships have driven rapid growth, from less than $100 million to over $720 million between the end of 2020 and Q1 2024, according to FDIC call reports.
“With complex ecosystems, you have more partners than ever before,” Larson McNeil, co-head of marketplaces and digital ecosystems at J.P. Morgan Payments, told PYMNTS. This creates new challenges for managing partners and counterparty risk.
The Thread Bank case may indicate how regulators approach the intersection of traditional banking and financial technology. As the financial landscape evolves, the key to leveraging the BaaS model lies in fostering strong, transparent, and mutually beneficial relationships between banks and FinTech firms. By doing so, they can collectively drive the future of banking toward greater inclusivity, efficiency, and innovation.
Source: pymnts.com
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