Davis Polk partner and Financial Institutions co-head Margaret Tahyar was quoted in Bank Director on bank-fintech partnerships and how banking as service arrangements are being scrutinized by regulators. Margaret noted that “The banks that do it [banking as a service] well have constant engagement with their fintechs” and that “you need someone at the end to hold the bag – and that’s always the bank. So the bank always needs to have visibility and awareness functions.”

She added that in terms of regulation, “It’s quite clear that [the OCC] is going to be doing a deep dive in examinations on fintech partnerships.”

What to Consider as Regulators Scrutinize Bank-Fintech Partnerships,” Bank Director (October 10, 2022)