バンキング・アズ・ア・サービスにおけるリスク - パートナーマネジメントの基本に立ち返る

Banking as a Service (or BaaS) has been catching the limelight for a few years now, both in the US and Europe. Built on the backbone of modern API frameworks, banks and fintechs can collaborate to scale their products and services through new third party channels.

Celent has been covering this space for some time, and I recently published Adventures in the Open Banking Ecosystem: Considerations for Corporate Banking Partnerships, which discusses some of the gives and gets of a fintech-bank partnership. Potential partners must ask some tough questions of each other (and themselves) and have a real world reality check about culture, commercials, technology, operations, and risk. Ultimately it is the bank that is regulated and will be the party to bear regulatory wrath if things to go wrong.

Events surrounding SVB, Signature Bank and First Republic Bank have driven unease about the health of some banks this last quarter. Separately, recent news about Cross River Bank receiving a consent order from the FDIC will no doubt raise new concerns about the role of fintechs and innovative BaaS operating models. Just last summer, Blue Ridge Bank also received a consent order from the OCC.

Although Celent advocates a partnership model for BaaS adventures rather than a traditional vendor management approach, the bank in the relationship always bears the most risk. As a regulated entity, the bank must have the risk appetite for partners performing banking services on their behalf, such as adding accounts, acquiring balances, originating loans – and execute oversight of these activities. This approach, and the limits of risk tolerance, must be agreed at the highest level by business, operations, compliance, and risk management executives.

Building new bank-fintech partnerships may require training new muscles by both parties, but special consideration must be given to risk assessments and operational due diligence if BaaS and embedded finance misadventures are to be avoided. It is inevitable that the heightened risk sensitivity around the banking ecosystem will only encourage closer regulatory attention to bank-fintech partnerships. Banks must manage partners responsibly, hold them accountable, and not take on undue risk as they seek growth opportunities.