Banks are ultimately responsible for all of the services that they provide, even when they contract with third parties to help them deliver those services. More and smaller banks are partnering with outside providers, and there are more and smaller third parties being formed to meet more specific bank needs. While there’s even a section in the U.S. Federal Financial Institutions Examination Council’s (“FFIEC”) IT Examination HandBook detailing what sorts of due diligence a bank should conduct on its third party service provider, there’s still room for interpretation when deciding how more inexperienced banks should deal with those responsibilities.
The answer isn’t straightforward. All banks are challenged when contemplating a relationship with a small fintech because of the first three items on the FFIEC checklist: Existence and corporate history; Qualifications, backgrounds, and reputations of company principals…; and Other companies using similar services from the provider…. Small, new companies will find it more difficult than established firms to pass muster; many banks simply won’t want to take the risk of dealing with them. And many smaller banks simply won’t have the resources or expertise to properly vet these new entrants.
At the same time, many larger service providers to banks (including software vendors, outsourcing providers, and consulting shops) are searching for ways to bring innovation to their banking clients.
In recent conversations with clients I’ve been struck by an increasingly popular solution: a larger, more established firm bringing a fledgling company under its wing. The incumbent does the due diligence, offers advice, and, when satisfied, vouches for the FinTech. It may license the software, or engage the Fintech as a subcontractor; in any case, it’s assuming responsibility for the work of the smaller and newer firm.
Executed properly, it’s a three way win: the bank accesses a new and innovative solution; the incumbent service provider is able to add new value to the relationship; and the fintech is able to begin a relationship from which it would otherwise have been shut out. All participants in the banking ecosystem should consider whether this solution can help their particular situation.
