Fintech practices and banking regulation
摘要
This paper examines common practices by fintech firms providing banking or bank-like services and the impact of these practices on consumer and bank risk. First, we examine the extent of fintech firms claiming to provide FDIC-insured deposits using pass-through accounts and scrutinize whether these deposits are eligible for deposit insurance. Second, we examine the practice of sweep networks, where fintech firms use multiple accounts to provide insured deposits above the $250,000 limit imposed by the FDIC. Third, we examine the relationships between fintech firms and the banks that take their deposits and discuss the issues for these banks. We estimate that there could be $5.1 billion of deposits at state and federally chartered banks through fintech firms that are not eligible for FDIC deposit insurance. We discuss how fintech practices lie in a grey area of regulation making the restriction of such practices difficult for regulators given current legislation. In addition, we examine the hazards for consumers and regulators and the potential impact of these fintech practices on systemic risk.