Letter to OCC, Board and FDIC on Fintech Arrangements Involving Banking Products and Services

James P. Sheesley
Assistant Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW Washington, DC 20429
Attention: Comments RIN 3064-ZA43

Chief Counsel’s Office
Office of the Comptroller of the Currency
400 7th Street SW Suite 3E–218
Washington, DC 20219
Attention: Comment Processing, Docket ID OCC 2024-0014

Ann E. Misback
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC 20551
Attention: Comments Docket No. OP-1836

To Whom It May Concern:

The American Bankers Association1 is pleased to comment on the Request for Information (RFI) on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses that was issued by the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC). 2 The RFI solicits input on the nature of bank-fintech partnerships, effective risk management practices pertaining to these arrangements, and other implications of such partnerships.

The financial sector is melding banking and technology in new ways as the world economy undergoes a digital transformation. As this evolution unfolds, the RFI will be an important tool to help the agencies learn more about how banks partner with fintechs to deploy financial products and services. We urge the agencies to leverage the input generated by the RFI to modernize their approach to regulation and supervision and to provide banks with a meaningful, transparent, and consistent path to innovation. We appreciate the use of an RFI and encourage the agencies to continue to seek input from banks and other stakeholders as technology and bank partnerships evolve.

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