First & Peoples Embroiled In Dispute With Bankrupt "Fintech" Lender
First & Peoples Embroiled In Dispute With Bankrupt "Fintech" Lender
Banks' Partner Offered "Shoot Now Pay Later" Financing Via "GrabAGun," An Online Weapons Retailer
Hey all, Jason here.
When this hits your inbox, I should be about halfway between Amsterdam and Dubai, where I’m heading to speak as part of the Fintech Surge event taking place today through Wednesday.
I’m also excited to share that I’ll be in Washington, DC, this November for the American Fintech Council policy event, taking place on Tuesday, November 19th. I’ll be in DC November 19th through Friday, November 22nd — if you’re based in DC or will be in town and would like to catch up, let me know by replying to this email.
If you enjoy reading this newsletter each Sunday and find value in it, please consider supporting me (and finhealth non-profits!) by signing up for a paid subscription. It wouldn’t be possible to do what I do without the support of readers like you!Tune in: Results from surveying nearly 200 fintechs
Sponsored content: This Wednesday will be an action-packed discussion of the top trends Unit21 has uncovered in fintechs across fraud and AML. They’ll dive into topics like:
The most common, costly, and time-consuming fraud types
How others are addressing resource-intensive AML
Importance of speed to response as payment rails get faster
And the hidden cost of false positives
This is the 3rd annual State of Fraud & AML and this fintech data cut is part of a larger research report surveying nearly 350 FIs & fintech, launching October 28th. Request your copy.
First & Peoples Embroiled In Dispute With Bankrupt "Fintech" Lender
A mostly overlooked story earlier this year provides yet another example of the potential risks that face unsophisticated banks when they partner with third parties.
In this case, the situation centers on First & Peoples Bank, an approximately $200 million asset bank located in Russell, Kentucky, population 3,669, and its partnership with point-of-sale lending platform U.S. Credit, Inc.
It’s debatable whether or not U.S. Credit should be considered a “fintech,” as its web presence and court filings suggest the company and its leadership and staff were not particularly technologically inclined.
For its part, based on information contained in various court filings, the contents of the regulatory actions against the bank, and its web presence, First & Peoples doesn’t present as an institution particularly knowledgeable about technology, either.
But, regardless of the label, the operating model employed by U.S. Credit, First & Peoples, and several other bank partners that were involved — and the risks it entailed — are largely consistent with the kinds of approaches used in bank-fintech partnerships and marketplace lending arrangements by better-known lenders and banks.
The risks posed by the relationship directly led to First & Peoples receiving two regulatory enforcement actions. The first issued in December 2023 by the FDIC and the Kentucky Department of Financial Institutions; the second, a written agreement between the bank’s holding company and the Federal Reserve in March 2024.
But the challenges First & Peoples faces from its ill-fated partnership may go substantially beyond remediating these enforcement actions.
First & Peoples’ partnership with U.S. Credit has saddled the bank with a sizable amount of bad assets, which may require it to raise fresh capital — and, if it is unable to do so, may threaten its very ability to survive.
First & Peoples Partnership With “Fintech” Lender U.S. Credit
According to a statement in U.S. Credit’s January 2024 bankruptcy filing from its CEO, Stephen J. Galvin, the firm was initially founded as a “sales finance agency” specializing in rent-to-own financing and was purchased by Florida-based Perry Banking Company in 2010.
At the time, the company specialized in providing financing through manufacturers and retailers of “sheds and other outdoor storage buildings,” primarily in Florida and nearby states.
In 2017, Galvin acquired U.S. Credit from Perry Banking Company. Galvin, according to his statement in the bankruptcy case, spent fifteen months implementing “system enhancements” in order to offer a close-ended financing consumer loan marketplace that provides “elective medical service financing, financing and leasing of power sports equipment and vehicles.”
Initially, U.S. Credit utilized warehouse lines to fund its originations and sold loans to secondary buyers.
In 2020, the company “further refined” its business model in order to eliminate its reliance on debt facilities by entering into agreements with bank partners that would serve as lender-of-record to originate loans and with bank and credit union partners that would “contemporaneously” purchase the loans.
U.S. Credit secured First & Peoples as its initial originating bank partner in 2020, with the bank agreeing to originate up to $5 million in loans and leases per week, according to filings in the bankruptcy case.
Per the same filings, Connexus Credit Union, located in Wausau, Wisconsin, entered into a loan and lease participation agreement and, by 2022, was purchasing up to $30 million in loans and leases per month.
2022 also saw better-known Thread Bank enter into an agreement to purchase loan and lease participation stakes; Thread later agreed to serve as an originating bank partner for U.S. Credit, according to CEO Galvin’s statements in the bankruptcy.
Another financial institution, Georgia’s Own Credit Union, agreed to purchase up to $250 million of U.S. Credit-originated loans, per Galvin’s statement.
According to U.S. Credit’s filings, the company originated and oversaw loan and lease portfolios consisting of approximately 27,900 accounts to approximately 27,000 borrowers in all fifty states.
What Went Wrong?
While U.S. Credit’s business and operating model may sound complex, it isn’t all that unusual.
Better-known non-bank “fintech” lenders, like Affirm, Upstart, and Pagaya, leverage both bank partners and state-lending licenses and a number of financing mechanisms, including whole loan sales, securitizations, and the sale of receivables or participations stakes.
But, problems began to emerge in 2021 with one of U.S. Credit’s sub-servicers, ZuntaFi. According to the filing, that October, U.S. Credit “personnel discovered that approximately $3,100,000 in borrower payments designated for Connexus were stolen in a cyber theft from USCI’s sub-servicer, ZuntaFi.”
While, the suit says, U.S. Credit wasn’t at fault for the theft, it made Connexus whole and struck an agreement with ZuntaFi to be repaid $2.5 million over a 60 month period.
As a result of the incident, Connexus required U.S. Credit to replace ZuntaFi as its sub-servicer, which, CEO Galvin says, forced the company to migrate approximately 17,000 loan accounts to a new servicer. The transition process cost the firm $500,000 and “disrupted the payment patterns” of borrowers, resulting in loan losses the company estimated to be nearly $15 million, according to its filings.
Around the same time as the ZuntaFi cyber theft, First & Peoples “unilaterally reduced” its commitment to originate loans for U.S. Credit, and Georgia’s Own reduced what it would purchase, Galvin says.
U.S. Credit responded by funding certain loans itself from its revenue and subsequently, in December 2022, entered into a debt facility agreement with Clear Haven Capital Management, which agreed to make advances to U.S. Credit for up to $20 million against loans it had written, CEO Galvin admits in the bankruptcy case.
But, First & Peoples alleges in a separate complaint, filed in Kentucky state court in August 2023, that U.S. Credit breached its contractual and fiduciary obligations by failing to remit these and other payments to the bank. In the same complaint, First & Peoples also accuses Georgia’s Own Credit Union of breach of contract, stemming from its obligations under the loan participation agreement it entered into with First & Peoples and U.S. Credit.
In the suit, First & Peoples claims that U.S. Credit funded loans in the bank’s name, sold them, and, instead of providing the proceeds to the bank as their agreement required, used the proceeds to fund additional loan originations and/or retained the funds for the company’s own purposes.
The bank’s suit also alleges that U.S. Credit used the assignments of loans it originated under First & Peoples’ name to secure the $20 million credit line from Clear Haven, but did not make payment owed to the bank for these transactions.
In an unusual twist, the suit also names one of the bank’s own employees, Michael Hill, who, the complaint says, had a fiduciary duty to act in the interest of First & Peoples, was obligated to properly underwrite, monitor, and oversee the credit relationships of the bank, and was obligated to report material facts and circumstances of such relationships to the bank’s board of directors.
First & Peoples complaint alleges Hill, a vice president at the bank at the time, breached his fiduciary duties and acted in a negligent manner, including by failing to report to the bank’s board that U.S. Credit failed to make payments due to the bank, sold loans owned by the First & Peoples and failed to remit the proceeds to the bank, comingled funds of First & Peoples with funds of others, among other allegations.
Per First & Peoples’ most recent call report, the bank has just 50 employees. The decision to pursue a civil case against Hill and First & Peoples’ depiction of his role and actions suggest Hill had wide discretion over the third-party lending program with little, if any, oversight. Hill’s actions, as described, suggest stunning gaps in the bank’s oversight and controls, as they seem to indicate that the bank’s management and board were unaware of Hill’s actions or lack thereof.
As part of the suit, First & Peoples sought a temporary restraining order prohibiting U.S. Credit from “distributing or dissipating assets owned by or owed to [First & Peoples],” which was granted ex parte by the court.
But, by December 2023, despite ongoing negotiations between the parties, First & Peoples filed a motion alleging that U.S. Credit had violated the temporary restraining order and sought the appointment of a receiver to take control of the company.
Georgia’s Own Credit Union, despite certain disputes with First & Peoples, joined the bank’s motion seeking the appointment of a receiver.
Following an evidentiary hearing on the motion to appoint a receiver, the judge in the case found that (emphasis added) “the evidence establishes that by reason of U.S. Credit’s actions, the loan proceeds, loans, and loan portfolios and moneys in which First & Peoples Bank and Georgia’s Own have interests and ownership are in imminent and immediate danger of being wrongfully utilized, assigned, dissipated, and/or converted by the actions of U.S. Credit, thereby creating an imminent risk of irreparable harm to First & Peoples Bank and Georgia’s Own.”
The judge further found that U.S. Credit had failed to meet its contractual and fiduciary obligations to First & Peoples and Georgia’s Own by (emphasis added) “utilizing assets and moneys owed to First & Peoples Bank and Georgia’s Own for other purposes, failing to properly secure and protect the assets and funds of First & Peoples Bank and Georgia’s Own, commingling assets and funds belonging to First & Peoples Bank, Georgia’s Own, and potentially others, failing to keep accurate records of accounts and otherwise, and otherwise being managed and/or operated in a way that creates a significant and intolerable risks that the Assets will be dissipated, converted, and/or otherwise lost in the immediate future.”
The judge ruled in favor of First & Peoples and Georgia’s Own and appointed American Fiduciary Services as receiver.
But the matter didn’t end there.
On December 29th, 2023, U.S. Credit filed suit in Massachusetts Superior Court, in a case that was ultimately removed to US District Court, challenging the appointment of a receiver, arguing the company had no assets in Kentucky and that it was deprived of both substantive and procedural due process.
The action was ultimately rendered moot, when U.S. Credit filed for Chapter 11 bankruptcy protection in mid-January 2024.
Ultimately, U.S. Credit’s management team, including CEO Galvin, were supplanted by the appointment of a Chapter 11 trustee at the end of February. The bankruptcy case remains in progress as of mid-October 2024.
Excessive Charge-Offs When U.S. Credit Promises “Everyone Is Approved” For Up To $750
The legal disputes with First & Peoples and Georgia’s Own aren’t the only challenges U.S. Credit has faced.
One of U.S. Credit’s key distribution partners, iService, filed an arbitration claim against it less than a year and a half into their partnership.
iService, now known as DealerBuilt, offers a technology platform for auto dealers, including capabilities for managing customer communications, generating quotes, and accepting payments. According to its site, the company works with over 500 auto dealerships across the United States.
iService entered into an agreement with U.S. Credit in April 2021, in which iService’s dealers could offer U.S. Credit’s financing products, including those originated through its bank partners, to the auto dealers’ customers.
According to a filing by iService in U.S. Credit’s bankruptcy case, U.S. Credit represented to iService that “it was the lender and funding source of the loan products” made available to end users through iService’s dealers and, iService argues, intentionally omitted that it worked with multiple bank partners to originate and fund the loans.
Per the original agreement between the companies, U.S. Credit would make available three distinct products: a 4-month “no credit check” loan of up to $750 and two larger, longer-term interest-bearing products.
It was issues with the “no credit check” product that ultimately led iService to file an arbitration claim against U.S. Credit.
The contract between U.S. Credit and iService explicitly acknowledged that the “positioning and promotion of the product offering” would be “critical to success,” and gave an example of such messaging that emphasized that “Everyone is approved up to $750.00*” —
By July 2022, U.S. Credit “unilaterally and without advance notice” halted the “no credit check” product, telling iService that “there was an ‘excessive default’ rate by the individuals taking these loans,” despite the companies’ contract not having terms governing maximum acceptable default rates, iService says.
U.S. Credit lacked the authority to unilaterally cease offering the product, iService argued in its arbitration claim and in a filing in the bankruptcy case, and did so, not due to the high rate of default, but because of challenges with its “concealed” lending partners stemming from the $3.1 million cyber theft from sub-servicer ZuntaFi.
In its adversary complaint in U.S. Credit’s bankruptcy case, iService argues U.S. Credit “engaged in a course of conduct amounting to fraud/defalcation while acting in a fiduciary capacity” and “willfully and maliciously” caused injury to iService, including through its actions around the “no credit check” loan offering.
iService is seeking damages of approximately $5.9 million as part of the bankruptcy case.
First & Peoples, Thread Both Facing Regulatory Repercussions
First & Peoples’ challenges managing its third-party partnership with U.S. Credit and the risks it poses to the bank’s safety and soundness haven’t gone unnoticed by its regulators.
In December 2023, First & Peoples entered into a consent order with its primary federal regulator, the FDIC, and its state regulator, the Kentucky Department of Financial Institutions.
While the consent order does not specifically name U.S. Credit, it does address the bank’s “third-party loan program” at length.
Among other requirements, the consent order mandates that First & Peoples (emphasis added throughout):
“develop and implement a written plan to recover losses resulting from the Bank’s relationship with the third-party loan program referenced in the Report of Examination dated April 17, 2023 (‘ROE’),” including legal and collections strategies it plans to pursue.
“reduce the Bank’s risk position in the third-party loan program referenced in the ROE.”
not grant “additional extensions of credit through, or advances of interest accrued but not paid to, adversely classified or criticized loans related to third-party loan program referenced in the ROE,” prohibiting the bank from engaging in what is sometimes known as “extend and pretend.”
Board of Directors “increase its participation in the Bank’s affairs to include monthly review of management’s legal and collection efforts relating to the third-party loan programs referenced in the ROE.”
“contact loan servicers for the third-party loan programs referenced in the ROE and directly obtain servicer reports with loan level information, including delinquency and other relevant risk metrics, on all the loan pools of the third-party loan programs referenced in the ROE. Until these reports are obtained directly from loan servicers, management must develop procedures to review for discrepancies in the reports obtained from the third-party loan programs.”
maintain a minimum leverage ratio of 10% and a total capital ratio of 12%, should the bank fall below the Community Bank Leverage Ratio minimum, thereby requiring the calculation and reporting of the total capital ratio.
not declare or pay a dividend without prior written approval.
“shall have and retain qualified management,” which the Board shall ensure “is provided all necessary written authority and resources to implement the provisions of” the consent order.
shall develop “a written plan addressing liquidity and asset/liability management, including implementing corrective action relating to weaknesses in funds management and interest rate risk management practices identified in the ROE.”
Board of Directors “shall review the adequacy of the Bank’s allowance for credit losses (“ACL”), provide for an adequate ACL, and thereafter maintain and accurately report the same,” including by reviewing and updating “credit risk metrics and loss data for the third-party loan programs referenced in the ROE and ensure appropriate provisions to the ACL relative to this information.”
formulate and submit for review and comment “a written profit plan and a realistic, comprehensive budget for all categories of income and expense for calendar year 2024.”
Board of Directors “must ensure that the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) Program is reasonably designed to assure and monitor the Bank’s compliance with the BSA and provides clear and up-to-date guidance to Bank staff,” including sufficient due diligence and ongoing monitoring of third parties who complete AML/CFT responsibilities on the bank’s behalf.
Board of Directors “should ensure compliance with Customer Identification Program regulations for third party-originated accounts, including obtaining full name from customers at account opening, and review all existing third party-originated accounts to identify instances where information required under CIP regulations was not obtained at account opening.”
About three months later, First & Peoples’ holding company, First & Peoples Bancshares, entered into a written agreement with Federal Reserve, which regulates bank holding companies.
That agreement requires the holding company to:
“serve as a source of strength to the Bank, including, but not limited to, taking steps to ensure that the Bank complies with the Consent Order entered into with the FDIC and the KDFI on December 28, 2023, and any other supervisory action taken by the Bank’s federal or state regulator.”
submit a cash flow projection to the Federal Reserve.
submit a written capital plan to the Federal Reserve, including an assessment of the adequacy of the bank’s capital, an action plan to raise additional capital or other steps to improve the financial condition of the bank, and an enhanced capital contingency plan to address the bank’s short- and long-term capital needs.
not declare or pay dividends, engage in share repurchases, or otherwise make capital distributions.
not incur, increase, prepay, or guarantee debt without the Federal Reserve’s prior approval.
Thread Bank also recently entered into a consent order with its primary federal regulator, the FDIC, stemming from its banking-as-a-service and “Loan-as-a-Service” programs — though Thread had a significantly larger fintech partner program, including working with middleware intermediary Unit, and it is not clear to what extent, if any, the U.S. Credit relationship contributed to the enforcement action.
As Fintech Business Weekly covered when that order was first released, some of the key elements it contains include:
the Board shall review and approve risk tolerance thresholds for individual financial technology (“FinTech”) partners based on an enterprise-wide financial analysis of each FinTech partner’s financial projections under expected and adverse scenarios.
strategies to maintain internal controls; and support for Anti-Money Laundering/Countering the Funding of Terrorism (“AML/CFT”) program compliance.
the Board shall update the Bank’s Enterprise Risk Management Framework to address examination findings and recommendations.
in regard to the Bank’s BaaS Program business line, the third party risk management program shall address the level of risk and complexity of the Bank’s FinTech partners, and shall confirm, at a minimum:
Appropriate policies and procedures are in place to ensure that risks are properly identified, measured, monitored, and controlled;
A documented customer due diligence process is implemented to establish a customer profile and expected customer activity;
Information systems associated with FinTech partners provide timely and accurate information;
Information required for the CIP is readily available;
A process to ensure third-party partners are meeting the requirements of the Bank’s AML/CFT program and policies;
the Bank’s BaaS and LaaS program policies and procedures should be thoroughly and completely documented, addressing, at a minimum, third party partner and customer approval requirements, due diligence processes, growth and stress modeling, ongoing AML/CFT compliance monitoring, and steps to unwind third-party business lines, including FinTech partners, within 120 days of the order.
The BSA/AML, due diligence, and third- (and fourth- and fifth-) party risk management have been recurring themes in the numerous enforcement actions against partner banks.
In the case of U.S. Credit, there seem to have been ample warning signs that the banks it partnered with didn’t heed or weren’t aware of.
For example, U.S. Credit’s CEO Galvin and his previous firm, Education Investment Company, were sued by Transportation Alliance Bank (TAB) in 2014, with the bank alleging Galvin and the company breached their agreement with TAB by transferring loan collateral to third parties without notifying TAB or obtaining a release of TAB’s lien on said collateral.
TAB sought approximately $3.5 million plus fees, interest, attorneys’ fees and costs in the case; TAB was ultimately awarded about $427,000 plus interest and reasonable attorneys’ fees.
It also appears that U.S. Credit’s CEO, Stephen J. Galvin, may have filed for personal bankruptcy protection in 1998, though it couldn’t immediately be confirmed that the Massachusetts case was the same Stephen J. Galvin.
It’s unclear to what extent, if at all, First & Peoples and Thread Bank oversaw the merchants through which U.S. Credit originated loans on their behalves. iService, the auto dealer platform, in turn partnered with more than 500 dealerships to offer loans through U.S. Credit and its underlying partner banks.
In addition to iService, U.S. Credit worked with MotoLease, which originates indirect lease contracts through a network of over 1,000 new and used powersport dealers across the United States, which sell and lease equipment like motorcycles, four wheelers, jet skis, and snowmobiles.
U.S. Credit also partnered with Metroplex Trading Company, doing business as “GrabAGun,” to offer financing for the purchase of firearms and related equipment, which the company branded as “Shoot Now Pay Later®”
In response to questions sent via email, Thread Bank clarified that it has “never originated or funded loans through ‘GrabAGun’ or for the purchase of firearms.”
It couldn’t immediately be determined what role, if any, First & Peoples, Connexus, or Georgia’s Own had in originating or funding the so-called “Shoot Now Pay Later” loans.
First & Peoples didn’t respond to questions about what due diligence, if any, it conducted on U.S. Credit and its CEO, Stephen Galvin, to what extent, if any, it reviewed the merchants through which U.S. Credit offered loans, or if the bank had originated or funded loans for the purchase of firearms or related equipment.
Regarding its due diligence process, Thread Bank’s Chief Banking Officer, John Bearden, told Fintech Business Weekly via email, “At Thread Bank, we have a rigorous due diligence, vendor risk management, and underwriting process for all of our partners, in compliance.”
Financial Fallout For First & Peoples Could Be Catastrophic
The implications of First & Peoples ill-fated partnership with U.S. Credit go well beyond the two enforcement actions.
Prior to entering into its partnership with U.S. Credit, First & Peoples was profitable, posting about $1.3 million in net income in 2019 — though its return on equity was an anemic 3.4% that year, compared to 10.43% for peer-group banks, defined as banks with between $100 million and $300 million in assets with three or more branches located outside of a major metropolitan area.
Indeed, First & Peoples’ low profitability may have been part of the motivation to pursue the lending partnership with U.S. Credit.
But, as it has struggled to manage the fallout of the disastrous partnership, First & Peoples has seen its total bank equity capital decline from about $37.9 million at the end of 2019 to $14.9 million as of its Q2 2024 call report filing; in the same timespan, its leverage ratio has declined from 19.4675% to 9.9876% — notably, below the 10% required by its consent order.
First & Peoples is also carrying an outsized proportion of non-performing assets.
In its most recent call report, the bank reported $25.785 million of loans and leases on non-accrual and an additional $275,000 of loans and leases 90 days or more past due — making more than 12% of the bank’s total assets impaired, compared to just 0.40% for its peer group, or about 30 times higher.
The nearly $26 million in non-performing assets is on top of charging off about $18 million in defaulted loans in 2022 and 2023, the majority of which were originated by U.S. Credit.
At the end of 2019, which was prior to entering into its partnership with U.S. Credit, First & Peoples reported just $1.245 million of loans and leases in non-accrual or 90 days or more past due, equivalent to about 0.6% of its assets at the time.
First & Peoples “Texas Ratio,” which measures non-performing assets as a percent of tangible common equity plus loan loss reserves, jumped from around 3% prior to its partnership with U.S. Credit to 127% as of the bank’s Q2 2024 call report filing.
A Texas Ratio above 100% is correlated with bank failure, as it indicates that the amount of non-performing assets exceeds a bank’s loan loss reserves and tangible common equity.
Representatives for First & Peoples did not respond to questions and a request for comment, but the bank did make a public statement regarding these issues following media reports earlier this year.
The statement, from the bank’s President, William Buffin “Buff” Clarke, says in part (spacing adjusted for readability):
“On August 19, 2024, it was recklessly reported by the Financial Times, a European publication, that First & Peoples Bank and Trust Company is on the brink of insolvency due to its alleged potential inability to recover the full value of a set of consumer loans…
First & Peoples is taking every action to recover on these loans, and its customers’ assets are not in jeopardy. Over the past few years, First & Peoples has partnered with several third parties to supplement local loan demand, many of which were successful.
However, due to a number of concerns, in 2022, we began distancing ourselves from one of these third parties (U.S. Credit, Inc.), and took action to hold them accountable.
While U.S. Credit has caused some losses on loans, First & Peoples has not put our depositors at risk. Over a year ago, in the ordinary course of business, the FDIC confirmed the Bank’s concerns that a specific set of loans were potentially at risk. At that time, we took strong, affirmative, and effective action to address and remediate any adverse effects of these loans. We have been working tirelessly, hand in hand with regulators, outside counsel, and others, to minimize potential losses…
In January 2024, U.S. Credit filed bankruptcy. Since that time, we have continued our extensive efforts to maximize our recovery from these assets, while at the same time continuing our century-long record of providing this community with first class service, security, and return on investment…
We have fought to remove U.S. Credit from its position handling these loan proceeds, and now that U.S. Credit is fully removed and a Trustee has replaced U.S. Credit – that Trustee is working to see that the loan proceeds are getting to the rightful owners, including First & Peoples.”
Given its small size, First & Peoples hardly poses a systemic risk, but its still-unfinished story adds another data point to the risks associated with “complex, technology-driven partnerships” and the increasingly byzantine “supply chain” in consumer banking that federal bank regulators have recently set their sights on.
Representatives for First & Peoples Bank and Trust, U.S. Credit, and Stephen J. Galvin didn’t respond to questions and requests for comment on this matter.
Other Good Reads & Listens
Modernizing the Regulatory Framework for Domestic Payments (Treasury Under Secretary for Domestic Finance Nellie Liang)
How Safe Is Your Money in a Fintech, Really? (Bloomberg)
Why Walmart is doing Pay by Bank (Fintech Brainfood)
Pathward Financial Exec on How To Do Banking as a Service (FinXTech)
Listen: Do Regulators Want to Kill Banking-as-a-Service? (Banking with Interest)
About Fintech Business Weekly
Looking to work with me in any of the following areas? Email me.
Pre-order my book, Banking as a Service: Opportunities, Challenges and Risks of New Banking Business Models, here
Vendor, partner & investment opportunity advice and due diligence
Fintech advising & consulting
Sponsoring this newsletter
News tip or story suggestion — reach me on Signal at +1-316-512-1571