Banks and their Fintech Partners: Who Will Regulators Hold Accountable?
Author: Stephen T. Middlebrook.
Source: Volume 34, Number 08, August 2018 , pp.97-100(4)
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Abstract:
The author discusses recent enforcement actions involving banks and their Fintech partners. He finds that regulators have exercised discretion as to whom to charge based on a variety of factors, have apportioned civil money penalties among the parties, and have used the amorphous UDAAP as a basis for charges.Keywords: CFPB Enforcement Actions; In re UniRush LLC; In re Bank of Lake Mills; In re Conduent Business Services, LLC
Affiliations:
1: Womble Bond Dickinson (US) LLP.