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TPRM/Vendor Management

Shaping Policy So Community Banks Can Innovate

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ICBA Expert Contact

Michael Emancipator

Senior Vice President, Regulatory Counsel

ICBA

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Ensure a Level Playing Field

As banks and fintechs increasingly collaborate to deliver accessible, efficient, and inclusive financial products, it is essential that lawmakers and regulators adopt policies that both recognize the benefits of fintech partnerships and address emerging risks.

ICBA policy recommendations would achieve those policies by:

Reinstituting frequently asked questions as an addendum to the guidance.

Utilizing dormant authority provided under the Bank Service Company Act.

Modernizing CSI rules and guidance to engage the full compliance ecosystem without expanding the regulatory perimeter.

Periodically publishing supervisory highlights.

Permitting and acknowledging the use of shared due diligence and standard setting organizations that leverage economies of scale. 

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