The Consumer Financial Protection Bureau recently issued a request for information to better understand the benefits and risks associated with new financial services that rely on access to consumer financial accounts and accountrelated information.9 In addition to the risks I have outlined that are specific to new financial technologies, firms also must control for risks that have always been present, even in brick-and-mortar financial institutions.
For example, risks around the BSA and Anti-Money Laundering rules cut across all segments and all portfolios. Similarly, firms must monitor credit and liquidity risks of loans acquired or processed via fintech platforms, especially given that these products have not been tested over an economic cycle.