Defining Roles & Responsibilities in BaaS
Updated: Oct 20, 2022
Members of Alloy Labs, in partnership with leading technology providers, have released new industry standards for Roles and Responsibilities in Banking as a Service partnerships.
Banking as a Service (“BaaS”) as a business model has been around for over a decade. The industry, however, is still early in its evolution. Many Alloy Labs member banks were early leaders in the movement and are actively working to mature the industry through its BaaS Center of Excellence. The group released a BaaS nomenclature guide to standardize the definition of many buzzwords last May.
Today, the group releases standards for Roles and Responsibilities in building these partnerships. Like the nomenclature guide, these standards are the result of months of collaboration between leading players in the space and industry compliance experts.
“Clarifying roles and responsibilities in the BaaS partnership model helps solidify compliance and increase efficiency. With this guide, banks and fintechs can fulfill their unified mission: to provide access to funds and financial resources for those who need it most.” Laura Wildenborg, Fintech Innovation Manager at Sunrise Banks states.
“BaaS providers leverage different paradigms as it relates to roles and responsibilities for regulatory compliance" said Treasury Prime's Associate General Counsel, VP of Compliance, Sheetal Parikh. "Treasury Prime's philosophy supports a paradigm that allows bank partners to always control the regulatory levers while engaging and empowering fintech and enterprise partners to have a seat at the table.” As an example, Treasury Prime focuses purely on technology and the bank is responsible for compliance oversight.
"a great enabler of financial inclusion"
“Banking-as-a-service is experiencing massive growth as the industry evolves to recognize technology as a great enabler of financial inclusion,” stated Phil Goldfeder, SVP of Global Public Affairs at Cross River. “There’s an opportunity to create an inclusive financial system that works for every consumer with a standard framework around compliance and defined responsibilities. As a pioneering leader in the space, Cross River is thrilled to be a part of this industry-wide initiative that will continue to bring responsible innovation and financial access to underserved communities.”
“Bringing innovative products and services to customers that are not well served by mainstream banks was an essential part of our BaaS strategy,” continued Curt Queyrouze, President of Coastal Financial Corporation, “innovation is essential to powering inclusion.”
“Compliance, fraud, and the safety and soundness of the industry are areas where collaboration is much more effective than competition. Our members want to continue leading the industry forward.” added Jason Henrichs, CEO of the Alloy Labs Alliance, the consortium of banks who are spearheading the efforts.
The best practice includes definitions for 37 roles and responsibilities that serve as a framework for banks, startups and middleware providers to build their relationships. “Working together is critical to preserve the safety and soundness of the financial system, provide fair customer outcomes and promote responsible innovation.” Said Clayton Mitchell, Managing Principal Fintech at Crowe.
Alloy Labs has made the Banking-as-a-Service Roles & Responsibilities Playbook available as a free download here.
The Roles & Responsibilities document is for guidance only and each organization is responsible for compliance with all applicable state and federal regulations. Roles and Responsibilities may vary depending on the nature of the partnerships and services provided. Users of this guide are encouraged to seek professional guidance.