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Special Episode — Back By Popular Demand: Fintech’s Getting Spicy

Breaking Banks

CHAPTER

The Drawbacks of Using the Language Deposits in Banking

I worry that we're in this gold rush and banks are going to be signing up to participate in banking as a service without understanding that at the end of the day, the regulator knocks on your door. I'm hopeful that with maybe a little encouragement from regulators, we'll get some new guidance around. But I want the CFPB to jump into this because when we think about what is UDAAP, what are UDAAP violations? It all sort of fundamentally comes down to what words did you use and why did you use them?"

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