N/A — Industry Guidance
In 2025, OCC leadership publicly expressed support for bank-fintech partnerships while emphasizing that risk management must remain a core priority for supervised institutions. The OCC's supervisory stance reflected a balance between encouraging innovation and maintaining safety and soundness standards. Monthly regulatory reviews through mid-2025 highlight ongoing OCC scrutiny of fintech arrangements, with expectations for enhanced due diligence, independent testing, real-time monitoring, and clear exit strategies from sponsor banks. The guidance signals a potential regulatory 'settling' period where enforcement gives way to proactive compliance framework requirements.
Verified from source: The OCC's Financial Technology page lists NR 2025-51 dated 06/03/2025, where the Acting Comptroller of the Currency discusses the regulatory agenda, consistent with OCC leadership expressing support for bank-fintech partnerships while prioritizing risk management. The page also documents ongoing OCC scrutiny of bank-fintech arrangements and third-party risk management.
- May signal a more predictable regulatory environment for compliant BaaS banks
- OCC support for partnerships could encourage new entrants with strong compliance programs
- Ongoing scrutiny means sponsor banks cannot relax compliance efforts despite supportive rhetoric
- OfficialOCC News Release
- OfficialOCC Financial Technology
- NewsForvis Mazars
- NewsGibson Dunn