Fintech Regulatory Update: Bank Service Company Act, AML, Cyber Incident Reporting

A live 90-minute premium CLE video webinar with interactive Q&A

Tuesday, December 7, 2021 (Tomorrow)

1:00pm-2:30pm EST, 10:00am-11:30am PST

or call 1-800-926-7926
Course Materials

This CLE webinar will examine the regulatory framework that banks and fintech companies must contend with when banks outsource critical banking services to fintech. The panel discussion will include the Bank Service Company Act (BSCA), AML compliance, new proposed regulations regarding disclosure of cybersecurity incidents, and other issues.


As banks increasingly outsource traditional banking functions to financial technology companies (fintechs), regulators scrutinize these relationships. Fintechs must prepare to contend with AML compliance, cybersecurity incident reporting, and other banking regulations as their client banks do.

Under the BSCA, banks must notify regulators of contracts with fintechs that provide a wide range of services, including bookkeeping, accounting, data processing, payment processing, and mobile banking services. Section 7(c) of the BSCA subjects a service provider's performance of services to the same regulatory scrutiny as a bank performing similar services.

Bank regulators recently updated existing guidance to promote consistency among the agencies' guidance on third-party risk management and have issued guidance designed to help community banks exercise proper due diligence of fintechs they engage. They have also proposed a rule that would require a bank to provide prompt notification of any computer-security incident affecting the bank or any fintechs providing services on behalf of the bank.

Listen as our authoritative panel discusses the current regulatory and compliance issues counsel should consider when fintech provides banking services.



  1. The increasing role of fintechs in providing banking services
  2. Bank reporting obligations when outsourcing banking services
  3. Fintech compliance and reporting obligations under the BSCA
  4. Other regulations applicable to fintech companies


The panel will review these and other critical issues:

  • What kinds of banking services are being provided by fintechs, and why are they of particular concern to regulators?
  • What are the reporting obligations of a regulated bank under the BSCA? Do fintechs receive notice?
  • Per recent guidance, what are best practices for banks conducting due diligence on prospective fintech providers?
  • What are reporting obligations in the event of a cyber incident affecting a fintech providing services for the bank? Who is obligated to report an incident?


Maalouf, Khalil
Khalil N. Maalouf

Skadden Arps Slate Meagher & Flom

Mr. Maalouf is active in the areas of banking regulation, supervision and enforcement, and has represented clients on...  |  Read More

Nunn, Robin
Robin Nunn

Morgan, Lewis & Bockius

Ms. Nunn is Co-Leader of the firm’s Banking Industry Team. Her practice focuses on complex civil litigation,...  |  Read More

Attend on December 7

Cannot Attend December 7?

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video