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Who’s been toughest on fintech partner banks recently - the OCC, Federal Reserve, or FDIC?

After several inbound requests regarding this LinkedIn post, we decided to make the data easier to find with this blog post. It’s no secret our federal banking regulators have been directing a spectacular level of enforcement attention at fintech partner banks in recent quarters.  But are some worse than others? 

The charts below summarize recent formal enforcement actions by primary federal regulator for the period 1Q23-1Q24.  They show that if you were a fintech partner bank, your odds of getting tagged with a formal enforcement action over the past five quarters were:

  • 15% if your primary federal regulator was the FDIC

  • 10% if the OCC regulated you

  • 9% if the Federal Reserve was your regulator

We arrive at these calculations based on an estimated 149 partner banks (68 state non-member, 33 state member, and 48 national) and 4406 non-partner banks.

By comparison, if you weren’t a fintech partner bank, your odds of drawing a formal order during the same time period were just 1.8%.

If you’d like to chat about this data or anything related to innovation, regulation, remediation, or other associated topics, shoot us a note:


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