Fintech · Industry brief

The FDIC has proposed a new certification program called RAMP (Risk-Assessed, Manageable Partnerships) to help community banks evaluate fintech partners more efficiently. Under the draft term sheet circulated on July 21, 2026, independent assessors would evaluate fintech solutions against common standards through a banking innovation standards development organization (BISDO), with certificates usable across multiple banks. However, the certification addresses only entity-level and solution-level risks, not relationship-level risks specific to each bank-fintech partnership, creating potential gaps in oversight. The article warns that despite disclaimers, banks under resource constraints may treat the certificate as broader partnership endorsement, and systemic risk could increase if multiple community banks adopt the same certified fintech and experience simultaneous disruption. The author recommends RAMP standardize recurring relationship-level questions (such as balance reconciliation protocols and exception handling) that each bank-fintech pair would complete independently, with examiners verifying the assessment was conducted rather than certifying the partnership itself.

Fintechs are increasingly acquiring community financial institutions to gain banking charters, deposits, and infrastructure faster than building from scratch. Recent examples include SmartBiz's 2025 acquisition of $148MM-asset CenTrust Bank to expand small-business lending, Increase's acquisition of Twin City Bancorp ($70MM assets) relaunched as Increase Bank, and OppFi's June agreement to acquire BNCCORP ($1.1B assets) for a national bank charter and deposit base. CFIs with strong deposit franchises, established lending relationships, and sound compliance records are most attractive to fintech buyers seeking to complement their technology capabilities with regulated banking infrastructure. For CFIs considering fintech acquisition interest, risks include potential loss of control over institutional mission, integration challenges across core systems and compliance processes, regulatory pressure on risk management, and employee and customer disruption from changes to branch strategy and product offerings. Management should assess strategic value, consider alternatives beyond acquisition, identify operational weaknesses, and strengthen deposit franchises and technology capabilities regardless of transaction plans.

The Federal Reserve Board requested public comment on two proposed rules implementing regulatory responsibilities for payment stablecoin issuance under the GENIUS Act. The first proposal establishes substantive framework for FRB-supervised issuers and custodians, covering permissible and prohibited activities, reserve requirements, redemption timelines, disclosure obligations, reporting and audit requirements, capital standards, and anti-tying prohibitions. The second tailored proposal establishes an application process for insured state member banks seeking FRB approval to issue stablecoins through subsidiaries, with 30-day completeness review and 120-day decision timelines. The FRB has coordinated these rulemakings with parallel OCC and FDIC rulemakings and invited extensive comment on reserve diversification limits, multi-brand structures, and real-time reporting, with the 60-day comment period beginning after Federal Register publication (Federal Reserve Board, September 24, 2026). The Conference of State Bank Supervisors released a supervisory resource framework to help state examiners assess artificial intelligence use and risks at state-chartered banks and nonbank financial institutions. The principles-based, scalable framework consists of five components including a Core Examiner Guide, Examiner Work Program, Nonbank AI Supplements, optional AI Use Case Risk Tiering Worksheet with three risk tiers, and Source Support Document, drawing on established resources from NIST, the Cyber Risk Institute, and Treasury. Adoption is discretionary by each state regulatory agency, so institutions operating across multiple states should expect variation in examiner application (Conference of State Bank Supervisors, September 16, 2026).