Rick Dupree

Navigating the complex risk & compliance landscape 1 risk / 1 reg / 1 day at a time. #risk #compliance #grc #tech #fintech #regtech #banking #advisor

[Nik @NikMilanovic]

When all you have is a hammer (@twifintech 6/28)

https://t.co/kOM6LvF7AK

In my fintech career, I’m fortunate to have met with teams at the CFPB, the OCC, the FDIC, the FTC, and the SF and NY Federal Reserve Banks, mostly in the context of cashflow underwriting and consumer credit access.

Something universal about the regulators I met with was that they were thoughtful, well-informed, level-headed, and curious to learn.

They wanted to understand how to facilitate the delivery of better, more customer-aligned financial products, without forfeiting their responsibilities to consumer protection (or safety and soundness, oversight and examination, etc.) They understood that banking, like many industries, was improved through competition and innovation, and that those improvements ultimately benefited the end-users.

But they were also clear-eyed about the emergence of bad actors, regulatory arbitrage, controls failures, poor policies and procedures, and fraud in a nascent ecosystem like fintech.

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This week, compliance, internal controls, security and data storage practices, and customer fund management are back in the spotlight thanks to the ongoing meltdown of BaaS provider Synapse and the related hack of its banking partner Evolve, both of which have been well-covered by Jason at Fintech Business Weekly.

These two failures have breathed new life into the 'never fintech' crowd, who've called from the sidelines for years for fintech to be banned. Strangely, Equifax's 147 million customer data breach and the continual cycle of bank data breaches didn't lead the same crowd to cry breathlessly for the end of credit-scoring or the end of banking.

But the 'never fintech' crowd are not founders, they are not investors, and – fortunately – they are not regulators.

Regulators have a variety of tools at their disposal. Two of the most frequent ones you'll hear about are (1) rulemaking and (2) enforcement. Rulemaking concerns the development of guidelines for how financial products can be built and offered (such as the current open banking rulemaking process at the CFPB). Enforecement concerns the punishment of bad actors for failures or willful breaches of those rules.

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The question at-hand for the prudential regulators has always been how to rulemake in a way that counterbalances innovation and safety. I expect the Evolve and Synapse news to lead to enforcement actions both parties. I wouldn't be surprised if their controls failures also lead to expanded rulemaking about commingling of customer funds and data tokenization in storage and transmission.

I don't expect these two failures – as significant as they are – to lead to a 'regulatory ban' on fintech.

Bad practices need to be exposed, rules need to be refreshed, and consumers need to be protected from predatory and poorly-managed financial services providers in the digital age. But fintech has as much nuance as any other industry: just as there are bad actors in banking, so there are bad actors in fintech, and an all-or-nothing approach to rulemaking and enforcement doesn’t recognize nuance.

The 'never fintech' crowd must be incredibly cynical to look at examples like Nubank or Mpesa or Stripe and not see the millions and millions of people made better-off by well-run fintech companies.

I’m hopeful that we’ll continue to punish bad actors in fintech while rulemaking in a way that allows the good ones to flourish. When innovation and safety are well-balanced, it's the financial consumers who win in the long-run.

https://t.co/kOM6LvF7AK

[Rick Dupree @RickTheRiskGuy]

@wolfejosh @peterjhebert What a great post and then-and-now pic. And wtf is his anti-aging secret? 🤔

[OpenAI @OpenAI]

Code Interpreter will be available to all ChatGPT Plus users over the next week.

It lets ChatGPT run code, optionally with access to files you've uploaded. You can ask ChatGPT to analyze data, create charts, edit files, perform math, etc.

Plus users can opt in via settings.

[Bilal Zuberi // Red Glass Ventures @bznotes]

Proud of my partner @Farshchi, and portfolio founder @ClemDelangue of @huggingface, who are giving testimony in front of the House Science, Space and Technology Committee today on how the federal government can promote and support AI innovation to advance national interests. 👊🏽🇺🇸

[Rick Dupree @RickTheRiskGuy]

@bznotes Probably. I learned to drive on a stick. You don’t see much of that anymore.

[Rick Dupree @RickTheRiskGuy]

@immad Exercise and a sleep schedule aligned to the current timezone

[Rick Dupree @RickTheRiskGuy]

@sm Couldn’t agree more!!

[Rick Dupree @RickTheRiskGuy]

@immad Ty. Thought it was me. 😜

[Rick Dupree @RickTheRiskGuy]

@NikMilanovic So true. I made it a practice to learn at least a min amt of conversational language when visiting a foreign country (personally or professionally) where English is not first language. Prepping for first trip to Netherlands was def most challenging.

[Sara Mauskopf @sm]

Basically an influencer (1 view)

[Rick Dupree @RickTheRiskGuy]

@sm 👏👏👏❤️❤️❤️

[Andrew Yeung @andruyeung]

NYC product, engineering & tech leaders—where you at?

I’m hosting a curated event on March 23.

It’s at a penthouse with stunning views. Delicious cocktails. Light bites. Great music.

👉 Engage for details!

[Rick Dupree @RickTheRiskGuy]

@zachcoelius 👏👏👏

[Rick Dupree @RickTheRiskGuy]

@bznotes 👏👏👏

[Aaron Levie @levie]

ChatGPT has now successfully passed a Wharton MBA exam. Sure, this isn’t the hardest problem, but to execute it in 1 second is the breakthrough.

[Rick Dupree @RickTheRiskGuy]

@jrichlive So been there!!

[Rick Dupree @RickTheRiskGuy]

@sammaule @philballen @PetBerisha @Adamd8 @JeffTijssen @sytaylor I loved these. Had a pair just like these.

[Rick Dupree @RickTheRiskGuy]

Wow is right…

[Simon Taylor @sytaylor]

... wow

[compliance.ai @compliance_ai]

An expert at Risk & Compliance, @RickTheRiskGuy gives us his insights on upcoming regulatory trends. Find out more about subject matter expert advisor #RickDupree in his interview with our team here: https://t.co/2kbtcLAHvL

[Kate Levchuk @KateGoesTech]

Met a girl from Donetsk this evening

Beautiful, young Ukrainian girl, been in London for a week only

Russian speaker from Donbas. 8 Years of never ending propaganda... I didn't know what to expect

But then she told me:

🧵