A lot of founders I talk to are worried about what will happen with AI. So am I frankly. But they're actually better off than anyone else. If the world is going to get turned upside down, the safest place to be is in a small, fast-moving company that can easily change direction.
It’s officially the best time of year. People are fresh coming out of the summer heat, fall is in the air.
More time to focus and build even more awesome stuff with passionate people.
Wonder if only there was a solution to this... @blanc_hq "Periodically review every vendor or fintech partner that supplies BSA functions (KYC, monitoring, case management, etc.) and review internal staffing head count and skills to ensure that they are sufficient"
News from BaaS Island!
Hatch Bank, a California-chartered BaaS sponsor bank with $118 million in assets, has entered into a consent order with the California Department of Financial Protection & Innovation.
Hatch was founded in 1982 in San Diego as Rancho Santa Fe Thrift and Loan. In 2018, the board made the decision to pivot into BaaS, and the bank rebranded as Hatch in 2019.
Hatch's most notable fintech partners are Wisetack (which it still works with today) and HMBradley (which it worked with between 2020 and 2022). You may recall that HMBradley was forced to stop taking on new accounts in 2021 because Hatch was unable to accommodate the neobank's rapid growth. HMBradley eventually moved from Hatch to New York Community Bank.
The California DFPI consent order is the result of a March 4 2024 exam (FDIC + DFPI), which found unsafe/unsound practices and BSA-AML violations tied to Hatch’s third-party-fintech business model.
Among other things, the consent order requires the bank to:
- Redo its written enterprise money laundering and terrorist financing risk assessment so it accurately reflects the bank's fintech partners, customer types, volumes, and geographies. This must be done within 60 days.
- Write or overhaul policies for: internal controls, alert review & SAR process, customer due diligence, transaction-monitoring model validations, and staffing adequacy reviews. This must be done within 90 days.
- Periodically review every vendor or fintech partner that supplies BSA functions (KYC, monitoring, case management, etc.) and review internal staffing head count and skills to ensure that they are sufficient to meet the compliance and risk management needs of the bank based on projected partner and transaction growth.
- Obtain written approval from the California DFPI before engaging in any new lines of business or establishing any new branches or other offices.
For the most part, the Hatch Bank consent order is consistent with the orders that other BaaS sponsor banks have entered into with regulators over the last couple of years (correct BSA/AML deficiencies, increase board oversight, etc.)
From what I can tell, the big differences with this one are, A.) the timelines (60 days for the risk assessment and 90 days for the full BSA/AML program is fast, relative to other orders), and B.) the California DFPI taking the lead.
That last point is worth emphasizing. Consent orders for state-chartered BaaS banks are usually issued jointly by federal regulators (either the Fed or the FDIC) and state regulators. This is the first one that I have seen issued solely by a state. Perhaps a parallel order is forthcoming from the FDIC, but if not, it may indicate that the states (particularly California and New York) are preparing to take on more of a leading role in supervision and enforcement over the next four years.
As for Hatch Bank, I'm guessing 2025 will be a year of remediation and strategic reevaluation. It's worth noting that the executive who led the transformation of Hatch into BaaS sponsor bank (Jer Wood) left in January of 2024 and is now the head of lending strategy, partnerships, and operations at Cash App.
@ammarz Check out Pi compression algorithm. You can theoretically compress any file to two numbers, the index of the file sequence in Pi and the length of that sequence. Just a fun theory.
وبعد مشوار طويل وممتع نكمل مشوار جديد وشيق. تم الاستحواذ على شركتي روجر من قبل فليت كور احد اكبر الشركات فب عالم التقنية المالية. سعيد جداً بهذا الانجاز وشاكر لكل من شاركني الرحلة. القادم اجمل! ❤️
https://t.co/tLsT714D8U