Suggestions
Jonah Crane
Partner at Klaros Group, an advisory and investment firm focused on the future of financial services
Jonah Crane is a prominent figure in the financial technology sector, currently serving as a member of the Technology Advisory Committee at the U.S. Commodity Futures Trading Commission (CFTC). He is also a partner at Klaros Group, an advisory and investment firm that focuses on the future of financial services, a role he has held since February 2020.
His extensive experience includes being a Regulator in Residence at the FinTech Innovation Lab since April 2017 and mentoring at Queen City Fintech since March 2019. Prior to his current roles, Crane founded West 4th Street Advisors, where he advised fintech and digital asset firms on navigating regulatory frameworks.
Crane has held significant positions within the U.S. Department of the Treasury, including Deputy Assistant Secretary at the Financial Stability Oversight Council and Senior Advisor to the Under Secretary for Domestic Finance. His work there involved advising on financial regulatory policies and overseeing market structures.
He is actively engaged in the fintech community, contributing to various initiatives aimed at developing standards and strategies for digital asset markets and financial technology innovations.1
Highlights
Managing risk, including compliance risk, in connection with fintech partnerships is more complex than doing so in the context of direct distribution or traditional vendor relationships. Regulators and banks alike now regularly acknowledge that complexity, and duly recite the need for enhanced third-party risk management. But the “why” and the “how” are still not well-understood.
The recent request for information on bank-fintech partnerships includes a line that gets at an important core truth about bank-fintech partnerships, and why oversight of such partnerships is difficult: they “may present the full spectrum of risks facing banks.”
When we talk about “third-party risk management” of bank-fintech partnerships, we are really talking about managing potentially the entire range of risk and compliance issues–but doing so through a third-party risk management lens. This may sound obvious, but it is difficult to implement in practice and highlights an important reason the regulatory guidance on third-party risk management feels so incomplete when it comes to bank-fintech partnerships.
For example, the guidance still focuses on the lifecycle of a service-provider relationship, not the lifecycle of offering a bank product. Start, instead, with the product and customer lifecycles. At every step in those lifecycles you must ask: What are the requirements? What are the bank’s standards? Who is responsible for each task? And (for everything the bank is not doing) how is the bank going to make sure that activities meet bank standards? The picture gets clearer but vastly more complicated.
It’s not hard to see how doing this right can lead to significant duplication of effort, and how thinking narrowly about “third-party risk management” can lead to things slipping through the cracks.
A few thoughts from me and others on how the election may impact fintech and regulation.
Lots of wild cards as populism is ascendant in the Republican Party and Democrats have a new candidate. But bank charters and crypto seem likely areas of divergence. Most underrated risk of a Republican Administration in my view is some kind of fair access requirement.
Thanks to Yizhu Wang and S&P Global for including some of my comments.
