What BaaS companies learned the hard way in 2024 — and what’s coming next

Is BaaS the land of the dead? Actually, not so much. 2024 was admittedly a difficult time for partner banks and fintechs alike when it came to BaaS. But through the fires of consent orders and lost customer deposits came a realization that all firms involved needed to look more deeply into how they structured their relationships.

Lauren McCollom, SVP and Head of Embedded Finance at Grasshopper, called 2024 an “enlightening and chaotic year” for BaaS players. As consent order numbers climbed into double digits, hitting institutions like Evolve Bank & Trust, Sutton Bank, and Blue Ridge Bank, many fintechs decided they had to pivot and find new partner banks to ensure their programs’ longevity and survival.

On the other hand, affected partner banks had to dig deep into their existing programs and look for weaknesses, while non-affectees saw more and more fintechs queuing up for partnerships. “This fintech outreach wave which fueled pipelines and enabled partner banks to engage with leading fintechs looking for safety and stability in long-term programs with an established partner bank,” said McCollom.

In today’s story, we look at the major challenges partner banks and fintechs faced in 2024 and what trends may emerge in the new year for these firms.

Recap: 2024’s BaaS trials

Here is a top down view of all the challenges partner banks and fintechs faced last year.

The regulators and BaaS programs: One major difficulty BaaS partners faced was dealing with enforcement actions, reconciliation issues born out of underbaked BaaS programs, and a desire by fintechs to build redundancy in their bank partnerships.

“What came from this period in early 2024 were inquiries and clarification questions from fintechs trying to cut through the noise. Overall this permitted the education of the industry and alignment on what ‘direct’ can mean in BaaS,” McCollom added.

Compliance became top of mind and ultimately led to a reinvigoration of compliance technology providers and a deeper look at how these tools could be used to strengthen existing BaaS partnerships in the face of regulatory scrutiny.

On the other hand, fintechs that foresaw trouble decided they needed a change of partners and sought to migrate their programs leading to a few partner banks seeing more traffic. And while this narrowed the number of partner banks operating in the BaaS landscape, those that continued built much stronger foundations in compliance.

Balancing act: Given the regulatory focus on the industry, firms had to carefully manage building better compliance capabilities while looking after the bottom line. “The balancing act of investing in the necessary infrastructure, controls, and capabilities while maintaining a profitability model added further complexity to the equation,” said Richard Rosenthal, Principal at Deloitte.

The solution to evolving BaaS programs to be resilient to regulatory headwinds for many was putting in place the right infrastructure. There is a class of partner banks and fintechs emerging now that focus on implementing the right controls and processes, added Rosenthal.

Expectations and trends for 2025

Regulators aren’t done yet: Industry experts like McCollom expect a continuation of enforcement actions in the new year, as well as changes in regulations and policies, like the proposed brokered deposit rules as well as any changes by the new administration.

For partner banks, this means that their work on compliance is not done yet and that these firms need to “button up their respective fintech programs where deficiencies may reside,” said McCollom. The best approach here is to develop a strategy specific to BaaS and “align on what specific types of activities or fintech programs [banks] will support,” she added.

This means that the number and types of fintechs partner banks are interested in working with has decreased and may continue to fall, leading to fintechs having to be more competitive from the outset. Here, partner banks can help interested fintechs by clarifying whether they will enter into a BaaS relationship with a given fintech as soon as possible. “Giving a fintech a quick ‘no’ is more helpful than a long drawn-out ‘maybe,’” she added.

Building a strong tech foundation: BaaS players are now contending with changing regulatory requirements as well as growing customer expectations in a digital-first environment. In 2025, a significant challenge for partner banks will likely be ensuring that the right technological infrastructure is in place to support program growth as well as rigorous compliance demands. “Partner bank legacy systems may often require significant upgrades to support modern technology and partnership needs,” said Rosenthal.

This emphasis on using technology to bolster compliance processes may make fintechs that are built on newer and more robust technological infrastructure more attractive partners. “Banking regulators will hold the partner bank ultimately accountable for the risks triggered by their role and functions in the BaaS model, as a bank owns what it books,” he added.

Fintechs niche down: With fewer partner bank options out there and an increase in selectiveness, fintechs will need to find ways to differentiate themselves from their competition. The key here may be focusing on targeting niche customer segments. Products that bring in a new segment of customers like underserved populations into the system may be more effective in gaining a ‘yes’ from partner banks, according to Srinivasan Seshadri, Chief Growth Officer and Global Head of Financial Services at HCLTech.

Have the right customers: While partner banks focus on onboarding the right fintechs, fintechs on their part will have to focus on acquiring the right customers. To do so, fintechs will have to translate their partner bank’s expectations into their own context. “This means going beyond checking a box on a bank due diligence checklist when you are first onboarded by a partner bank, and developing a core risk and compliance program that addresses the risks faced by the products offered,” said Rosenthal.

Softening attitudes on Capitol Hill: Trump’s new administration may create a friendlier environment for BaaS players in 2025, shifting policies towards a more “commercial focus” according to Deloitte’s Rosenthal. “This may include the finalization of a pending FDIC proposed regulation on custodial recordkeeping,” he added, speaking to FDIC’s proposed rule first set out in October in 2024, which helps ensure that customers don’t lose money in case of reconciliation issues among BaaS partners.

Finalization of such a rule may bolster consumer trust and engagement with BaaS products as well as better prepare the industry for addressing the sticky issue of who really owns the customer.

Sidebar: The BaaS partnership manual

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Looking back and moving forward: How fintechs will beat back the dark clouds of 2024, capitalize on trends like AI, and build resilient firms in 2025

From ‘BaaS is dead’ to discussing how Gen AI and Open Banking could significantly change how fintechs connect to banks, serve customers, and help push the industry forward, 2024 has been a really happening year for fintechs. 

In this new year we look at how fintechs fared in 2024 and explore what shifts we can expect from these companies in this new year. 

Victoria Zuo, Principal at QED investors, says after a few years of headwinds she expects 2025 to be a year of recovery. 

The turnaround for fintechs was most evident in the uptick in public markets. It restored confidence in fintech companies following successful IPOs, according to Zuo. On the other hand, the private market continued to cherry-pick fintechs that exhibited they had what it takes to reach profitability, she added. 

Most importantly, in this year of many changes, fintechs had to find a way to pivot away from ‘growth at all costs’ and towards efficient scaling and operational discipline. 

“The year showcased the resilience of the sector as it adapted to macroeconomic challenges and recalibrated for long-term success,” Zuo added. 

Looking back: The trials of 2024 

Last year came with challenges that destabilized assumptions about what it takes to build fintechs, run them, drive them to success:

a) The interest rates paradox: At the start of 2024, interest rates remained high and the uncertainty surrounding cuts continued to challenge fintech leaders to think on their feet about how their firms will make money. “Rising rates squeezed margins for lending-focused fintechs, forcing them to diversify revenue streams and focus on underwriting excellence,” said Zuo. 

Source: SVB

Research by SVB backs this up, showing that fintechs have had to focus on acquiring high quality borrowers instead of extending credit to borrowers that may carry revolving balances. But as a result of this strategy, fintechs have had to reap their profits from interchange fees.

Elusive funding: Fintech leaders had a hard time chasing VC dollars in 2024, pushing them to focus on their business models. “Access to venture capital remained limited, prompting startups to extend their runways through cost optimization and prioritizing monetization over growth,” she said.

Source: SVB

The looming regulator: In 2024, regulators started to contract the freedom the industry had available to innovate and pushed its leaders towards building more safeguards and guardrails. This was most evident in how fintech-bank partnerships became strained due to a towering amount of consent orders for bank partners. “The regulatory landscape, especially in areas like BNPL and crypto, grew more stringent, pushing fintechs to invest in compliance and risk management,” Zuo added. 

Capitol Hill in flux: 2024 was an election year and the fintech industry was no stranger to this. FIntech leaders were caught in between red and blue, as questions about the Biden administration taking a more pro-regulation stance through government bodies like the CFPB clashed with ideas how a Trump administration could shift this focus. 

“A new administration could bring a more business-friendly approach, particularly in areas like crypto, financial inclusion, and open banking,” said Zuo. 

The regulatory push didn’t just impact how fintechs chose partners and structured products but also impacted their bottom lines. 

“Compliance costs have risen due to rising regulatory pressure, especially regarding BaaS partnerships. Fintechs are now responsible for more compliance requirements, leading to higher operational costs and a greater focus on regulatory diligence,” said SVB’s Head of National Fintech and Specialty Finance, Nick Christian.

But Zuo feels that moving ahead, this focus on building a strong compliance-forward foundation could be beneficial for the sector, saying that the stricter regulatory environment served as a “forcing function for fintechs to strengthen compliance” and will help in building consumer trust and robustness in the system in the long term. 

The making of a hero: The fintechs that rose up from these challenges were focused on improving cash flows, lengthening their runways, and had an eye on customer pain points, as well as regulation shifts. “Companies that proactively engaged with regulators and invested in compliance infrastructure navigated regulatory changes more effectively,” said Zuo. 

Moving forward: 2025 and fintech, the comeback kid

1. Global tensions will motivate local innovation: Given the geopolitical tensions of last year, fintechs that helped people connect and run businesses across geographies fared well, like those focused on cross border transactions. These tensions birthed a demand for tools that helped with things like risk management, and the expectation is that the impetus for 2025 will be AI – helping with automation in supply chain tasks and also powering productivity gains across the industry. 

2. B2C is still cool: While VC interest in B2C fintechs has generally cooled, Zuo believes that fintechs have made enough of a case in capturing the interest of and serving niche consumer segments that their momentum will likely continue. “Neobanking products tailored to niche demographics – such as gig workers, SMB owners, and specific cultural groups – will stand out by offering hyper-personalized experiences,” she said. 

3. VC dollars will quit playing hard to get (maybe):  The change in administration may have an impact on how strict the regulatory environment is for fintechs in the coming year making this year a “turning point” for the industry.  “Next year may bring a thaw, driven by pent-up demand and the possibility of more favorable regulatory and monetary policies,” she said. 

But the VC dollars are still likely to give precedent to those that can hit the golden trio: strong strategy for achieving profitability, capital efficiency, and clear differentiation in market positioning. 

4. The new kid on the block – Chief Compliance Officer:  To stay ahead of the regulators many fintechs have already started to build compliance programs that can stand comparisons with those by traditional FIs. One role that has emerged from this shift is the Chief Compliance Officer. “Many of these companies have appointed Chief Compliance Officers earlier in their lifecycle to handle the increasing complexity of compliance,” said SVB’s Christian.

As execs in these roles gain more experience, we may start to see a shift in how fintechs partner and position in the market.

5. Do you have what it takes? Asks the bank: The BaaS honeymoon period is decidedly over and bank partners are becoming more discerning in their partnership behavior. Recently, we heard from Newline by Fifth Third’s Director of Revenue Strategy, Dan Dall’Asta about how the bank prioritizes partnering for the long term.

“As clients are coming to us now, the first thing I tell them is, if you want to get to market fast, go elsewhere. We’re looking to build 10 to 20 year partnerships, and that has to be driven by oversight,” said Dall’Asta. 

This cherry-picking combined with the precedent set by 2024’s regulatory heat may motivate some bank partners to pull away from BaaS partnerships. “We may see fewer partner banks as fintech companies become more discerning, opting to collaborate with institutions with more robust compliance programs,” said Christian. 

Sidebar: ‘Tis the year for Gen AI and Open Banking?

Two technologies have dominated the conversations in this industry for the last year: Open Banking and AI. Open Banking, because the 1033 rulemaking started a discussion on who owns the customers and their data, and AI, because, well, Gen AI

Here is what you can expect from Gen AI in 2025: 

i) Change management initiatives: Along with initiatives to augment employees’  workflows with Gen AI, firms will also have to ensure that their workforce has a clear understanding of the tech they are interacting with and that they can do so safely. This change in process and the newness of the tech may spur the launch of data literacy and change management campaigns.

ii) Better investment in infrastructure: For FIs to fully lean into Gen AI, they will have to invest into doing away with legacy technology. 

Here is what is in store for Open Banking in 2025: 

Slim pickings: “With the final passage of the 1033 rule and revised timelines, industry participants now know they need to prioritize this broad implementation and there may well be excessive demand on the few vendors who are active in Open Banking,” said Ulrike Guigui, Managing Director at Deloitte

Operational efficiency: Banks might be able to utilize the increased availability of data to improve anti-fraud measures. There will be opportunities for banks to leverage data to improve fraud and related back-office activities.

Looking back and moving forward: 2025 trends for Open Banking and Gen AI

Two technologies have dominated the conversations in this industry for the last year: Open Banking and AI. Open Banking, because the 1033 rulemaking started a discussion on who owns the customers and their data, and AI, because, well, Gen AI.

Lets dive into how Open Banking and Gen AI impacted the industry in 2024 and how we think adoption is going to fare in 2025.

Looking back: Open Banking in 2024

The 1033 rulemaking, although contentious, is definitely pushing Open Banking from a possibility to an inevitability, and it’s a shift that is reflected globally. “Paired with innovations across the industry and regulatory advancements in different global markets have helped move Open Banking forward this year and will be instrumental to its sustained growth,” said Jess Turner, EVP, Global Head of Open Banking & API at Mastercard.

Banks’ strategies to Open Banking adoption and the 1033 rulemaking is primarily determined by their size, according to Ulrike Guigui, Managing Director at Deloitte, who says:

  1. Large banks and regional banks are building out the infrastructural and technological components needed for compliance and are also exploring use cases and opportunities.
  2. Medium-to-small sized banks are looking towards vendors to access the tech or are not prioritizing this topic in light of the lengthy timeframe to comply.

The infrastructure build that Open Banking requires can be a challenge for some banks: “For banks on their path to compliance with rule 1033, the challenge has been to put in place a cross-functional strategy that addresses the ‘builds’ that will be required: consumer portal, enhanced third party risk management and developer (API) portal. Mapping data from proprietary and vendor systems, putting in place the infrastructure to handle the anticipated volume of API calls as well as the operational capacity to handle increased consumer call volume, are time consuming tasks in an environment of stretched resources,” said Guigui.

With banks finding that they may soon need to act on Open Banking either due to competition or regulation there is also a push towards raising the overall industry standard. Mastercard’s Turner adds that she has observed a call to make the ecosystem more secure as well as an added emphasis on ensuring that consumers are at the center and have control of their data.

Trends: Open Banking in 2025

As the industry navigates the infrastructural challenges and the changing regulatory landscape, we can expect to see the following trends emerge: i) More financial inclusion for consumers: Traditional credit decisioning systems may be excluding a significant portion of customers from accessing liquidity and credit. But Open Banking may be able to bring more customers into the fold. “Open banking’s innovative use of alternative data – for example, using data like rent payment history, cash flow and balance analytics to prove creditworthiness – create more opportunities for those outside of the credit mainstream to take control of their financial lives,” said Turner. This is not necessarily a new use case but the regulation-driven adoption of Open Banking and the formalization it is making necessary may finally push alternative data usage from being on the periphery to being more widely deployed.

ii) More business for vendors: Technology providers and vendors play a huge role in helping this industry shift towards new technologies, and while Open Banking isn’t ground breakingly new at this point, the number of vendors that offer these capabilities isn’t too large. “With the final passage of the rule and revised timelines, industry participants now know they need to prioritize this broad implementation and there may well be excessive demand on the few vendors who are active in Open Banking,” said Guigui.

iii) Products and experiences: Deloitte’s Guigui expects to see product development to be focused in CX and building operational efficiencies.

  1. Customer experience: Existing customer-facing processes like account opening and underwriting may become easier due to better availability of data.
  2. Operational efficiency: Banks might be able to utilize the increased availability of data to improve anti-fraud measures. There will be opportunities for banks to leverage data to improve fraud and related back-office activities.

Looking back: Gen AI in 2024

Last year, the industry warmed up further to Gen AI. It was a welcome shift from discussing whether Gen AI could end the world towards discussing what it could do for us and how to ensure it does everything safely.

Big banks like JPMC, Morgan Stanley, and Truist all found back office tasks that could benefit from the tech. Some small but forward thinking banks are realizing that building AI literacy and capabilities in their workforce is essential and launching strategies that help their workforce upskill. Meanwhile, fintechs like Public and Lili continued to move faster and found ways to augment their customer-facing interfaces with Gen AI-powered digital assistants.

“2023 was all about education and doing proofs of concept, while 2024 was about leveraging those learnings to build enterprise AI platforms and beginning to move GenAI use cases into production. At the end of 2024, we have seen solid progress from financial institutions using Gen AI in their organizations and expect this to continue to ramp up in 2025. These use cases have been focused on efficiency plays and supporting workforce acceleration but have included a human in the loop,” said Kevin Laughridge, Principal at Deloitte.

Trends: Gen AI in 2025

So far, firms (specially banks) have used Gen AI to make their existing processes more effective. But as ease with the technology increases it’s likely that Gen AI would start to feature more heavily in products and impact firms’ bottom lines.

i) Pushing into the front office: Even though there are very few active projects that hint at banks implementing Gen AI in the front of the office, it’s unlikely that it will always be this way. It took banks years to act on chatbots but they did eventually. The natural evolution of the chatbot is enhancement through Gen AI. Similarly, as comfort levels with the technology increase driven by the formulation of internal governance policies, moving implementation to the front of the office will become less daunting.

“We expect to see the GenAI use cases in financial services begin to move from the middle and back office to supporting more front office functions and move to support more revenue generations vs. driving efficiencies,” said Laughridge.

ii) Open Banking + Gen AI: There is also a possibility that both Open Banking and Gen AI technologies will come together to enhance already existing products like PFMs – layering on top of one another to enhance product experiences through automation. “In synergy with informed consent protocols, open banking data, coupled with responsible Generative AI, can optimize a consumer’s financial management, essentially acting as a personal wealth manager,” said Mastercard’s Turner.

iii) Infrastructure builds: FIs hoping to take better advantage of innovations offered by Gen AI will need to invest in improving their technology and make bigger strides in their data modernization journey. “Financial institutions will need to galvanize their AI platform; this is more than simply picking an LLM, it is a platform that enables scaled AI with many LLMs in a controlled environment,” he added. iv) Managing people:  As firms continue to deploy Gen AI first in the back office they will need to make a concerted effort to ensure their employees not only possess the technical skills to leverage Gen AI, but the data literacy to understand its risks. “FIs will also need to work through change management of their employees, continuing to show why AI is a workforce accelerator and enabler of business value,” he said.

Sidebar: Banks’ barrage-like movement when it comes to Gen AI


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[podcast] The top 10 fintech stories of 2015

top stories about financial technology in 2015
2015 was in many ways a watershed year for fintech. According to Pitchbook, it looks like 2015 will finish with close to $8 billion worth of venture capital invested in financial technology startups. To put that into perspective, there was $4.7 billion worth of fintech investments in 2014. It looks like there will be close to $10 billion of M&A done in 2015, as well. Based on our coverage, here’s what we believe to be the top 10 most important fintech stories of 2015.

Listen to the FULL episode

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5 trends we’re watching this week

weekly trends in fintech

Every week at Tradestreaming, we’re tracking and analyzing the top trends impacting the finance industry. The following is a list of important things going on we think are worth paying attention to. For more in depth trendfollowing, subscribe to Tradestreaming’s weekly newsletter (published every Sunday).

1. Computers vs. Humans: Who wins the investment game? (Tradestreaming)
Do humans have an innate ability to pick winning stocks or should we turn everything over to the machines. A frank conversation with 2 experts moderated by Tradestreaming’s managing editor, Zack Miller and hosted on Dealbreaker.

2. A Future Where Virtual Reality and Finance Converge (Finance Magnates)
In this week’s Fintech Spotlight, Finance Magnates delves into how virtual reality could become a big data tool of the future in the finance industry.

3. The Next Fintech Boom: Resource Maximization (Bank Innovation)
Former Thomson Reuters CEO, Tom Glocer predicts fintech startups to begin squeezing more out of the financial system. “Think of all the underutilized financial resources out there — credit lines, savings, advisory, illiquid assets. All are ripe for maximization.”

4. Why Every Financial Institution Needs a Digital Champion Now (The Financial Brand)
Is anyone spearheading your organization’s digital strategy? Here’s what banks and credit unions should look for when creating this new role.

5. Robo-Advisors Squeeze Advisor Profits, Not Fees (Michael Kitces)
Michael Kitces with a thoughtful analysis of the robo-advisor trend and how it’s impacting the AUM fees investors pay (it’s not what you think it is). While fees don’t seem to be dropping, profit margins are indeed getting squeezed. Worth a read.