The Expert Interview Series is a segment of the COMPLY Podcast where we shine a spotlight on the industry leaders who are truly making a difference in the marketing compliance landscape. These boots-on-the-ground professionals work tirelessly to protect consumers while navigating the complex regulatory environment.
We’ll chat with these compliance experts as they share their real-world experiences, expertise, and practical insights. By hearing from those who are actively engaged in compliance, you’ll gain valuable perspectives and actionable strategies to apply in your own work.
In this episode, I sat down with Andrew Grant, Partner at Runway LLP, where we talked about his extensive experience in financial services law and how companies can operationalize compliance effectively. We explored Andrew’s unique insights from his 15-year career, particularly in the evolving fintech landscape and its regulatory challenges.
Discussion topics include:
- How compliance teams can shift from being seen as “the team that says no” to being problem solvers who help businesses succeed
- Why strong compliance programs can help companies stand out and win partnerships with banks and other financial players
- The importance of gaining compliance buy-in from leadership and other departments (and tips on how to get it)
- Predictions for 2025 amidst a new administration, including steady enforcement from the CFPB, a decrease in new federal regulations, and increased state-level activity to address gaps in financial oversight
Show Notes:
- COMPLY Podcast Speaker Interest Form: https://comply.performline.com/comply-content-speaker-interest
- Driving Marketing and Compliance Collaboration with Technology: https://performline.com/blog-post/driving-marketing-and-compliance-collaboration-with-technology/
- Connect with Andrew: https://www.linkedin.com/in/andrew-w-grant-24667315/
- Connect with Gianna: https://www.linkedin.com/in/gianna-kennedy/
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About COMPLY: The Marketing Compliance Podcast
The state of marketing compliance and regulation is evolving faster than ever, especially for those in the consumer finance space. On the COMPLY Podcast, we sit down with the biggest names in marketing, compliance, regulations, and innovation as they share their playbooks to help you take your compliance practice to the next level.
Episode Transcript:
Gianna:
Hey there COMPLY Podcast listeners, and welcome to this week’s episode, which is the first one of our new segment that we’re calling the Expert Interview Series. This segment shines a spotlight on the industry leaders who are truly making a difference in the marketing compliance landscape. In each episode, we’ll hear directly from compliance experts as they share their real-world experiences and practical insights. Thanks for listening, and enjoy!
Gianna:
Hey, Andrew, welcome to the COMPLY podcast! I’m really excited to have you join us today. For our listeners, this is actually the first episode of our new podcast segment called the Expert Interview Series, where we meet with compliance experts in the space to talk about their experience, expertise, and practical insights. With that, Andrew, why don’t you start by telling us a little bit about yourself, your background, and your path to compliance?
Andrew:
Great, thank you very much, Gianna. My name is Andrew Grant, and I’m a partner at Runway LLP, which is a mix of a law firm and a consulting firm.
I’ve been practicing financial services law for about 15 years now, with a focus on almost everything consumer financial services-related—non-mortgage, non-auto for the most part, and some commercial as well. I got my start shortly after the Dodd-Frank Act and the global financial crisis.
We worked with large banks to figure out what they needed to do post-Dodd-Frank because there was concern about the scope of preemption and what might apply that hadn’t previously applied.
Being junior at the time, I really saw how, beyond just reading the law in law school, companies had to operationalize it. What were they concerned about? We’d tell them, “Here’s what the law says,” and then work with their operations and compliance people to figure out, “If we have to change how we’re doing this, how do we do that?”
Is it just a change of language on a statement? Do we have to do something operationally? How do we respond if consumers have questions about this? That really opened my eyes to how law and compliance intersect—they go hand in hand. You can’t have one without the other.
That’s a high-level overview of my path to compliance and why I find this subject so fascinating. I didn’t go to law school intending to be a financial services attorney, but it’s something I’ve grown to love. Seeing how everything works and helping companies come into compliance has really been a joy.
Gianna:
Yeah, that’s awesome. Sometimes that’s just how it happens—you fall into something and realize you actually enjoy it.
You kind of touched on this already, but maybe you can expand a little. What really compels you about the work you do in compliance?
Andrew:
Going back to where I started, I was representing larger financial institutions at the law firm I was with at the time. This was right after Dodd-Frank, so fintech wasn’t really a thing yet.
There were co-brand cards and bank partnerships, but fintech, as we know it today, didn’t exist then. As the years went on, fintech became something, and I saw how companies could push the boundaries of compliance—how they could deliver products to consumers who might not otherwise receive or access these services.
This might be because of a bad credit profile, a lack of awareness, or because their existing bank doesn’t have the capabilities. Helping companies grow into offering these products has been a huge area of discussion over the last few years, especially regarding how bank-fintech partnerships are regulated and overseen.
Seeing that evolution over time and being at the forefront of it has been exciting. I remember working with partners and other attorneys back then, noting that while we didn’t have direct say over some structures, we could recommend stronger compliance practices.
For instance, we’d advise fintech companies to be aware of potential risks, such as if their banking partner didn’t implement something properly or handled something differently for another partner—it could indirectly impact them.
Law and compliance are so intertwined. I want to see the financial services industry succeed and provide value to customers at all stages of their financial journeys.
Gianna:
Yeah, that’s awesome.
So, in your opinion, what are some of the biggest challenges that compliance professionals face? I know you touched on “pushing the boundaries” and trying to give consumers access to different financial products while staying in compliance. Is there anything else outside of that? What would you say?
Andrew:
There are a couple of things, and I’ll branch them into two categories.
First, there’s the legal component. This is where companies try to do something new or different, but the laws and regulations were written for older products and experiences. It becomes a challenge to fit these older laws—laws that, by their nature, aren’t updated frequently—to newer ideas.
For example, we have very prescriptive laws like Regulation Z. It specifies how open-end credit, like credit cards, needs to be displayed, requiring certain formats like a disclosure box. For closed-end credit, there’s more flexibility to stack disclosures differently. Apple, for instance, reportedly spent about a year figuring out how to launch the Apple Card in a way that complied with these regulations. It’s very much a “square peg, round hole” situation.
Then there’s the operational component, which can sometimes be about getting people to understand the importance of compliance.
We’re starting to see a shift, though. Regulators, and even the banks themselves, are pushing this emphasis on compliance down to the fintechs. They’re saying, “We’re upgrading our compliance capabilities, and you need to upgrade yours as well.”
This shift has brought more attention to compliance. It’s becoming less of a “check the box” exercise and more of a critical, comprehensive focus. Compliance professionals are being recognized for playing a more important role in their organizations.
Gianna:
Yeah, we hear that a lot from many people—that they sometimes struggle to get buy-in from other departments or even their organization as a whole. There can be challenges around securing budget or getting other teams to understand why compliance is so important.
But like you said, we are seeing that shift. Compliance is becoming more embedded in company cultures, which is great to see. It’s something we’ve noticed across a lot of companies we work with as well.
Andrew:
Yeah, one point I think compliance is doing a good job shifting is the approach to problem-solving.
As an attorney, I’ve worked on this myself. It’s about asking, “What’s your goal here? What do you want to accomplish?” and then figuring out how to get there. In the past, there was sometimes hesitation to approach compliance because it was seen as a roadblock—just saying no to everything.
Now, there’s a shift in mindset. It’s more about, “How can we help you solve this problem?” Compliance professionals are increasingly helping teams brainstorm ways to achieve their goals while staying compliant. With more experienced people in these roles, they’ve seen a lot and can offer alternative solutions that may be slightly different from the original plan but still effective.
Gianna:
That’s so true. People often see compliance or legal teams as barriers, especially marketing teams. They have these creative campaigns they want to run, but everything has to be in compliance—you don’t want any UDAP risks. It’s important to emphasize that compliance isn’t here to stop creativity; it’s here to ensure it’s done in a way that won’t get the company into trouble.
Andrew:
Exactly. And like I said, the compliance mindset is evolving. There’s a greater emphasis now on, “How do we help you achieve your goals?”
Gianna:
Definitely. So with that, what’s your biggest piece of advice for a successful compliance program?
Andrew:
Buy-in from leadership.
It can’t just be, “Here are some policies and procedures. Reach out to outside counsel if you have questions,” or relying solely on the general counsel. It has to be a cultural mindset. The entire company has to ask, “Is this important to us?”
For a compliance program to succeed, it can’t just be the compliance team operating in a silo. Leadership and other departments need to buy into it. Without that buy-in, you’ll encounter tension, and the program will be less effective.
Gianna:
That’s a great point. In your experience, if you’re a compliance professional trying to get buy-in, do you have any insights on how to do that?
Andrew:
A simple example is if you’re a bank, you’re going to be examined. The sophistication of examiners varies, but you can expect their reviews to be more robust now than they were a year or two ago. They may even tell you something different than they did in the past.
If this is the line of business you want to continue operating in, you need to highlight that to leadership. For example, referencing recent consent orders can show the importance of building a sustainable compliance program.
For fintechs, it can be even more existential. If your compliance program isn’t solid, a bank could cut you off, and finding another banking partner could be challenging. If you want to elevate your partnerships—say, moving from a middleware provider to working directly with a bank—you need to demonstrate that you’re “bank-ready” with best-in-class compliance.
Being able to say, “We have a top-tier compliance program,” is a differentiator. It sets you apart and helps you maintain or secure the partnerships you want.
Gianna:
Exactly. We like to say “compliance as a competitive advantage” around here.
Andrew:
Yes, exactly. That’s a much shorter way to put it!
If you’re compliant, you have a competitive advantage. It improves how you operate and can even allow you to take calculated risks because there’s a level of trust—people know you’re acting in good faith.
Gianna:
Absolutely. That makes total sense. Thank you.
So, what big changes or trends do you predict for compliance over the next six months? Especially as we navigate administration changes, it feels like there’s a lot happening as we end 2024 and look ahead to 2025.
Andrew:
Yeah, it’s an interesting time to consider this question. I’ll caveat this by saying I could be completely wrong—it’s just a prediction.
My prediction is that the CFPB will operate similarly to how it did under the previous Trump administration. As a government agency, it’s relatively popular. People appreciate getting money back when they feel they’ve been wronged, which makes it an easy sell for the CFPB’s continued existence.
From a compliance perspective, I think we’ll continue to see enforcement actions and efforts to clamp down on bad actors. No one wants it on their watch when consumers are taken advantage of or harmed. Even under prior leadership, we saw the expansion of legal interpretations, like in the Townstone case, which broadened the scope of what constitutes an applicant under ECOA. That case was recently upheld by the courts, so we might even see the CFPB push the boundaries of current legal understandings if they perceive harm to consumers.
However, I don’t think we’ll see many new regulations enacted. It’s possible the CFPB might not even finalize some of its existing regulatory proposals. For example, the earned wage access (EWA) guidance, while technically an interpretive opinion, was put out for notice and comment but hasn’t progressed much. Similarly, we haven’t seen movement on their proposed rules around data brokers or medical debt.
The 1033 rule is a big question mark. It’s been published and is currently facing a legal challenge. My prediction is that the rule will likely remain as it is, with the CFPB defending it. Open banking, which 1033 helps to establish in the U.S., has bipartisan support despite some industry opposition. If there is any change, it could be similar to what happened with the small-dollar lending rule, where implementation was paused for revisions and additional notice and comment periods.
Beyond federal regulations, I think we’ll see states becoming more active. They may pass laws or increase oversight, particularly in areas where the CFPB has been less aggressive. For example, some states are already licensing earned wage access providers, with varying interpretations of whether these offerings constitute loans. Others may follow suit.
We might also see states focus on regulating large fintech partnerships differently, ensuring more oversight of companies like Synapse, which often operate outside traditional frameworks like money transmission laws. States may explore new ways to regulate and monitor these entities.
Overall, state-level activity—both legislatively and regulatorily—could increase, and staying ahead of these changes will be critical for compliance teams.
Gianna:
Yeah, for sure. I feel like that’s been a common prediction I’ve been seeing everywhere. At the federal level, we’ll see what happens. People are kind of expecting… I don’t know if deregulation is the right word, but they’re expecting the states to step up their oversight and compliance efforts.
But I think—and you tell me what you think—it’s fair to say that no matter what happens, the focus should always remain on the consumer. Protecting the consumer and doing right by them should be at the forefront, and that will guide you through a lot.
Andrew:
Yeah, I agree. I wouldn’t call it deregulation either. I don’t foresee many new laws or regulations being enacted or proposed. However, I do believe we’ll continue to see moderately robust enforcement. That enforcement often stems from compliance failures, or at least alleged failures.
To your point, keeping the consumer at the center and ensuring that whatever offering you’re providing is compliant with the law as it stands is crucial. I also think this administration will be more receptive to innovation. We might even see something like a rebuild of the CFPB’s sandbox program or a similar initiative to foster innovation in compliance.
That said, even if leadership expresses support for innovation, change happens slower at the ground level. Examiners, who have been doing this work for decades, often stick to what they know based on their experiences and “battle scars” from past cases. This can create some tension between top-level directives and on-the-ground enforcement.
Gianna:
Something to think about for sure. It’ll be interesting to see what actually unfolds over the next six months.
Andrew:
Absolutely.
Gianna:
Awesome. One last question for you, a little unrelated to compliance. What would you say is your secret superpower? Whether it’s work-related or something else you’re surprisingly good at?
Andrew:
Work-related? I’d say I’m terminally online, so I respond very quickly.
Non-work-related? It’s a bit niche, but I’m exceedingly good at trimming angry cats’ claws. For some reason, cats don’t scratch me when I do it, so I’m often called upon by family and friends to help with their cats.
Gianna:
That is definitely a superpower! That’s hard, especially with cats. Dogs are one thing, but cats are a whole other beast.
Andrew:
Yeah, I don’t know why, but they seem to tolerate me well. It’s a very niche superpower that doesn’t come in handy often, but it’s been useful!
Gianna:
That’s awesome. Well, Andrew, thank you so much. This was a really great conversation. You shared so many valuable insights, and I’m sure our audience will appreciate everything you brought to the table.
Andrew:
Thank you so much for having me. It was a pleasure to join you for the inaugural podcast, and I’m looking forward to seeing how the series develops.
Gianna:
Awesome. Thank you!
Gianna:
Thanks for listening to this week’s episode of the COMPLY podcast! If you or someone you know is interested in being featured on a future episode, let us know by filling out the interest form linked in today’s show notes, or you can connect with me on LinkedIn.
As always you can find the latest content on all things marketing compliance by heading over to performline.com/resources. And for the most up-to-date pieces of industry news, events, and content be sure to follow PerformLine on LinkedIn. Thanks again for listening and we’ll see you next time!
Rhonda McGill 
