Episode 69: Responsible Bank-Fintech Partnerships with California DFPI Deputy Commissioner Christina Tetrault
Christina Tetrault, Deputy Commissioner at California’s Department of Financial Protection and Innovation (DFPI), offers a candid, practical look into the regulatory realities shaping today’s financial collaborations.
Drawing from real-world enforcement actions and firsthand experience, Christina outlines the common missteps that can derail even the most promising partnerships—and what organizations must do to stay on course. Her message is clear: compliance isn’t a checkbox or a one-sided burden—it’s a shared responsibility across the entire ecosystem.
Whether you’re scaling a fintech startup, leading risk at a traditional bank, or exploring the future of financial innovation, this episode delivers a clear roadmap for building partnerships that are not only groundbreaking—but built to last.
Christina offers insights on:
- How to build a resilient culture of compliance from the inside out
- Modern tools and strategies for staying ahead of regulatory expectations
- Why proactive engagement with regulators is key to long-term success
- Lessons from recent enforcement actions—and how to avoid similar mistakes
Show Notes:
- Connect with Rhonda: https://www.linkedin.com/in/rhonda-mcgill/
- For more info on California DFPI’s weekly office hours: https://dfpi.ca.gov/about/dfpi-divisions-and-offices/office-of-financial-technology-innovation/
- Subscribe to PerformLine for resources and updates: https://lp.performline.com/subscribe-to-performline
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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:
Rhonda:
Hey there COMPLY Podcast listeners, and welcome to this week’s episode. In today’s episode, we want to highlight the regulatory session from our recent Client Summit, where Christina Tetrault, Deputy Commissioner from California’s Department of Financial Protection and Innovation provided our attendees with an insightful look into responsible bank-fintech partnerships. Christina then discusses common pitfalls and why compliance isn’t just one party’s job, but shared responsibility. As always, we appreciate you listening and we hope you enjoy.
Christina:
Hello everyone. I’m Christina Tetrault, Deputy Commissioner for the Innovation Office for California’s financial Regulator, the Department of Financial Protection and Innovation. I’m here today to talk about responsible Bank FinTech partnerships and some of the compliance challenges and opportunities that I have seen.
The Bank FinTech partnership is a model that allows for innovation and creativity, including the delivery of products and services to people who otherwise may not be well served or to market segments that wouldn’t, otherwise receive these services. When it works well, it benefits banks and credit unions, fintech’s and consumers.
But there are some challenges, and I first want to talk about some of the hiccups or some of the pitfalls that I have seen. The first and foremost is do not call yourself a bank if you are not a bank. California has very, very strict laws about this, and we have had to take enforcement actions against companies who use the word bank when they do not have a California issued bank license.
So this is a, really, really critical, element and, I urge people to think broadly about, not using the term bank. But if you have questions, you know, come talk to us, we’re happy to point to the statute, show you the enforcement actions, and really help you understand your obligations, around the use of the term bank.
The second thing I want to talk about is the license requirement. California again has very specific requirements for activities, and licensing activities. And often what I have seen is entrepreneurs will start off in one space and they’ll look to expand their product line. And we absolutely urge companies that are looking to expand their product lines to meet with their examiners.
They’re the regulator who licenses them to really discuss those product lines before they expand into them. And that way you can avoid stepping into territory of doing an unlicensed activity. I think the third thing that I really want to encourage is that compliance is a team sport and that all parties must take responsibility. This is really, really, critical. Again, the department has had to take enforcement actions in this area, most recently around, our, the consent decree with Hatch Bank. And we are very eager to see every party, within the ecosystem, really work together in order to ensure compliance with all the laws on the books.
I think there’s really an important aspect of compliance that we don’t necessarily talk about very much. And that is the importance of expertise. It is critical to have experts on your board of directors, from your VC if you’re a startup, that can, in addition to, ideally in-house counsel, although we know not, every startup can afford that but there needs to be a compliance team and people focused on making sure that you are compliant as well as, seeking counsel, especially in those, when there are questions, or opportunities. So again, it’s a team sport. All parties must take responsibility and really the ecosystem benefits, when there is this robust culture of compliance.
I think the thing that I’m most excited about, cause I don’t wanna be all gloom and doom, is there are some amazing compliance tools out there. and I’m really thrilled to see the advances that have been made in all sorts of critical areas. I won’t, I don’t want to, inadvertently endorse the company cause we certainly can’t do that.
But there’s really been amazing advances in BSA and KYC in knowing your, in, , digital identity, all sorts of aspects. Even just some of the tools that allow folks to understand the way that laws and regulations are changing. So, I wanna close today by saying that I’m so excited for all the innovation that’s happening in financial services broadly. I’m very aware that bank FinTech partnerships, including those that are about back of the house services, are ultimately really beneficial. It really takes everyone working together to ensure those cultures of compliance that make this ecosystem work. Again, I want to invite you if you have questions please talk to your regulator. My office, the innovation office, we hold weekly drop-in office hours. They are on Tuesday mornings from nine to ten PCT. If that time does not work for you, we will find a time to meet with you. It is on our webpage is how you can register or if you have questions, you can email at ofti@dfpi.ca.gov.
Thank you so much for this opportunity. I really appreciate having the opportunity to chat with you and talk a little bit about our office and encourage us to all work together to make sure that the fintech and compliance ecosystems thrive.
Rhonda:
Thanks for listening to this week’s episode of the COMPLY Podcast! As always for the latest content on all things marketing compliance you can head 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!
