Embedded Finance and “Payments as-a-Service” Models: Navigating Legal Risk

Embedded finance and “payments as-a-service” models are redefining how financial institutions, payments companies, and software providers are partnering to provide new and innovative payments, lending, and banking products to consumers and businesses. This session will examine the legal and regulatory risks that arise when FIs, fintechs, and technology providers collaborate in these ecosystems. Panelists will discuss key contractual, compliance, and oversight challenges—including issues of data sharing, consumer protection, and third-party risk management—as well as practical strategies for mitigating exposure. Attendees will gain a deeper understanding of how to structure and manage these partnerships to support innovation while maintaining regulatory compliance and operational integrity. The panel will also discuss how the Fed's recent announcement of a skinny master account for fintechs may impact bank partnership models.