The Washington State Department of Financial Institutions (DFI) is gathering information about lending activity involving financial technology (fintech) companies that partner with out of state banks and credit unions.
Lending relationships between fintech companies and banks or credit unions are often referred to as “rent-a-bank relationships” or “banking as a service.” Banks and credit unions in other states may “export” their home state’s interest rate to other states, including Washington, through the fintech lender, resulting in higher interest rates charged to Washington consumers. It can be difficult to determine which entity in these relationships is the “true lender.” The true lender question is important because different regulations and interest rate limits apply to loan companies as compared to depository institutions.
DFI is issuing requests for information to 10 well-known fintech companies making loans in Washington while operating in partnership with an out of state bank or credit union. The requests were sent to OppFi, Elevate, NetCredit, Personify Financial, American First Finance, Axcess Financial Services, EasyPay Finance, Lendly, Max Cash, and Total Loan Services.
The information requested from the fintech lenders will help DFI better understand the relationship between fintechs and out of state banks or credit unions, the terms of these financial products, whether they need a Washington license, and how their loan products affect Washingtonians.
If you have questions about this inquiry, please email CSReg@dfi.wa.gov