This is a great problem to have but also one that needs to be monitored closely by auditors, legal counsel, IT experts and the board/audit committee for transparency. Obviously, there should be clear boundaries on which party is responsible for which function/operation, but regardless, the bank will still be liable for compliance and consumer protection so clarity on all fronts must be documented and vetted. Folks who are very well versed on not only the technical aspects of this project should be very involved from the beginning, but the tech folks should also have a good understanding of banking and the payments rails as well to help protect the bank in the event something does not work out in the way it was anticipated. That is where banking legal comes in.
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