Fintech Deposit Sweeps Face Fresh Scrutiny as US Banks Reassess Partner Risk

US fintechs and digital banking providers are being pushed to take a closer look at how their customer deposit arrangements work, as banks face growing regulatory scrutiny over third party relationships.

The issue is particularly relevant to sweep programmes, where customer funds are moved between banks, often through a fintech or another intermediary. The Federal Deposit Insurance Corporation has raised concerns about how some of these arrangements are classified and reported, including cases where banks may not have properly identified deposits as brokered.

The FDIC proposed broader changes to its brokered deposit rules in 2024, including changes that could have affected certain sweep arrangements and the treatment of third party deposit placement. But the agency withdrew that proposal in March 2025, meaning fintechs should not treat those proposed changes as a new set of rules already taking effect.

The scrutiny has not disappeared, though. US banking regulators have continued to focus on the risks created when banks rely on fintechs and other third parties to deliver deposit products. The agencies have made clear that using a third party does not remove a bank’s responsibility for complying with banking laws and managing the associated risks.

That leaves fintechs with a fairly practical problem. A deposit arrangement may look straightforward from the customer’s side, while the regulatory treatment behind it can be considerably more complicated.

Banks are therefore likely to want a much clearer picture of who controls the customer relationship, where the money is being placed, how funds are moved and who maintains the underlying records.

That last point has become especially important after the collapse of Synapse Financial Technologies exposed weaknesses in some third party deposit arrangements. The FDIC has separately proposed stronger recordkeeping requirements for banks dealing with custodial deposits held through non-bank companies.

For fintechs, the lesson is fairly simple. Do not assume that a deposit sweep arrangement is safe just because it has worked up to now. The regulatory framework is still evolving, and partner banks are paying much closer attention to the details.