Compliance, BaaS, Marketing, AI and more with Nicky Senyard, CEO & Founder Fintel Connect

The second of what is becoming a monthly video interview series here.

In this edition of Fintech Compliance Chronicles, I'm continuing a new monthly video podcast series we started this year where we sit down with folks in the Fintech Compliance space. This month, I got to connect with Nicky Senyard, CEO & Founder of Fintel Connect, a company that offers a three-prong set of solutions in the marketing world, two of focused on affiliate marketing and marketing analytics, but one that has really caught our attention which is focused on compliance called Fintel Check.

Nicky has been an influencer and leader within the affiliate space for the past 20 years, with the goals of creating contribution and growth for Fintel Connect clients and partners. She has driven the organization to become a leading affiliate network dedicated to serving the financial services space, with clients that include Scotiabank, Tangerine, and Borrowell. Nicky successfully exited from her first SaaS marketing technology company in 2016.

Our video interview is below, and the transcript of our discussion follows. Enjoy, and thanks again to Nicky for spending time with me!

Zarik Khan: Welcome everybody to the second ever Fintech Compliance Chronicles video interview podcast - we’re still trying to figure out what to call this thing. But I'm really really honored to be joined today by Nicky Senyard who is the CEO and founder of Fintel Connect. Nicky and I have had the pleasure of getting to know one another over several months/last year and I’m really proud to have her join us today to learn a little bit more about her, Fintel Connect, the products they've got going on. And really as we're called Fintech Compliance Chronicles, everything we're going to talk about is going to be against the backdrop of Compliance. So Nicky if you could just briefly introduce yourself to our viewers and listeners and tell us a little bit about your story. Would love to have you share what I’ve learned with everyone else.

Nicky Senyard: Thanks so much to the introduction and it's a pleasure to be here. And I think what you're doing is incredibly cool in a really niche market approaching it in such an accessible manner. So I'm very honored to be here. Thank you. As you said my name is Nicky Senyard. I'm CEO and founder of Fintel Connect. We come to compliance in a roundabout way and so our Core Business is on net new acquisition for banking products. So whether that be a CD product a business savings account a business loan a mortgage, we really are on the net new acquisition side of it. But the way we do it is a little bit unique. So we do it through third parties - the NerdWallets of the world, the CreditKarma's the Business Insider reports. And we as a technology platform are the plumbing behind all of that that allows the banks to pay for only net new acquisitions. So as you could imagine we're working through third parties, and there's a commercial relationship between the banking product or the credit union product and the third party which means, as everybody knows in the compliance world, it means that the behavior of these third parties related to that product has an implication on the bank.

So as we were developing out our own business, we developed a tool for ourselves to look at policing content. So what we're looking at doing is making sure that when an interest rate changes or a product description changes or any of those things that are crucially important to FDIC, billing practices or any of those sorts of things, we need to make sure that the content’s updated. So as we deep dive - and we decided to use machine learning and AI technology to help us do this - like any tool that we might need to manage, we were developing it as a utility function as we grow our business and keep our clients safe. The very curious thing is the more that I started to look at it from our perspective of net new acquisition and all of those sorts of things, it opened the door to your world, which is in banking compliance. I can't say by any stretch of the imagination I'm an expert but I've got to tell you I have learned so much in the last two years - so much - and I have learned that banking compliance teams are significantly overworked. They are the players that protect the bank and yet they are under so much pressure because of volume of work of the attention to detail of all of this sort of reporting elements that all of the regulators are doing on the banks. I've come to realize the very pressure cooker environment a lot of compliance people are under; so I've decided to make it my mission to see if I could alleviate a little bit of that pressure by developing a tool that provides really good utility in this whole content compliance world. And just before we go on I just wanted to do one thing for the listeners to put this all into context for them if that's okay. So in my viewing of marketing compliance, there are sort of layers to it - one layer is where you’re looking after the brand so it's brand messaging and all of those sorts of things and people have tools that grow and crawl the web for that. That's not what we do because that, I have worked out, creates a lot of work for compliance people because a lot of them are just mentions that need to be reviewed but aren't necessarily mission critical in terms of the relationship with the regulators and the regulations and all of those sorts of things. And what we do is a little part of this very big compliance pie that is just about content compliance on websites that have a commercial relationship with the bank as we know that could either be a marketing channel. Like a Forbes or Business Insider - or it could be a banking as a service fintech. Interestingly enough I found actually multiple uses for this one tool. So that's how the story creates, that's how I sort of have a toe in your water, a toe in your pond with this content compliance.

Zarik Khan: That's really really helpful and to help us the stage a little bit I think you talked about getting into the compliance base and I would argue that your timing is impeccable because as many of our listeners and viewers will know this past year the three major federal regulators put out revised third-party risk management guidance, and they haven't done that for I think dating back, almost 10 years. So it's been quite a while.

Nicky Senyard: Yeah, I was going to say that definitely yes.

Zarik Khan: That in and of itself was kind of concerning but since then I have had the pleasure of going to a number of events talking with a number of compliance professionals meeting you and your colleague Alana Levine who's your CRO at the Money20/20 conference in Las Vegas and hearing over there all this talk about BaaS, BaaS, BaaS - and that’s banking as a service for those who don't know what I'm talking about - and the reason I bring that up is because there's become such a concern for many regulators actually, not necessarily going after, but really holding the bank up to a very high standard for not necessarily the work that they're doing directly but the work that their fintech or partner are doing on their behalf. In many cases the fintech may presume, “we're not regulated. We're not dealing with the bank. We're just doing work for these banks that may or may not have these regulatory requirements” and I think what it goes to show is that banks need to recognize that any of their third parties as you mentioned, they're going to be on the hook for whatever they do, especially if they're representing a bank. So thus I think everything you said, the need for the services you provide, is more timely than I think it’s probably ever been in the past as well as others who are also trying to get involved in this space.

So thanks for setting the stage for us. I want to actually focus on, you talked about, the servicing piece that you are able to provide as well as marketing compliance, but I want to stop and focus on marketing compliance for a few seconds. I've had the opportunity to look at disclosures and look at advertisements in past life and when you think about marketing compliance, sometimes it can be really nebulous because so much of it can be policy and of course, there's quantitative components to be sure when you think about things like pricing. But sometimes one of the issues that regulators will go really into particular is false claims. How do you think about something like false claims in the context of your product? Let's say if you're thinking about something like influencer marketing right? I'm not sure if any of your third parties that you work with or the bank has third parties that deal with that. But what's your take on, the claims or the qualitative, elements of marketing compliance. And for example the FTC has started to go after some institutions for the false claims piece - what's your take on that and what can Fintel Connect do to address that risk?

Nicky Senyard: So I think the interesting thing that when we talk to marketing people when we talked to banks with marketing compliance and we break it down into two very distinct pods, I suppose one is things that we evaluate which are things like the wording on a disclaimer - like a fintech can't say they're the bank or the fintech can't say that they're FDIC insured because it's actually the bank that's FDIC insured. So we talked in our world about those terms that can be evaluated, like it's a pass or a fail, it can be evaluated and then you talk about terms that create a misleading environment or in terms of what you’re referencing and we talk about those terms being monitored. It's very interesting that when you do this day in and day out you get to understand what we call trigger terms that when you cluster them all together, they give you a pretty good indication whether it's down that slippery slope giving a wrong impression or whether it's just a term that's being used in an improper context. Because it's the context of these things that are most important not just influencers, and it goes into every type of digital presentation that a third party can do, related to the banking product that they’re connected to the bank with.

So the way that our technology goes especially for websites and content is that we're looking at trigger terms that we monitor like “Free” and “free commission” and all of those sorts of things because we know that from our feedback with our banking partners, what they're looking for is to make sure that the disclosures - or make sure that the context of those words - somebody could put “free” on their website - but when you talk about a free banking product that may or may not be indicative or misleading. So that's the way, we've actually seen that to be really important to the banks that we work with and it was really good insight because we didn't understand that coming into it we were just solely focused on the evaluation element of it because in our Core Business, that's what's really important. But as we started working with the Frontline compliance people we worked out that these trigger terms were of equal importance in their daily function. So that's how we've done it.

As you know, the regulatory bodies each have a slightly different Focus each of the equal importance but some are more on the fair lending side, which is UDAAP and making sure that everything is accessible whereas the FDIC is much more about the things that they're doing. So each body has their own remit as it were and the trigger terms can be similar or different depending on the body that is the dominant audience in the policing of the content.

Zarik Khan: When you're talking about trigger terms that actually leads me to my next question which I will say for the audience's benefit, I had the opportunity to take a look at Fintel Check, one of the products that you all offer. And so one of the features that really fascinated me was what I think it's called “rule manager” - so when you talk about trigger terms and how we think about this rule manager, if you could give our viewers and listeners some background on how this rule manager piece plays into that and maybe just talk about the complexity of what it can handle how does it create instances that you can talk about where you've seen it really really worked powerfully - talk a little bit about that feature in the product.

Nicky Senyard: Absolutely, so the way when you're looking at a tool like this; we had to come up with the logic. Because the fact is if we we’re going to - when we talk about machine learning and artificial intelligence - it's all very well and good, but we want it to be practical and we want there to be utility. So we had to work out how we were going to do it. What we've decided to do is that we decided to have it based on what we classify as rules. These rules are what the engine evaluates the content against to work out whether from an evaluation perspective. the interest rate is correct or it's wrong or to find the trigger term and say we found this.

So the rules we do on different levels - for example with a complex rule we can say an interest rate needs to be 12% or if you say the word “FDIC” needs to be on the page and then we can have what the FDIC disclaimer needs to be - it may be that it passes for the 12% but the FDIC disclaimer is wrong. So what we're trying to do is we're trying to get as much flexibility from a natural logic perspective into using the tool as we possibly can. But the great thing about the way that we've developed our rules manager is it's based on a product feed, which is really unique in the marketplace which means that the user of the tool has almost a library of specific elements like interest rate disclaimer product description. It’s a library. And what happens is that the library data points are then pulled into the rule so you can update the data library, but you don't need to update the rules because it's already automatically connected. All of these little things that we're trying to do to just slipstream the administration of all of the things that are going on. So when the report runs based on the rules, we're actually able to show a screen capture of what we've done on the page to say “Bank name” “product name” rule. There's quite a number of variables in that; we take the screenshot. We can tell you whether the rule was a pass or a fail on the evaluation side and we can show that we found the term on the monitoring side and you can see what rule work associated with it. So, I don't know if that was a very complicated description, but the utility of it is very helpful for discovery and that's what we're trying to do. We're trying to provide all of this information to the compliance analyst in a way that is easy to review and synthesize so that they can actually get on and apply the intelligence that they need to do their job as opposed to the discovery element of trying to find these mentions.

Zarik Khan: I think it really gets to something that, being an auditor myself, it has come up a lot in that, we're not necessarily we're talking about, a tool that's powered by machine learning for example, like Fintel Check, that it's not necessarily replacing the analysts but it’s sort of saving them a lot of time in as you said that discovery piece that feed, that pulling of information piece, and doing that so they can make that decision. But on that point, let's sort of carry it forward - you mentioned machine learning. where do you think something like, artificial intelligence, generative AI Etc, could play into either Fintel Check or just the general tools similar to Fintel Check or maybe your own roadmap in the future. Would love to see how you think it’ll play out.

Nicky Senyard: I think the really interesting thing with cutting edge technology, which is what we know. artificial intelligence is, that any cutting edge technology will more fit itself into uses that we haven't even perceived yet because what I find fascinating is that every element of every person's domain - career domain, whatever else - everybody has one unique problem or unique set of problems that they're trying to solve that something that is as an amorphous - as artificial intelligence - is applied in a really unique way each time. So I think when it comes to marketing and compliance, one of the things that I'm very conscious of is using the tool in a very functional and predictable manner because when it comes to compliance it's about safety and it's about reputation and it's about the regulators. What we're trying to do is use the power of the discernment without giving the power of decision to the tool. So the tool is there providing information, but it's really still up to the analyst to actually interpret that information so that there is still - the human brain is a fascinating thing and it can do multitasking incredibly well in a way that AI I don't know we'll ever be able to do, maybe 20 years time I'll be proven completely wrong. But the thing is you still have to understand what you're looking for and understand the implications of your choices, What do they say garbage in garbage out? So that's my personal view - AI is still a tool. It's a really super cool hot, on steroids tool but it's still a tool which means I don't think our lessons from compliance professionals prevents us from having the ability to use this tool or this intelligence in a really cool manner, but it's still doesn't replace the millions of decisions that a person makes when they look at something. Does that make sense?

Zarik Khan: Yeah, absolutely. I was gonna say, I mean when you were explaining that I was thinking, even if you think about in 2023 - granted, also in 2022 and before as well - but really in 2023 with ChatGPT and generative AI on and on, there was the thought that okay, this is it, like this is the beginning of humans becoming obsolete and what folks found later - granted not limited to fintech or marketing compliance or compliance in general - but they found that a lot of these tools are actually spitting back a lot of fake information not necessarily because of any malicious intent in the program, but what I found in my experience was that these tools are simply not plugged in or looped into enough data; the infinite amount of data. There simply doesn’t seem to be a way yet for that data to fully be integrated into what these tools are capable of.

Nicky Senyard: But I think it's also discernment which is such fragile thing. It's sort of like it can't be described. Discernment is the thing, what it takes - if you look at a professional that's been doing the same thing for 20 years their discernment is going to be so much sharper than somebody that's been doing it for two years, because they've seen so much more. So what I'm talking about with AI, that's why I'm saying in 20 years time. Maybe I'm talking about something different but when I read something that I’ve done or read something that has come through generative AI it's just slightly wrong. Do you know what I mean? But that slightly wrong shows the degree that I can discern that it's slightly wrong, but I've been doing what I've been doing for 25 years. I don't know that a new graduate would necessarily be able to discern that it was 10% off. And that's where I think what we're wanting to do is harness the utility of what this tool does without giving it work to do discernment because discernment still has got to be in the hands of the user in my opinion until I'm proven otherwise, but that's how I just see it at the moment.

Zarik Khan: 100% - I mean that professional you've referred to, the 20 years of professional experience - they had a host of experiences through 20 years that they built on they learned from and I think goes back to the concept of machine learning so that the AI model even in and of itself needs to go through enough of those scenarios, be trained on enough of these scenarios, where then maybe as you said, right - 20 years down the road it is able to have that discernment. Maybe it's not 20 years. Maybe it's two years and it's more accelerated right? But even still it needs to have to some degree, some of the experiences that 20 year professional has. So yeah, I think those are fantastic points.

Nicky Senyard: I think anytime you use anything like a user tool be aware of its power, but also be aware of its pitfalls and then you manage the pitfalls and you take advantage of the powers.

Zarik Khan: 100% agree with that. I think that is very sage advice so, just zooming out a little bit, maybe shifting from AI just to back to the bank versus the third parties, so correct me if I'm wrong, but your product is for banking institutions, who partner with these third parties, is that correct?

Nicky Senyard: Yep, correct.

Zarik Khan: Okay, so when we're thinking about these third parties, obviously the banking institution. I'm sure they're gonna be very interested and want to take advantage of this product. But let's maybe shift to those third parties; have you, in working with these Bank Partners, have you been able to get a sense of how these third parties think about tools like yours you'd mentioned at the beginning policing for example

Nicky Senyard: Absolutely. Yep,…

Zarik Khan: For example, do they feel something like your tool or the services that you provide is maybe squeezing their business or do they actually feel that in the wake of everything that's going on that it might be actually helpful for them. I'm curious what you've seen from the third party perspective.

Nicky Senyard: I actually think people that are genuinely wanting to build a business and generally want to play within the rules would like to take anything on board that will give them the power to be ahead of the pain, the pain being the regulators or if they're just consent orders or whatever else. So we are actually finding that a lot of it all comes down to a price sensitivity, which we're very aware of and really people are wanting to use this sort of tool. It's so early days everybody's just trying to, especially with the Banking as a Service fintech Partners - the banks themselves are building out their pipes. The fintech partners are starting to understand what's required. I think everybody in my experience really just wants to do a good job. And there's so many competitive pressures on everyone that sometimes they make a call with the knowledge that they have at the time and it may not be the right call. But that doesn't mean that there's necessarily any maliciousness or underhanded stuff going on. It's just that they're trying to do what they can with what they've got. So I absolutely find that everybody is sort of really willing to participate. But everybody's being very pragmatic on bottom lines and not wanting to have extraneous overheads with the way that it goes. So that's why what we're trying to do with this tool is make it as pragmatic and as utilitarian as we possibly can because then through the utility it has value.

Zarik Khan: I think that word is very key - pragmatic and pragmatism - because I've heard for those who don't necessarily have as much experience dealing with a regulator for example, or those who maybe never partnered with a third party or a third party never really partnered with the bank before - they might have certain views about the other side of the coin or a regulator and I think when folks start to talk to each other and understand the views including a regulator, I think that comes out. That's what I've seen in my experience as well dealing with, being part of an institution dealing with third parties talking to regulators. Whenever you start talking you recognize that - for the most part - people don't have malicious intent, they’re just trying to do the right thing. It's just sometimes there's miscommunications frankly - those unresolved miscommunications sometimes end up turning into regulatory matters because from a regulator's perspective, they couldn't really get comfort that this control that you have, the process you have, is actually enough to mitigate the risk. So with that said I think that the pragmatism is really the best way to go for everybody's perspective and that's really remedied by more conversation.

So, talking about conversations this has been a fantastic conversation. I hope our viewers and listeners have really learned a lot from you. I know I have, I really just enjoyed, getting your perspective, having a conversation with you about Marketing Compliance, about Fintel Connect about Bank third parties. So as a closing question, where can those folks who might be interested in learning more about Fintel Connect, Fintel Check your product - where would you like to steer those folks who would like to learn more?

Nicky Senyard: Easiest way to do it is on our website, which is just fintelconnect.com. I'm on LinkedIn anybody can reach out to me. I'm lucky that my name is pretty unique. It's just Nicky Senyard on Linkedin, or just nicky @ fintelconnect.com. I think this is a really cool space. We’re coming at it from a very non-traditional point of view, but I think the more people that add their perspective on something that I think is pretty crucially important - because at the end of the day the regulators are trying to protect consumers, they're not doing this because they're trying to be mean, they’re actually doing this because they have a really really important function which is to protect consumers' ability to understand and interact with finance. And so anything that I think we can do to understand the more of the issues, to be able to give utility and practicality to what we do and to hone a product through feedback of actual practical people who are doing the job; I think puts us in a really good position. So I'm really happy to talk to people and I'm really happy to get their feedback and perspective and all of those sorts of things. I think it's a really cool intersection, in time.

Zarik Khan: That’s fantastic; any other closing thoughts before we wrap it up?

Nicky Senyard: I think the openness with which and the willingness with which I'm talking to people in compliance, I find thrilling because they really want to solve the problem and it's a very collaborative approach. And I love the insight into the workflow processes, if you find something how is it handled and where does it go and what's important and all those sorts of things - I really find that we're not there yet, but we've got sort of very grand visions for what this can be in terms of helping people use their time and energy in a very productive manner, so that's what I'm excited about.

Zarik Khan: Yeah, and I would say from our side, I know that among the subscriber base of Fintech Compliance Chronicles there’s a host of experienced knowledgeable compliance professionals who are hopefully watching this as you and I are talking and so I would encourage those who are listening or viewing to reach out to Nicky just to have a conversation. Even if you're not necessarily somebody who can use the product I think it’s just to exchange perspectives. I know I certainly value the conversations I've had with you and your colleagues. So yeah,… I would encourage our viewers to just reach out if they can.

Thank you so much Nicky for your time. I really appreciate it. And best of luck to you and Fintel Connect as you move forward with Fintel Check and all your other products and look forward to speaking to you again in the future.

Nicky Senyard: Thank you so much for having me. I really appreciate it.