Episode 8 – Discussing Digital Performance Marketing with Alana Levine

Fatima Rangwala [0:00] Hi. Welcome to another exciting episode of The Martech Cube Podcast. Joining us today is Alana Levine, a true visionary and the Chief Revenue Officer (CRO) of Fintel Connect. Fintel Connect, headquartered in Vancouver, stands as a trailblazer in performance marketing technology tailored explicitly for the financial sector. It adeptly navigates the nexus of technology and financial services, transforming affiliate marketing into a potent conduit for delivering consumers invaluable insights on banking alternatives, credit cards, and more.

Alana is a highly sought-after speaker, an author of insightful articles, and a riveting interviewee. As an industry luminary, her journey is a testament to her unwavering passion for propelling change and innovation in this domain. Complementing her professional journey are her academic accolades, including bachelor's degrees in economics and psychology and a post-graduate degree in finance from McGill University.

I am your host, Fatima, and in this episode with Alana, we'll explore the critical realms of marketing and compliance within banking as a service. Alana will illuminate why these aspects are pivotal and delve into her team's adept approach to discuss strategies for navigating compliance intricacies. We’ll also delve into Alana's inspiring journey, her visionary endeavors to enhance investment opportunities in the financial services sector, and her multifaceted expertise spanning diverse topics such as investment opportunities, digital marketing, performance marketing, and campaign optimization for BaaS partners. With a global footprint in over 50 markets, Alana has made an indelible mark as a founding pillar of Fintel Connect.

Without further ado, it is with great pleasure that we welcome Alana to this podcast.

Thank you for joining us, Alana!

Alana Levine [02:10] Thank you. What an introduction, Fatima. Thank you so much. I'm really excited to be here.

Fatima Rangwala [02:20] All right, thank you. And, it's a pleasure, Alana, definitely. So, before we get into our conversation, I think it would really help if we could get enlightened on why marketing and compliance are so crucial, especially for banking-as-a-service?

Alana Levine [02:42] Sure.

I think for those who are listening in who may not necessarily be as familiar as to the relationship between the Fintech ecosystem and the banks that really support them, it's important to understand that these partnerships are very co-dependent. There's amazing innovation that's happening with new developing financial services products. And these fintechs need to partner with these back end banks who own the banking licenses and can help support and provide the foundation for them to deliver their products to their audiences. And so what happens is these fintechs are innovators. They're amazing marketers. They really know how to build a brand. However, it's important for them to work really congruently and closely with their banking-as-a-service partners or those back end banks that are really providing them with that financial foundation. And so from a compliance standpoint, what happens is these back end banks are the ones that hold the licenses and the ones that the regulators will hold accountable for these fintechs to make sure that they are aligning and complying with the appropriate regulations from consumer production, UDAP, regulations that make sure that there's fair lending practices, appropriate transparency with how products are being marketed.

And the fintechs are experts at what they do in marketing and growing their brands. They don't always understand the nuances and complexities. And what's happening is as things are moving forward so quickly and back in banks are bringing on many more partnerships in the fintech arena, it becomes really challenging for them to start to kinda able to manage and have full transparency over what their fintech partners are doing. So, it's becoming more and more critical and the regulators are paying a lot more attention of what they're doing, which is why the compliance element is so important for them.

Fatima Rangwala [04:42] Right. Right. So, you spoke about accountability, and it's really important to embrace the entire cultural shift and perhaps uphold the paramount importance of the dichotomy of security and regulatory compliance in the BaaS model. Because definitely when it comes to accountability, it's also the customer trust and safeguarding that data security. These are two indisputable priorities, Alana. When we draw upon your expertise when it comes to all of this, can you elaborate on how you or Fintel connect address compliance and legal standards within the intricate landscape of the financial sector going forward?

Alana Levine [05:35] Yeah, I mean we’re learning just as much as anyone else. I think maybe I can give a bit of background to how we got into this space.

Fatima Rangwala [05:42] Sure!

Alana Levine [05:43] So as you mentioned in the introduction we started our business and really the acorn of our business and foundation is on the affiliate and partner marketing side of things. So we actually power the affiliate programs for a number of major enterprise banks and Fintechs and brands in the U.S. and Canada. And what we found is this channel is such a significant part of their acquisition funnel. And as you expand out and have 50, 100, 200 of these third-party marketing partners talking about your financial brand in a highly regulated sector, it becomes really tenuous. The marketing teams are having to go to the compliance teams and be able to demonstrate how they're actually keeping an eye on what these third parties are saying. And that's really why we developed the first iteration of Fintel Check, our compliance tool was because it was just too much heavy lifting to try and manually monitor what all of these different partners are saying.

And the things that they're monitoring for are things like making sure interest rates are accurate and up-to-date, because otherwise the regulators would consider that as misleading.

If there are certain promotional offers, are there accompanying disclosure language in the marketing content that makes sure that customers that are reading this information or reading the marketing campaigns actually have the right education to understand what they're signing up for because financial products are such a critical - it's not like buying a pair of jeans, it's something a little bit more in-depth. And so long story short, what happened was we had a client of ours that we were marketing their products on these third-party sites. They also happened to be a backend bank. They approached us and said, “Hey, we have all these fintech partners that we are helping to power and be the backend of, can we use this tool to monitor what they're doing? Because my team is doing it all manually at the moment. And that's really where we ended up pivoting and building out this new iteration of our tool, what we're calling Fintel Check for BaaS, because it's a similar application and a similar criteria. So really, when you talk about what our contribution is or where we see our role from a compliance and legal standard standpoint, we see ourselves as a facilitator and as a tool to help compliance team, who are having to do this work manually have something that's going to allow them to automate some of the functions that they need to be able to do and do it more comprehensively.

So what we're looking to do is really, as I said, we're learning is, how do we build out a standard? How do we build out what we call rules repository? What are the things that most backend banks are having to monitor for? And how do we create standards on how we build all of the things that they are going to be monitoring for and need to hold their fintech partners accountable for? I think a lot of them have their own internal understandings. They follow the regulations to the best of their abilities. The regulations are changing all of the time. The expectations of the regulators are changing all of the time. So, we see ourselves as wanting to take the mantle of helping educate the compliance teams that there's a better, more comprehensive way, giving them tools to be more efficient with what they do, and helping to create a bit of a standardized ruleset and guidelines for how they can appropriately monitor the things that they need to be watching for with their Fintech partners.

Fatima Rangwala [09:17] Yeah, I think that's quite insightful and does make sense. So, you've come from a transition from the BaaS perspective and exploring your insights on completely navigating the landscape of risks and regulations and the adherence and the best practices - to building up completely a customizable framework where you can provide possibly a valuable asset for banks and fintech partners, and navigating the entire complexity of all of this regulatory adherence. So, before we move into a deeper discussion related to that, our listeners would really find it useful if you could shed some light on if there are any specific features or technological innovations that set your tool apart, like you have with Fintel, the tool that sets anything apart, anything that you can highlight about this feature, that would be really great.

Alana Levine [10:35] Sure. I think some of the things that we really looked to deliver for our partners and especially, I mean, their BaaS or backend banks, sponsor banks that are at various stages of their journey in building out this arm of their business. Some are very mature and have 15 to 20 fintech partners. Some sponsor banks have one or they're just looking to get into the space and they're wanting to get ahead of things and really plan and prepare and make sure they have the right foundational structures in place to do so. What we wanted to do is really focus on building functions into the technology that were exactly what these backend banks are going to need. There's amazing technologies out there that are super comprehensive and sometimes can be overwhelming and create even more work to these different compliance teams. So what we wanted to do is help create some functions that will help streamline things. So, for example, our ability to call different content into our rules so that if an interest rate has changed for a fintech partner, then the tool already knows that that's what to expect, and the next time it scans, it'll be able to update the rule and automatically scan the content on the fintech pages or wherever the sponsor bank's brand is being mentioned, for example, and then be able to evaluate that content.

There's an AI component to the tool where it's looking at building its knowledge of how contextually information is being shared within different marketing campaigns. So being able to pick out what we call trigger terms and looking at are those terms something to be concerned about, or are those terms just something to be aware that they're there, whether that the fintech is it appropriately, and then creating an easy system to be able to remediate any potential issues that have been flagged. We have something called our link manager. The link manager is meant to show you exactly where all of your campaigns or mentions are living, so even down to the specific referral URL and page. And then we store all of the data, so it's easily accessible from a reporting standpoint to give to the auditors, to give to your compliance and risk team. And all of the data is meant to be really consumable to evaluate, to be able to remediate, and then to be able to share and have a historical record of this, so that in cases where, for example, a regulator flagged something that they identify as an issue, which has been happening more and more now, that the compliance teams can say, Oh, okay, I can actually tell you exactly how long this is persistent for.

I can tell you how much traffic has been on that page, and therefore we can evaluate and quantify what the potential risk was and demonstrate more than anything. And this is actually feedback from one of our clients that we've been working with is, it's the idea that you can demonstrate to the regulators that you're taking proactive steps and that you have a way to actually manage it. That's the biggest thing that they're looking for is that the backend bank has a system and a plan in place for how they can manage it. Really, that's what we looked for our tool to be able to give these sponsor banks.

Fatima Rangwala [14:08] That's really insightful. Is this around the AI tool? The tool is about AI. Is it got to do something with the artificial intelligence as well? Or is it just something that's really manual at the moment?

Alana Levine [14:23] If I understood your question correctly, it's the AI component.

Fatima Rangwala [14:27] Yeah!

Alana Levine [14:28] Is what. The intelligence that the machine needs to basically be fed to. It's constantly learning every time it's going out and crawling different pages within the web. It's learning and it's teaching itself how to get more accurate and to better pick up on nuances of how text is incorporated. We often get asked, “How does your tool know? And it's talking about a credit card on a page that it's, My fintech partner's credit card product and not a competing product.

Fatima Rangwala [14:59] Precisely!

Alana Levine [15:00] And that's where the engine has to learn and has to be able to better pinpoint. And it's well beyond my knowledge. I'm not the person who's built it from a technical standpoint, but functionally, it's a critical part of actually the tool having value for our partners.

Fatima Rangwala [15:16] Correct. And I think it's all about adaptation with the changing times. And it also leads to how these tools can build trust and credibility with the finance partners. So, is there any particular framework that you follow when it comes on how can they build trust and credibility rather through a compliant marketing approach? Can you let our listeners know about that as well?

Alana Levine [15:47] Yeah. I think that the foundation of this, more than anything else, is just as much transparency as you can create both internally between marketing team and compliance team, as well as externally between compliance and the Fintech partner. A lot of these fintech partners, they've never run a bank before. They don't understand the nuances. They may not have invested in hiring a compliance person internally. They may have consultants externally, and it's something that they're still trying to navigate. And so I think the more that you can create that sense of transparency and setting expectations upfront on what needs to happen and to understand from both perspectives. I mean, the fintechs want to move at lighting speed and get everything they need to get done as quickly as possible, because that's how they stay competitive and that's how they grow business. But the banks are appropriate in the areas that they need to be cautious about and things that they need to be monitoring for to make sure that the fintech doesn't massively step out of line. So coming with an understanding of both of those things and saying, “Hey, I acknowledge you want to move quickly. Let's find a way where we can create a process or have something in place that allows us to work more effectively, collaboratively.

And so what we see for our tool, at least, is it's a conduit for A, creating that transparency. So there's no guesswork on what the sponsor banks are looking for. The fintechs know, they can log in, they can see what's going on themselves, and it helps them more proactively manage and make sure that they don't have a misstep, and it gives the sponsor bank comfort that they've got a partner and that the fintechs are acknowledging and understand what needs to happen from a compliance standpoint.

Fatima Rangwala [17:55] Absolutely. I think it's rightly said that transparency and collaboration and fostering successful partnerships definitely goes a long way. So having said that, I think we can now shift our focus to understanding some of the challenges that BaaS partners might encounter when balancing compliance with growth marketing efforts. So what to your knowledge, Alana, are those?

Alana Levine [18:27] Yeah. I think it's what I said earlier as a start about how the fintechs want to move at and the banks are often seeing this just holding them back and are a pain in the butt to have to deal with and work with. I think a challenge for the sponsor banks up until this point is that they had their legacy systems and how they manage things. They've almost applied - our observation is they've applied similar approaches to how they manage their own internal marketing, meaning the bank that's marketing to their own direct customers versus their having to manage what their fintechs are doing. And I think that's not necessarily the most scalable approach. I think a lot of the compliance teams we meet don't have necessarily the biggest budgets to implement tools. Not a lot of tools have necessarily existed in the way that they have needs now for how they're managing their fintech partners. And as they bring on more and more fintech partners, it just gets more and more unmanageable because you're multiplying the volume of what the compliance teams are having to keep an eye on.

And so the manual effort and the time, intensity that it takes and the budget that it ends up requiring. I mean, as soon as you bring on more fintech partners, a lot of these banks are having to hire more people. Finding good people to hire is a challenge. I mean, there's so much movement we're seeing at the moment between sponsor banks and the compliance department, where they're losing staff, gaining staff to train them up again, it's challenging. And it's an area that's just constantly growing and getting more and more competitive. And so, I think finding ways to create those efficiencies and really just to give their teams leverage so that they can do their jobs better, focus on supporting the fintech partners, and that kind of grunt work, manual, heavy lifting stuff can get taken care of by a tool that helps to automate those things.

Fatima Rangwala [20:32] Right. I think you've given us a lot to think about, Alana, and definitely it's clear that balancing, compliance and collaboration in the BaaS landscape is a multifaceted challenge, definitely. So, I think we'll pivot and dive more into understanding how fintech partners, rather, can foster a culture of compliance within their organization and align their marketing goals with legal and ethical standards involved. How is your approach on that?

Alana Levine [21:11] Yeah, I think it's a lot of the early movers on the fintech side of things have skinned their knees in this area because as I said, it's not necessarily something that they prioritized when they were launching their product. I hate to say it, but when you're a small scrappy fintech that doesn't have a lot of exposure and is still figuring things out, the risk to the regulators is a lot less. If you take a time versus a newly launching brand, not a lot of people hear about the magnitude of the potential, and it's the same that applies in the banking space. I mean, the regulatory hurdles and requirements of the megabanks is very different from those that are community-centric. And that's just because of the potential risk to the economy, to the masses and volume of consumers. So I think no matter where these fintechs are, I think that now what's happening is the earlier on their trajectory, whereas before the small fintechs just didn't prioritize it. Now I think they're realizing they need to, especially if they're going to secure these partnerships with the backend banks. They have to really invest in recognizing the value of compliance, the importance of it, and having it be part of the initial requirements and it gets embedded and incorporated into their processes and procedures early on, because then it becomes just a well-worn muscle. You have a team that's trained to know what they need to be looking for, to know what the backend banks and their sponsor partners are going to expect, and that they stay ahead of it. Then from there, it becomes a lot easier to be able to innovate more quickly, launch new campaigns, and do things more efficiently because you've worked out the mechanics and the partnership between Fintech and backend bank becomes just this really well-oiled machine.

Fatima Rangwala [23:06] Yeah, I think the compliance team has often assumed the role of the bad cop within an organization. With your insights, I think it's reassuring that you're here to show that compliance can actually have a softer side, sort of like a good cop in the world of regulatory rules and-Yeah, I think that does make sense, definitely. All right. I think to continue on a quest to demystify how the compliance is, speaking of which what are some of the effective methods for conducting the compliance training for marketing teams? We've spoken about the growth marketing. We would like to know about what is the conducting compliance and how BaaS partners are ensuring their marketing staff is definitely if they are well informed about the regulations or certainly they're not. How is this being applied to their activities?

Alana Levine [24:15] Again, I think it's about setting those expectations upfront and creating something that's just easy to use and is something that's scalable. So even when it comes to security training, it's something that happens regularly. A lot of these banks, it's something that probably happens even monthly. So, helping the marketing teams understand the requirements from a compliance standpoint, what we're finding is there's regular materials, regular updates, regular meetings where it's really clear what's prioritized making information much more consumable so that they understand what's a priority one, compliance requirement versus a priority three, compliance requirement, and what are the things that - and what are the remediation plans and what are the expectations of how marketing should be reporting into compliance and vice versa? So the more that you can create that structure, as that team grows, they're going to have a much better understanding and a much stronger foundation on what needs to happen. I think having tools in place like ours is a way to do that. I think a lot of compliance teams and marketing teams in banking-as-a-service have managed to this point.

And when you're just getting started, it might be good to start even manually and look at how do you handle one fintech partner and what's the marketing team's role, what's the compliance team's role, and what are the things that we need to step through? And then as it scales, you can recreate that in an automated system. And so we're finding, I think, a lot of backend banks are doing that. But I'd say the expectation settings, standardized processes, regular check-ins and touch points, and a structure from a reporting standpoint will be really key, because then that becomes the foundation. Any new staff coming in, they've got that training ready to go, and they're inducted into a system that again, is really well fleshed out.

Fatima Rangwala [26:43] Right. And I think compliance is really not a one-time effort. So it requires definitely an ongoing monitoring and adjustments. So that goes a long way too. So I think, Alana, what are the best ways for BaaS partners to establish a process to review and update their marketing strategies regularly to ensure that they remain compliant with industry regulations?

Alana Levine [27:15] Yeah. I mean, it's something where the compliance teams need, again, to have that framework and structure. When we are creating rules in our platform for our banking partners, our sponsor bank partners, we're using the standard, most like critical content monitoring required rule sets or logics. So again, things that relate to UDAP, things that relate to Reg Z and Reg DD, which are regulations around lending, checking, and unfair or deceptive marketing practices, all of those things feed into this process. And so I think there's things that are just always going to be that foundation of rules and requirements that they're going to have to be monitoring for. But between the FTIC and the FTC, and I'm speaking mainly to the U.S. market here and the OCC, those regulatory bodies are looking at as new products are being launched, whether it's in the crypto space, whether it's blockchain technology and real time payments, all of these different types of new products that are being launched and being supported by these backend banks come with new required expectations of information and transparency and what these back end banks need to be aware of.

And the regulators are still, to be honest, probably figuring things out and trying to understand what are the risks, what are the things that the back end banks really need to be careful of with how these products are positioned.

And I think those are the areas that really have been the catalyst, these new developments for the banks to - for the regulators to wake up and say, okay, there's a lot of these other areas, even in just our standard financial services space, that we need to do a better job of keeping an eye on. And so I think going to directly to these regulatory outlets, all the information is available on their website. They issue being signed up to all of their newsletters, even having feeds where it can feed in information to you on a regular basis and updates to this regulatory content. A lot of banks have compliance officers and risk officers that are responsible for these things. But then it's about how do you disseminate it down to those that are operationalizing it? And I think that's what's really critical. I think knowing what to watch is not as much the issue as it is how do you actually do it at scale.

Fatima Rangwala [29:53] In your opinion, what are some of the best approaches that BaaS partners can adopt to achieve their growth objectives while still staying within the boundaries of compliance regulation?

Alana Levine [30:10] What I would say to that is I think again, the backend sponsor banks have been doing a lot of this heavy lifting manually. So they're working with their fintech partners. And what generally happens is the fintech partners will submit content or campaigns or landing pages or information or new disclosure documentation regularly. Usually it's once they launch and then ad-hoc here and there. And that's really when the compliance teams have a review, look through everything, and then sign off on it, and it goes live. I think the biggest challenge is the fintech partners will make some minor changes here and there. They'll update some of the language, and they don't understand that there could be potential issues with that when their sponsor bank partners are not aware of it. And when they don't have oversight over it, and it's hard for them to keep an eye on things, it makes it difficult when they have to come back to their fintech partners and say, Hey, we can't allow you to make any changes now when we haven't had a chance to review it first because of what the potential implications are with the regulators. And so I think the sponsor banks are now looking at more efficient ways to implement tools.

And we're talking about compliance in the context of marketing, but compliance comes in a whole range of areas when it comes to how they work together from KYC and AML, which is knowing-your-customer validating, understanding and properly evaluating who they are, as well as from an anti-money laundering standpoint, having the right structures, processes, tools in place, all of these things come in. We're just talking about it from a marketing standpoint once there's offers and content in market. And so I think the backend banks are implementing tools that help facilitate a more efficient and effective relationship with their fintech partners. And so obviously one of those tools is ours, but there's many others. And I think that's a great way for the best partners to demonstrate that, hey, we understand the backend banks benefit when their fintech partners are to grow and do what they do well, but they have the appropriate controls in place to make sure that they're reducing the risk of what those fintech partners are doing and have a more efficient way of managing what they're doing.

So, I think from that standpoint, there's a lot of really great progress we're seeing in the space and it's exciting.

Fatima Rangwala [32:56] Of course, yeah. I think to stay compliant, there also could be a lot of industry specific platforms or organizations that the BaaS partners should be aware of rather. If you can just let us know about those as well.

Alana Levine [33:12] Sure. Obviously, there's ours from a marketing standpoint, but there's tools like one that we've come across a lot recently as a tool called FEMIS. It's a platform that allows you to manage workflows and transparency between fintech partner and sponsor bank, and it touches a much broader and wider breadth of the compliance functions. From that KYC, AML, risk processing and documentation, ledgers, data, information sharing between the two organizations, all of these things I think encompass that. They've been a really cool tool. They went through an accelerator program similar to the one that we did. We've been kinda keeping an eye on them. But there's many others that are out there that the BaaS banks are implementing.

Fatima Rangwala [34:00] All right, thanks for that insight. I think as we conclude this fantastic session, Alana, I think it would be really great if we can share a quote that resonates with you and perhaps even a success story for all our listeners.

Alana Levine [34:19] Yeah. I mean, I think probably a great success story or example is just a few of the sponsor banks that we work with. I can't name them necessarily, but what I can share is I think they've seen a huge…We actually get asked this question a lot is like, how are you evaluated on the impact you're making? I think one thing for certain is in the amount of efficiency and time that we've saved. So they've implemented our tool, they have a much clearer picture of the things that they need to be monitoring for, and it's a much more structured process. And from that standpoint, it also helps with the comprehensiveness of how they're able to monitor what their fintech partners are doing. There's still a lot of kinks to be worked out. I mean, I think they're trying to figure out how does this scale beyond the sample of partners that we've been working with? So they've chosen a subset of their fintech partners, and now it needs to be replicated across the wider mix of their fintech partners. I think also just in the context of how we work with our direct clients and their third-party marketing and how do they better monitor and keep an eye on things.

When we first actually rolled out our tool for one of our BaaS partners, and we ran the tool across our fintech partners, that subset, they had no idea how many pages had incorrect interest rates mentioned for specific checking products that they were offering, which they were like, okay, this is probably something that we can correct. And the success is then seeing the next time we run the scan and the next time that we run the scan, the reduction in the number of what we would call infringements that the tool has actually identified. I think that's been a big success for us as well as just seeing incremental progress being made through the use of the tool, which is, yeah, exciting.

Fatima Rangwala [36:07] Wow, I think, oh, my God, that's an inspiring story and truly the leaders guide to the world of BaaS and compliance. Alana, thank you for such wonderful insights and such impromptu use cases of your clients and the experience and the kind of journey that you have with your partners and with Fintel Connect. I must admit, really, I'm stunned by the wealth of knowledge you've shared with the world today. And heartfelt, thank you for being part of this enlightening session. Your journey and completely the straightforward takeaways you've provided have been exceptional. And special thanks to the entire of Fintel Connect team for making this possible. Really appreciate their efforts and insights.

Fatima Rangwala [36:58] So, this brings us to the end of the podcast. Alana, thank you so much.

Alana Levine [37:06] Fatima, thank you so much for having me. It's been a pleasure. I'm in no way claim to be an expert in this area, but I think there's lots of exciting things happening in the space, and I'm happy to share at least our perspective. Thanks to you and Martech Cube for having us.

Fatima Rangwala [37:21] Our pleasure. Thank you, Alana! To all our listeners, I really encourage you to stay tuned to the Martech Cube podcast for more insight, tricks, trends, and practical know-how from the top minds in the marketing technology space. It was a really great session. Thank you, and until next time.