Recent years have witnessed the emergence and rapid growth of a large, diverse, and constantly evolving shadow payment system. The shadow payment platforms (SPPs) that populate this system perform many of the same core payment functions as conventional deposit-taking banks: including custody,...

The dominant narrative about financial technology holds that change in the financial services industry demands a broad rethinking of regulatory approaches. But the regulation of payment services defies this narrative. Its technology and business-model neutrality makes it relatively well-suited...