And don't they use a bank's services so they don't have to go through the normal 'if you're going to be a bank' scrutiny? I'm guessing that they have a requirem

And don't they use a bank's services so they don't have to go through the normal 'if you're going to be a bank' scrutiny? I'm guessing that they have a requirement from the banking service to vet anything that would normally need underwriting otherwise.