Thorny Laws That ICHRA Vendors Should Consider, Part Three: FinTech Edition

We continue our series on the legal and regulatory challenges facing individual coverage health reimbursement arrangements (ICHRAs); this time, we are focusing on the fintech-related requirements that may apply to ICHRA vendors. In part one of our series, we summarized an array of health benefit plan and third party administrator compliance requirements with a brief mention of money transmission considerations. In part two, we further explored other health benefit plan compliance issues as well as tax and insurance agency topics. In part three (this article), we explore an array of financial services laws and regulations that may apply to many ICHRA vendor activities, many of which may surprise you.