Bank Partnership Readiness for Fintechs
The documentation gap between what a bank compliance team expects and what most fintechs actually have is where deals stall. This 4-week engagement produces the complete due diligence package that bank sponsors, OCC-supervised banks, and FDIC-supervised institutions require before executing a program agreement with a fintech partner.
Book a Discovery CallWhy Bank Partnerships Stall
Bank sponsors evaluating fintech partners are essentially running a regulatory examination of your company before agreeing to be accountable for your compliance program. They are looking for the same documentation, controls, and processes that an OCC or FDIC examiner would look for during a third-party risk review. Most fintechs do not have this documentation packaged to that standard at the time they enter partnership conversations.
The result is either a prolonged due diligence cycle that costs momentum and credibility, or a conditional approval with remediation requirements that delay go-live by months. This engagement compresses that cycle by producing the complete package before conversations reach the due diligence stage.
4-Week Delivery Timeline
Gap Assessment and Inventory
Structured review of existing compliance documentation, policies, controls, and vendor agreements. Produces a gap map against OCC third-party risk management guidance, FDIC FIL-29-2024, and Federal Reserve SR 23-4. Identifies the 15 to 25 items the bank sponsor will ask for that the company does not currently have.
BSA/AML and Compliance Program Documentation
Full BSA/AML program written to examination standard: CIP/KYC procedures, transaction monitoring framework, SAR filing policy, OFAC screening controls, and independent testing protocol. Includes the BSA Officer designation memorandum and the written compliance program required under 31 CFR Part 1010.
Third-Party Risk and Information Security Evidence
Vendor risk management policy and register. Information security program documentation. Business continuity and disaster recovery summary. If a SOC 2 Type 2 report exists, annotated summary for bank review. If not yet achieved, gap analysis against SOC 2 Trust Services Criteria with remediation roadmap.
Due Diligence Package Assembly and Executive Summary
Complete package assembled, indexed, and formatted for bank submission. Executive summary written for the bank sponsor's Chief Risk Officer and Chief Compliance Officer. Cover letter addressed to the reviewing institution. Preparation for any follow-up questions or supplemental requests.
What the Package Contains
Written BSA/AML Program
Compliant with 31 CFR Part 1010. Includes CIP, transaction monitoring, SAR, OFAC, and independent testing sections.
Compliance Management System Documentation
Consumer complaint policy, UDAAP monitoring procedure, fair lending risk assessment, and compliance committee charter.
Third-Party Risk Management Program
Vendor risk policy, tiered vendor inventory, risk assessment methodology, and evidence of critical vendor due diligence.
Information Security and BCP Summary
Information security program overview, incident response policy, and business continuity plan summary calibrated for bank review.
Corporate and Governance Documentation
Entity formation, ownership structure, key management bios, and board/advisor governance summary.
Regulatory History and Litigation Certification
Signed certification covering regulatory examinations, enforcement actions, pending litigation, and material complaints.
The Bank Examiner Standard
This package is built by a former Federal Reserve Bank examiner who has reviewed third-party fintech relationships from the bank's side. That perspective matters. A compliance program documented to the examiner standard is not just a document set, it is evidence that the company understands what the bank sponsor is accountable for and has built controls accordingly.
Bank sponsors operate under OCC Bulletin 2013-29 and updated third-party risk guidance from the joint OCC/FDIC/Federal Reserve guidance issued in June 2023. These frameworks establish what the bank's board is responsible for when selecting and monitoring fintech partners. This package demonstrates that the fintech understands those obligations and has met them.
Who This Engagement Is For
- Fintechs in active bank partnership conversations that need to accelerate due diligence timelines
- BaaS applicants approaching Thread Bank, Evolve Bank, Sutton Bank, or similar program managers
- Fintechs that received a conditional approval with remediation requirements as a condition of partnership
- Companies preparing for bank sponsor RFP processes where documentation readiness is evaluated in writing before meetings