Fintech Compliance Insights

Three bank sponsors received consent orders in 2024 and 2025 with explicit requirements around fintech partner oversight. Here is what changed, what it means for program managers and fintech clients, and which compliance controls became non-negotiable as a result.

The Federal Reserve's SR 26-2 guidance extended model risk management requirements to fintech partners of supervised banks. This piece covers what the guidance actually requires, how examiners are testing for compliance, and the documentation gaps most common at fintechs operating AI underwriting systems.

Bank sponsors are conducting materially more rigorous due diligence on prospective fintech partners than they were two years ago. This piece walks through each workstream of a current-standard bank due diligence process and explains what documentation you need before you sit down with a prospective bank sponsor.

UDAAP enforcement has shifted from marketing claims to product design. The CFPB's current focus areas include fee transparency, default product configurations, and AI-assisted customer communications. Here is how to assess your product's UDAAP exposure using current examination priorities as the benchmark.

FinCEN guidance and bank sponsor expectations for fintech BSA/AML programs are not the same thing. Bank sponsors are accountable for fintech partner AML compliance and their expectations often exceed the regulatory floor. This piece covers the gap and how to close it.

The FDIC's updated CRA rules create new opportunities for community banks to claim CRA credit for fintech partnerships serving low-to-moderate income populations. Here is how the credit works, what documentation is required, and how to structure a bank partnership to maximize CRA value for both sides.