Fractional CCO for Fintech Companies
Ongoing compliance leadership at a fraction of the cost of a full-time Chief Compliance Officer. Structured for post-seed fintech companies approaching CFPB supervision thresholds, BaaS fintechs with active bank partner obligations, and growth-stage companies where a permanent CCO hire is premature but compliance gaps are not.
Book a Discovery CallWhy Fintechs Hire a Fractional CCO
A full-time Chief Compliance Officer at a funded fintech typically costs $250,000 to $350,000 in total compensation. At the post-seed stage, that capital is better deployed in product and engineering. But operating without compliance leadership creates exposure that compounds: bank partners begin asking questions the company cannot answer, CFPB supervision brings scrutiny to programs that have not been documented to examination standards, and BSA/AML obligations continue regardless of headcount.
A fractional CCO engagement delivers structured compliance leadership within a fixed monthly retainer. The scope is calibrated to what the company actually needs at its current stage. The output is documentation, programs, and processes built to the standard a bank examiner or bank partner would accept.
What the Retainer Covers
BSA/AML Program Maintenance
Monthly review of the BSA/AML program, suspicious activity monitoring thresholds, SAR filing obligations, and CIP/KYC policy currency. Ensures the program remains calibrated to actual transaction volumes and product risk.
UDAAP Compliance
Review of consumer-facing materials, marketing copy, product disclosures, and fee structures against CFPB UDAAP standards. Flags representations before they reach regulators or enforcement staff.
Bank Partnership Obligations
Management of ongoing compliance reporting to the bank sponsor. Covers quarterly reporting deliverables, complaint data, suspicious activity summaries, and policy certification requirements under the program agreement.
Regulatory Examination Readiness
Continuous maintenance of the compliance documentation package. When a bank examiner or state regulator requests materials, the package exists, is current, and is organized to produce at short notice.
Policy Library Maintenance
Quarterly review and update of all compliance policies: BSA/AML, data privacy (GLBA, CCPA), vendor risk management, consumer complaints, and product-specific regulatory policies.
New Product and Feature Review
Compliance review of new product launches and feature changes before deployment. Identifies regulatory mapping gaps, disclosure requirements, and any required policy updates before the product reaches consumers.
Who This Engagement Is For
- Post-seed fintechs approaching CFPB supervision thresholds — companies crossing $10B in annual consumer credit originations or $5B in consumer payments become subject to CFPB supervisory jurisdiction. The compliance program must be in place before that threshold, not after.
- BaaS fintechs with active bank partner agreements — program agreements with bank sponsors create ongoing compliance reporting obligations. These are not optional. The fractional CCO manages those obligations on a monthly cycle.
- Growth-stage fintechs that have outgrown self-managed compliance — founder-managed compliance documentation does not scale past Series A. The fractional CCO builds the institutional compliance infrastructure that supports institutional fundraising.
- Fintechs in bank partnership conversations — if the bank sponsor's compliance team is asking questions the company cannot answer, the fractional CCO engagement resolves that within the first 60 days.
What You Get Each Month
- Monthly compliance status report covering open items, regulatory calendar, and policy maintenance status
- BSA/AML program review and suspicious activity threshold calibration
- UDAAP review of new marketing copy, product disclosures, and fee communications
- Bank partner monthly reporting package preparation
- Policy library review against current regulatory guidance
- New product and feature compliance review (within 5 business days of request)
- Direct access for compliance questions (email, 24-hour response commitment)
- Regulatory calendar monitoring with 90-day advance notice of applicable deadlines
Regulatory Experience Behind the Engagement
This engagement is led by a former Federal Reserve Bank examiner with senior compliance and risk roles at Goldman Sachs, AIG, and BMO Financial Group. The compliance programs built in this engagement are built to examiner standard, which means they are built to withstand scrutiny from the institutions that will review them: your bank sponsor's compliance team, CFPB supervision staff, and state regulators.
The distinction matters because compliance documentation built to a template standard will not hold up under examination. The structure, the controls, the testing protocols, and the audit trails all need to reflect how a regulator thinks about compliance programs, not how a compliance software vendor packaged them.