Fintech Regulatory Health Check
A structured 10-day compliance gap analysis covering every regulatory domain that matters to an OCC-supervised bank evaluating a fintech partner, a CFPB supervisor reviewing a consumer financial services company, or a Series A investor conducting due diligence on regulatory risk. Delivered as a written report with a prioritized remediation roadmap.
Book a Discovery CallWhat the Health Check Reviews
The health check is not a checklist. It is a structured review by a former bank examiner against the regulatory standards that apply to your specific business model: your product type, your customer base, your bank partner relationship (if applicable), and your current stage of growth. The output is a written report that tells you exactly what you have, what you are missing, and in what order to address the gaps.
BSA/AML Compliance
Customer identification program, transaction monitoring, SAR filing procedures, OFAC screening, and independent testing protocol reviewed against FinCEN's 2016 Customer Due Diligence rule and current examination standards.
Consumer Protection and UDAAP
Product disclosures, fee structures, marketing representations, and complaint management reviewed against CFPB UDAAP standards and applicable consumer protection statutes (Reg E, Reg Z, TILA, EFTA).
Data Privacy and Security
GLBA Safeguards Rule compliance, CCPA applicability, data mapping, vendor data-sharing agreements, and privacy notice adequacy reviewed against current FTC and state regulatory requirements.
Bank Partnership Obligations
If an active bank sponsor relationship exists: compliance reporting obligations, marketing approval requirements, consumer complaint escalation procedures, and program agreement compliance reviewed against executed agreement terms.
Third-Party and Vendor Risk
Critical vendor identification, vendor due diligence evidence, and vendor risk management policy reviewed against OCC Bulletin 2013-29 and 2023 joint agency third-party risk management guidance.
State Licensing and Registration
Money transmitter licensing applicability, state-specific registration requirements, and regulatory exemption analysis reviewed against product and geography of operations.
What You Receive
- Written compliance gap analysis report (30 to 50 pages depending on company complexity)
- Risk-rated gap register: Critical, High, Medium, Low priority for each finding
- Prioritized remediation roadmap with 30/60/90-day milestones
- Regulatory reference citations for every finding so your team understands the source
- Executive summary (3 to 5 pages) formatted for board, investor, or bank partner distribution
- 30-minute debrief call to walk through findings and answer questions
When to Commission a Health Check
The regulatory health check is the right starting point when you know you have compliance gaps but do not yet know which ones are material, how to prioritize them, or how to communicate your compliance posture to a bank partner or investor.
It is also the appropriate engagement when a bank partner's compliance team has asked questions the company cannot confidently answer, when an investor's legal counsel has flagged regulatory risk during diligence, or when the company is approaching a growth threshold that will bring new regulatory obligations into scope.
Many companies commission the health check before the Bank Partnership Readiness engagement to ensure the remediation scope is accurately understood before a higher-investment project begins.
Typical Findings Across Fintech Business Models
- Payments platforms frequently have gaps in OFAC screening documentation, Reg E error resolution procedures, and state money transmitter licensing analysis.
- Lending platforms typically have gaps in adverse action notice procedures, fair lending risk assessments, and UDAAP review of underwriting criteria.
- BaaS-enabled products commonly have insufficient BSA/AML program documentation and inadequate evidence of consumer complaint escalation to the bank sponsor.
- Savings and investment products frequently have FDIC pass-through insurance disclosure deficiencies and incomplete GLBA privacy notice and opt-out procedures.