Fintech Compliance Advisory

Compliance Built to
Withstand Scrutiny

Former Federal Reserve Bank examiner. Senior roles at Goldman Sachs, AIG, and BMO Financial Group. Fixed-fee advisory engagements for fintech companies that need bank partner-grade compliance before the bank asks for it.

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Federal Reserve Bank Examiner Goldman Sachs AIG BMO Financial Group NYU Stern MBA Penn State
Castleigh Johnson, Fintech Compliance Advisor and Fractional CCO
10
Days to Regulatory Health Check
4-wk
Bank Partnership Readiness
$350K
Full-Time CCO Cost Avoided
100%
Fixed-Fee Engagements
Core Advisory Services

Three Fixed-Fee Engagement Types

Each designed for a specific compliance inflection point in a fintech company's lifecycle. No retainers without scope. No surprise invoices.

10-Day Assessment $7,500 fixed fee

Regulatory Health Check

Know your compliance gaps before a bank examiner or bank partner finds them. Covers BSA/AML, UDAAP, data privacy, vendor risk, and product regulatory mapping. Delivered as a written report with risk-classified findings and a remediation roadmap.

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4-Week Engagement $25,000 fixed fee

Bank Partnership Readiness

The complete compliance documentation package your bank sponsor will require under 2023 OCC/FDIC/Federal Reserve third-party risk guidance. BSA/AML program, vendor risk register, BCP, and compliance policy library. Built at examiner standard, not template standard.

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Monthly Retainer $12,000/month

Fractional CCO

Ongoing compliance leadership without a $300K full-time hire. BSA/AML program maintenance, UDAAP compliance, bank partnership obligations, and regulatory examination readiness. Structured for post-seed fintechs approaching CFPB supervision or bank partnership milestones.

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Specialized Services

Additional Advisory Areas

BaaS Compliance

Program Agreement Compliance Advisory

For fintechs negotiating or operating under a bank sponsor program agreement. Covers compliance obligation mapping, BSA/AML ownership, UDAAP at the program manager level, and ongoing reporting to the bank sponsor. Enforcement context drawn from Blue Ridge, Evolve, Sutton, and Cross River actions.

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Model Governance

SR 26-2 AI Model Risk Management

Advisory on the Federal Reserve's SR 26-2 guidance for AI and machine learning models. Model inventory, validation framework, documentation standards, and ongoing monitoring protocols for fintech companies using AI in credit decisioning, fraud detection, or compliance monitoring.

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How It Works

From Discovery Call to Delivered Engagement

01

30-Minute Discovery Call

We discuss your compliance program's current state, your bank partnership timeline, and the specific regulatory risk you are trying to manage. I tell you which engagement type fits your situation and why.

02

Engagement Proposal

Within 24 hours I send a fixed-fee engagement letter with scope, timeline, deliverables, and the specific regulatory frameworks that apply to your product and business model.

03

Document Review and Assessment

I review your existing policies, agreements, product documentation, and bank partner correspondence. This review is structured to identify gaps against OCC, FDIC, and CFPB standards.

04

Deliverable and Briefing

Every engagement concludes with a written deliverable. The Regulatory Health Check produces a risk-classified findings report. Bank Partnership Readiness produces a complete documentation package. Fractional CCO operates on an ongoing monthly cycle.

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Which Engagement Is Right for You

Engagement Timeline Fixed Fee Best For
Regulatory Health Check 10 business days $7,500 Pre-bank partnership diligence, investor due diligence prep, understanding current risk exposure
Bank Partnership Readiness 4 weeks $25,000 Fintechs actively in bank partner conversations, program agreement negotiations
Fractional CCO Ongoing monthly $12,000/mo Post-seed fintechs approaching CFPB thresholds, BaaS fintechs with active bank partner obligations
Frequently Asked Questions

Common Questions

What does a fintech compliance advisor do?
A fintech compliance advisor assesses regulatory risk, builds compliance infrastructure, and prepares fintech companies for bank partner due diligence and regulatory examination. Engagements typically cover BSA/AML program design, UDAAP compliance, consumer protection policies, and vendor risk management.
What is bank partnership readiness for fintechs?
Bank partnership readiness is the process of building compliance documentation before a bank sponsor asks for it. Under 2023 OCC, FDIC, and Federal Reserve third-party risk guidance, banks must assess a fintech's BSA/AML program, information security posture, business continuity plan, and compliance policy library before executing a program agreement. Fintechs that arrive at this conversation without documentation in place lose months to remediation cycles.
How much does a fractional CCO cost compared to a full-time hire?
A full-time Chief Compliance Officer at a funded fintech typically costs $250,000 to $350,000 in total compensation. A fractional CCO engagement delivers ongoing compliance leadership at a fraction of that cost, typically structured as a monthly retainer sized to the company's current compliance needs and stage.
What is a regulatory health check for fintechs?
A regulatory health check is a structured compliance gap assessment covering a fintech's BSA/AML program, CFPB supervision exposure, UDAAP risk, data privacy posture, vendor risk management, and product regulatory mapping. It is delivered as a written report with risk-classified findings and a prioritized remediation roadmap designed to be shared with a board, investor, or bank partner.
What fintech compliance regulations apply to BaaS companies?
BaaS fintechs operating under a bank sponsor program agreement are subject to BSA/AML requirements, UDAAP enforcement at the program manager level, Reg E for payment products, GLBA data privacy obligations, and ongoing reporting requirements to the bank sponsor. The 2023 OCC, FDIC, and Federal Reserve interagency guidance significantly increased compliance obligations for BaaS program managers.
Who should hire a fintech compliance advisor?
Fintech companies in four situations benefit most: companies preparing for a bank partnership conversation, companies currently in the bank's compliance review phase, post-seed companies approaching CFPB supervision thresholds, and companies that have received an MRA or bank partner information request requiring rapid response.

Ready to Build a Compliance Program That Holds Up?

Schedule a 30-minute discovery call. We will discuss your compliance program's current state, your bank partnership timeline, and which engagement fits your situation.

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// 30 minutes · No sales pitch · Fixed-fee scope delivered within 24 hours