Specialized Advisory

BaaS Compliance Advisory

For program managers, embedded finance platforms, and BaaS providers operating under sponsor bank program agreements. Compliance obligation mapping, BSA/AML ownership, UDAAP at the program manager level, and ongoing sponsor bank reporting. Enforcement context drawn from Blue Ridge, Evolve, Sutton, and Cross River actions.

What Is Included

  • BaaS program compliance framework

    End-to-end compliance program tailored to a program manager operating under one or more sponsor bank program agreements. Calibrated to OCC, FDIC, and Federal Reserve third-party risk management guidance.

  • Program agreement compliance obligation mapping

    Line-by-line mapping of every compliance obligation embedded in your sponsor bank program agreement, with owner assignment, evidence requirements, and reporting cadence.

  • BSA/AML program for BaaS context

    BSA/AML program calibrated to the unique transaction monitoring, KYC, and OFAC obligations of a BaaS program manager. Includes bank sponsor reporting workflow.

  • UDAAP review at program manager level

    UDAAP review of embedded product marketing, in-app disclosures, complaint handling, and customer-facing communications. Calibrated to current CFPB enforcement and recent BaaS enforcement actions.

  • Sponsor bank audit preparation

    Audit-readiness assessment, evidence packaging, and walkthrough for sponsor bank quarterly or annual audit cycles. Includes mock bank examination prep.

  • Third-party and sub-vendor risk management documentation

    Vendor inventory, due diligence playbook, and ongoing monitoring framework that meets sponsor bank pass-through TPRM expectations.

  • Multi-bank relationship coordination

    For BaaS providers operating under multiple sponsor bank agreements: harmonized compliance baseline, per-bank reporting calibration, and conflict resolution between divergent sponsor bank requirements.

  • Enforcement action gap analysis

    Structured comparison of your current program against the compliance failures cited in recent BaaS enforcement actions (Blue Ridge, Evolve, Sutton, Cross River), with remediation priorities.

Who This Is For

  • Program managers operating one or more BaaS programs under sponsor bank agreements
  • Embedded finance platforms negotiating, renewing, or remediating a sponsor bank program agreement
  • BaaS providers managing multiple sponsor bank relationships and needing a unified compliance baseline
  • Community banks and credit unions launching or auditing a fintech sponsorship or BaaS program

How It Works

  1. 01
    Discovery and scope (week 1)

    Program intake, sponsor bank agreement review, identification of immediate remediation pressure, and scoped engagement plan delivered end of week one.

  2. 02
    Compliance framework build (weeks 2 to 5)

    Program framework, obligation mapping, BSA/AML program, UDAAP framework, and TPRM documentation built or revised. Weekly working sessions with the program team and direct coordination with sponsor bank counterparts where appropriate.

  3. 03
    Audit readiness and walkthrough (weeks 6 to 8)

    Mock sponsor bank audit, evidence packaging, and walkthrough with the bank's BSA officer counterpart (subject to bank approval). Final remediation roadmap delivered.

  4. 04
    Optional retainer continuation

    After project delivery, optional transition to monthly retainer for ongoing program management, sponsor bank reporting support, and remediation tracking.

Building a BaaS Program?

Compliance infrastructure for BaaS programs that satisfies OCC, FDIC, and Federal Reserve third-party risk guidance.

Discuss BaaS Compliance

Not legal advice. Clients requiring legal counsel are referred to qualified fintech attorneys.