Engagement 02

Bank Partnership Readiness

Everything the bank's BSA officer will ask for, assembled and organized. Four weeks to a complete compliance documentation package built for fintechs with an active sponsor bank conversation or signed LOI. Includes mock bank due diligence walkthrough.

What Is Included

  • Complete BSA/AML policy suite

    Written or reviewed BSA/AML program, AML risk assessment, KYC and CIP procedures, transaction monitoring framework, and OFAC screening policy. Calibrated to sponsor bank examination standards.

  • UDAAP compliance manual

    Marketing and disclosure review framework, dispute and error resolution procedures, and ongoing UDAAP review cadence. Built around CFPB enforcement priorities and current bank examination expectations.

  • Third-party and vendor management framework

    Vendor inventory, due diligence playbook, contract clause library, and ongoing monitoring framework aligned to OCC, FDIC, and Federal Reserve third-party risk management guidance.

  • Consumer complaint handling procedures

    Intake, classification, investigation, response, and reporting workflow. Calibrated to CFPB complaint database expectations and sponsor bank reporting requirements.

  • Data privacy and GLBA Safeguards Rule policy

    Information security program, vendor data handling agreement framework, and incident notification workflow that meets the current Safeguards Rule.

  • Incident response plan and BCP summary

    Cybersecurity incident response playbook, breach notification workflow, and business continuity summary that satisfies FFIEC IT examination expectations.

  • Board-level compliance program charter

    Compliance committee charter, BSA Officer job description, and regulatory change management process. The governance evidence sponsor banks actually read first.

  • Mock bank due diligence walkthrough

    A structured walkthrough that mirrors the actual sponsor bank BSA officer review. Identifies gaps and rehearses how you present the program before the real conversation.

  • Three revision cycles included

    After delivery, three rounds of revisions to address sponsor bank feedback or in-house review notes before the package is considered final.

Who This Is For

  • Fintechs in active sponsor bank conversations or with a signed LOI who need the documentation package
  • Embedded finance providers building bank partnership infrastructure from scratch
  • BaaS companies managing multiple bank relationships and needing a unified compliance baseline
  • Founders who have failed a prior sponsor bank due diligence and need to rebuild the package before the next conversation

How It Works

  1. 01
    Intake and document audit (week 1)

    Full intake call, existing policy and procedure audit, and inventory of what exists, what is missing, and what needs to be rebuilt. Engagement plan delivered end of week 1.

  2. 02
    Structured build (weeks 2 and 3)

    Policies, procedures, and frameworks built or revised. Weekly working sessions to walk drafts and adjust to your business model. All documents reviewed against current sponsor bank examination expectations.

  3. 03
    Mock due diligence and refinement (week 4)

    Mock sponsor bank BSA officer review of the package. Findings worked back into final documentation. Final package delivered end of week 4.

  4. 04
    Three revision cycles post-delivery

    After delivery, three rounds of revisions to address sponsor bank feedback, in-house review notes, or new regulatory developments before the package is considered final.

Ready to Approach a Bank Partner?

Four weeks to a complete compliance package your bank sponsor can actually approve.

Discuss Bank Partnership Readiness

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