Engagement 03

Fractional CCO for Fintech

Senior compliance leadership embedded in your team. Ongoing program maintenance, bank partner relationship management, examination readiness, and direct BSA Officer availability for sponsor bank conversations. No full-time CCO hire required.

What Is Included

  • 10 hours of dedicated advisory time per month

    Scheduled working sessions, ad hoc availability, and direct Slack and email access during business hours. No junior staffing.

  • Ongoing compliance program management

    Policy maintenance, procedure updates, training material refresh, and quarterly program review against current OCC, FDIC, and CFPB expectations.

  • BSA/AML monitoring and oversight

    Risk assessment refresh, transaction monitoring framework review, OFAC screening oversight, and SAR referral support.

  • UDAAP review of new product and marketing materials

    Pre-launch review of new product features, marketing copy, disclosures, and customer-facing communications against current CFPB enforcement priorities.

  • Bank partner relationship management

    Direct availability for sponsor bank BSA Officer conversations, quarterly compliance reporting to the bank, and management of ongoing diligence requests.

  • Examination readiness and audit support

    Preparation for sponsor bank audits, third-party assessor visits, and regulatory examination scenarios. Response drafting support for examination findings.

  • Monthly compliance committee reporting

    Board-ready compliance committee report covering program health, key metrics, regulatory developments, and remediation status. The governance evidence sponsor banks expect to see.

  • Regulatory change monitoring and alert service

    Curated monthly briefing on OCC, FDIC, CFPB, FinCEN, and state developments that affect your business model, with action items where relevant.

  • Incident response support

    On-call support for compliance incidents, consumer complaints requiring escalation, and regulatory inquiries.

Who This Is For

  • Fintechs post-bank partnership agreement who need ongoing compliance leadership without a full-time CCO hire
  • Seed to Series B fintechs whose compliance burden has outgrown the founder or general counsel
  • Embedded finance providers managing multiple bank relationships and needing a single senior compliance presence
  • Community banks and credit unions building or auditing fintech partnership programs without a dedicated fintech-CCO hire

How It Works

  1. 01
    Onboarding audit (month 1)

    Full compliance program review, sponsor bank relationship intake, identification of remediation priorities, and 90-day operating plan delivered end of month one.

  2. 02
    Monthly operating rhythm

    Weekly working sessions, monthly compliance committee report, regulatory change briefings, and direct response to sponsor bank inquiries and consumer escalations.

  3. 03
    Quarterly program review

    Structured review of program health, sponsor bank feedback, examination posture, and remediation status. Roadmap adjustments delivered at end of each quarter.

  4. 04
    Annual examination readiness audit

    Comprehensive readiness assessment ahead of any anticipated sponsor bank audit, third-party assessment, or regulatory examination.

Need Ongoing Compliance Leadership?

Monthly retainer. Direct access. No junior staffing. Your compliance program runs without you building it from scratch.

Discuss a Fractional CCO Engagement

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