Audit-ready
Documentation maintained year-round
BSA/AML
Program for FinTech risk profile
180 days
Bank termination notice window
Scalable
Architecture grows with product
Client Snapshot
Industry
FinTech
Solution
IT Consulting | Process Solutions | Data Solutions
Complexity
High
Delivery
Advisory + Program Design
The Problem
Embedded finance platforms operate in one of the most complex regulatory environments in financial services subject to BSA/AML obligations, CFPB consumer protection rules, GLBA privacy requirements, and state money transmission licensing simultaneously, through a sponsor bank relationship that creates additional oversight obligations. Most FinTech compliance programs are built reactively adding controls when regulatory issues surface rather than designing a program architecture that satisfies sponsor bank program audits from the start.
Sponsor bank program management audits are the compliance gate that determines whether a FinTech can continue operating under its bank partnership agreement. These audits probe BSA/AML program quality, complaint handling, UDAAP compliance, and data security at the standard the bank itself would be examined against. FinTechs that treat sponsor bank audits as compliance checkboxes rather than genuine examinations are regularly surprised by findings that threaten their partnership agreement.
Ready to Start?
Schedule a Compliance Program Assessment
Get a candid analysis of your current compliance coverage, sponsor bank audit readiness, and program gaps.
180 days
typical sponsor bank program termination notice period when compliance deficiencies are found unacceptable. That is the operational window a FinTech has to find an alternative bank partner, migrate customers to the new banking relationship, and rebuild compliance infrastructure simultaneously. Prevention is substantially less expensive than remediation at this scale.
How PiTech Delivers
01
Regulatory Scope Assessment
Complete regulatory obligation mapping for the platform’s product set, customer base, and geographic footprint. BSA/AML program requirements, CFPB examination expectations, state MTL compliance obligations, and sponsor bank program terms mapped into a unified compliance architecture design.
02
BSA/AML Program Design and Implementation
Risk-based AML program designed for the FinTech’s specific customer profile, transaction patterns, and fraud exposure — not a generic bank AML program template. Customer risk assessment methodology, transaction monitoring approach, SAR filing workflows, and annual independent testing designed and implemented.
03
GLBA, UDAAP, and Consumer Protection Framework
GLBA privacy notices, data sharing limitation compliance, and safeguard requirements implemented. UDAAP review process for marketing, product terms, and consumer communications. Complaint handling process with regulatory reporting documentation by state.
04
Sponsor Bank Audit Package Design
Compliance documentation library built to the specific sponsor bank’s audit expectations: BSA/AML program documentation, complaint handling records, UDAAP compliance evidence, and data security controls organized in examination-ready format. Maintained current between audit cycles not assembled in the two weeks before an audit request arrives.
What You Gain
Proven Outcomes
Audit-ready
Sponsor bank compliance documentation in every program engagement
BSA/AML
Risk-based programs calibrated to FinTech-specific transaction patterns
18+ yrs
Financial services experience sponsor bank and regulator expectations
Proven Outcomes
18+
Years in Regulated Industries
What You Gain
Audit-ready
Sponsor bank program documentation maintained current year-round
BSA/AML
Risk-based program calibrated to the FinTech's customer and transaction profile
Compliant
GLBA, UDAAP, and CFPB compliance evidence documented and current
Scalable
Compliance architecture that extends to new products without full rebuild
What's Included
Regulatory obligation mapping
Regulatory obligation mapping
Cloud-native unified platform with streaming and batch processing for all use cases
BSA/AML program
BSA/AML program
Customer risk assessment, transaction monitoring approach, and SAR filing workflow
GLBA privacy program
GLBA privacy program
Privacy notices, data sharing limitations, and safeguard requirements implementation
UDAAP compliance framework
UDAAP compliance framework
Marketing review process, complaint handling documentation, and consumer protection evidence
Sponsor bank audit package
Sponsor bank audit package
Documentation library organized to the sponsor bank's specific audit request format
State MTL compliance monitoring
Fair lending monitoring module
State MTL compliance monitoring
License status tracking, renewal calendar, and compliance obligation monitoring by state
Regulatory change monitoring
Regulatory change monitoring
CFPB, FinCEN, and state regulatory development tracking with compliance program impact assessment
Frequently Asked Questions
What does a sponsor bank program management audit cover?
Sponsor bank program audits typically cover BSA/AML program quality and effectiveness, UDAAP compliance in marketing and product terms, complaint handling process and outcomes, data security controls, and operational resilience. PiTech structures the compliance program to produce evidence for each category on a continuous basis not assembled reactively when the audit request arrives.
When should a FinTech platform build its compliance infrastructure relative to product launch?
Compliance infrastructure should be designed before product launch, not after. BSA/AML program requirements apply from the first customer transaction. Sponsor bank program agreement compliance obligations are effective at program initiation. Retrofitting compliance onto a live platform with a growing customer base is substantially more disruptive and more expensive than building it before the first customer onboards.
How does the compliance framework scale as the platform adds new products?
PiTech designs the compliance framework with product expansion in mind. Each new product triggers a regulatory scope assessment that identifies incremental compliance obligations new BSA/AML risk categories, additional state MTL requirements, updated UDAAP considerations and extends the existing program rather than requiring a full rebuild. The framework architecture supports growth without structural compliance rework.
What is the difference between a FinTech BSA/AML program and a bank's AML program?
The regulatory obligation is the same FinTechs operating through sponsor banks have BSA/AML obligations equal to the bank’s requirements. The program design differs in risk calibration: FinTech customer bases often have different risk characteristics, transaction patterns, and fraud exposure than traditional bank customers. PiTech calibrates the BSA/AML program specifically to the FinTech’s customer profile and product-specific risk factors, not a generic bank AML template.
How does the compliance program address evolving CFPB supervision of FinTechs?
The CFPB’s supervisory authority over nonbank financial companies including FinTech platforms with significant consumer transaction volume has expanded significantly. PiTech designs compliance programs to satisfy CFPB examination expectations as well as sponsor bank audit requirements, recognizing that FinTechs face potential direct CFPB examination alongside sponsor bank oversight.
Compliance infrastructure built before growth is a fraction of the cost of compliance remediation during growth. PiTech builds FinTech compliance programs that scale.
Contact PiTech to begin with a compliance program coverage and sponsor bank audit readiness assessment.
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Contact Details
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