Fintech-bank partnerships introduce new avenues through which banking and credit projects can reach consumers. These partnerships, however, require a clear understanding of regulatory compliance responsibilities. Fintechs operating as an agent of their bank partners typically assume operational compliance responsibilities, while the bank partner retains third-party risk management and oversight obligations. As such, fintechs must remain in compliance with federal laws and regulations.

Asurity Advisors leveraged industry expertise, extensive knowledge of BSA/AML/OFAC and fair lending laws and regulations, and significant experience working with fintechs to evaluate the client’s programs. With respect to both workstreams, Asurity reviewed policies, procedures, and other
documentation and determined if the written documentation aligned regulatory compliance requirements, expectations, and existing institution practices. Asurity conducted interviews, attended walkthroughs, and developed questionnaires to better understand the client’s existing practices. Asurity developed observations and recommendations for improving both programs, tailored to the specific product offerings, scope of regulatory applicability, and risk profile of the fintech. At the end of the engagement, Asurity delivered reports documenting the fintech’s practices and any observations, which gave the fintech and their bank partner reasonable assurance as to the adequacy of both programs.