Regulatory Resiliency
Avoiding primary factors of consent orders that have shut BaaS Provider/Fintech down
We’re sharing this matrix, developed by industry advisors and regulatory agencies, to highlight the key factors that have led to consent orders in BaaS programs. While a consent order against a sponsor bank doesn’t necessarily shut down a fintech program, it can significantly disrupt operations, growth, and resource allocation.
As we expand our partner banking initiatives, we’re taking a deliberate, risk-aware approach that prioritizes regulatory alignment and long-term stability. This includes:
- Full transparency with regulatory agencies around every program we launch
- Maintaining bank-owned data, accounts, and transaction records in line with FDIC standards
- Ensuring continuity of customer access — even in the event of a fintech partner exiting — to reduce legal exposure and protect end users
This framework is designed not just to meet today’s expectations, but to future-proof our partnerships and avoid the pitfalls that have impacted other BaaS models.
- Bank-controlled
- Bank-defined rules
- Bank-decisioning
- Real-time end-user account access
- Segregated program operating accounts
- Automated Settlement Operations to Bank operating accounts (no money gets lost)
- No data transfers needed – Bank already has full access to all customers, accounts, transactions
- Centralized Console for Bank and Fintech “one version of truth”
- Built-in deposit resiliency
- Bank can provide customer access to funds as DR plan
- Documented and visible operating account structure
- Defined funds flow and payment processes
- Settlement to FFIEC compliant core system
- Eliminate risk of BaaS middleman with ledger outside bank control
- Bank owns direct contract with Fintech / Brand
Updated 2 months ago