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Compliance Services For Fintechs and Bank Partners
We provide services to the fintech directly, to a bank partner, through a law firm providing legal advice to these organizations, or on behalf of other funders, either those providing capital to the company itself or investors in the loans.
Regulatory Compliance
Compliance Management System (CMS) Consulting Services
Management and the board of directors have ultimate responsibility for compliance oversight. Ensuring the effectiveness and sustainability of the CMS through essential program elements from policies and procedures to consumer complaints is key to that oversight. CrossCheck’s compliance consulting services address these key program elements for fintech companies and their partner banks.
Fintech compliance services:
- Compliance Policy & Procedure Review/Development – Establish and incorporate compliance requirements and responsibilities into business processes.
- Compliance Risk Assessment – Identify and risk-rate compliance risks and controls for a refined focus.
- Monitoring, Audit, or Targeted Loan or Deposit Compliance Reviews – Review the operations and compliance with regulatory and partner bank requirements to ensure responsibilities are carried out, legal requirements met, corrective action taken, and procedure and systems updates are made.
- Training – Communicate compliance responsibilities and guidance to all employees, management, and the board.
- Compliance Investigations & Remediation – Research and understand the root cause of identified issues and the persons impacted to ensure the corrective action and remediation addresses the issue and not the symptoms.
- Consumer Complaint Handling – Establish procedures to categorize, risk-rate, escalate, and address the root causes of consumer complaints. Ensure corrective actions are taken to prevent complaints from recurring.
Anti-Money Laundering/Combatting the Financing of Terrorism (AML/CFT) Services
CrossCheck consultants perform annual AML audits and risk assessments required by the FFIEC, prudential, and state regulators. An assessment of a fintech company’s AML/CFT risk profile and the annual audit is required every 12-18 months, or when changes to its products/services occur.
Fair Lending
Fair Lending Statistical Analysis
Our fair lending statistical analysis offerings identify potential disparities across pricing, underwriting, exceptions, and redlining risk. We apply advanced modeling and regulatory insight to uncover patterns of lending activity that could point to potential disparate treatment, helping fintech companies mitigate risk, demonstrate compliance, and strengthen fair lending controls with defensible, data-driven results. Explore Service
Fair Lending AI Model Output Testing
Conducting statistical testing at each stage of the credit decision funnel—output, configuration, manual review, and final decisioning—enables fintech companies to identify whether disparities are associated with the AI model itself, its implementation, or later manual decisions. As AI adds complexity to credit decisioning, CrossCheck’s proprietary AI Fair Lending Funnel Analysis℠ helps our fintech clients isolate and assess risk at each stage. Explore Service
Section 1071 Small Business Data Integrity Reviews
CrossCheck performs Section 1071 business data integrity reviews to ensure accurate small business lending data collection and reporting. Our experts verify processes, detect inconsistencies, and enhance governance frameworks, helping institutions prepare for CFPB compliance expectations and future fair lending analyses. Explore Service
Fair Lending Program Review/Audit
Fintech companies, like traditional lenders, must comply with fair lending laws to ensure that all consumers have equal access to credit and financial services. CrossCheck conducts independent fair lending program reviews and audits to evaluate your company’s policy effectiveness, governance, and monitoring systems. Our experts assess program design against regulatory expectations, identify control gaps, and provide actionable recommendations to enhance compliance readiness and examiner confidence.
Fair Lending Risk Assessment
CrossCheck’s fair lending risk assessments evaluate products, policies, and practices, specific to fintech companies, to identify potential disparities or gaps in compliance management. We deliver prioritized, actionable findings that help mortgage companies proactively address examiner expectations, strengthen oversight, and maintain a fair and inclusive lending environment.
Fair Lending Program Development
CrossCheck designs and enhances fair lending compliance management systems that align with regulatory and bank partner expectations. Our approach integrates governance, monitoring, training, and data analytics, creating a sustainable framework that proactively manages fair lending risk and supports continuous compliance improvement.
Fair Lending Training
CrossCheck’s fair lending compliance training programs equip board members, management, and staff with practical knowledge of regulatory requirements across all areas of fair lending and emerging risks at your fintech company and emerging risks. We tailor content to your institution’s products and risk profile, fostering a culture of compliance and accountability across all levels of the organization.
Internal Audit
Internal Audit Risk Assessment & Audit Plan Development
Identification and prioritization of risks allows your fintech to focus on areas most important to meeting the goals of your business and partner bank. An objective assessment of the likelihood and impact of financial, operational, and compliance risk and mitigating controls help drive the focal points of your internal audit plan.
Operational Audits
Control design and effectiveness and risk management processes are imperative for well-controlled fintech companies. Review of policies and procedures, key personnel interviews, and testing will determine the completeness and effectiveness of existing controls in mitigating risks inherent in daily execution of activities. Recommendations address root causes to prevent recurrence.
Auditable areas for fintechs include:
- Deposit and Loan Operations
- Secondary Marketing
- Branch Operations
- Accounting
- Asset Liability Management
- Funds Management – Investments
- Payroll/Human Resources
- Wire Transfer
- Third-Party/Vendor Management
- Mortgage Electronic Registration Systems (MERS) Audits
Compliance Audits
An independent compliance audit will assess whether your CMS is operating as intended and maximizes compliance performance. In addition to a full review of the CMS, CrossCheck performs targeted compliance reviews across key regulatory areas applicable to a fintech client’s products and services.
Fintech and partner bank audits we perform:
- Consumer deposit and lending regulations
- Consumer deposit products and services
- Loan origination and loan servicing regulations
- Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) regulations
- Advertising and website regulations
Meet your FinTech Experts
Fintech Compliance FAQs
How do regulators evaluate risk in bank–fintech partnerships?
Regulators evaluate bank–fintech partnerships by assessing how risks introduced by the fintech are identified, managed, and overseen by both parties. Key focus areas include governance, third-party risk management, compliance accountability, data integrity, consumer protection, and whether controls scale with growth and complexity.
How is compliance accountability typically shared between fintechs and bank partners?
While accountability depends on contractual structure and regulatory context, regulators generally expect clear delineation of responsibilities, strong oversight by the bank, and meaningful compliance ownership by the fintech. Ambiguity in roles or reliance on assumptions rather than documented controls is often viewed as a risk.
How do bank regulators assess oversight of fintech third-party relationships?
Bank regulators assess whether the bank—not the fintech—retains effective oversight and accountability for third-party activities. Reviews focus on governance structures, risk assessments, due diligence, contractual controls, and ongoing monitoring of fintech partners. Regulators also evaluate how banks and fintechs coordinate on issue management, data integrity, consumer protection, and regulatory change management, particularly where fintechs perform core operational or customer-facing functions.
What compliance risks are most common in fintech lending and payments models?
Common risks include UDAAP, fair lending, servicing and dispute handling, disclosures, data integrity, model risk, and third-party dependencies. These risks are often amplified by automation, rapid product iteration, and reliance on vendors or embedded finance arrangements.
How do regulators assess fintech compliance management systems (CMS)?
Regulators assess whether a fintech’s CMS is appropriately designed for its risk profile and operating model, and whether it functions effectively in practice. This includes governance, policies and procedures, training, monitoring and testing, complaint management, and issue remediation—not just the existence of documentation.
What role does compliance testing and independent review play in fintech regulatory readiness?
Compliance testing and independent review are critical to demonstrating that a fintech’s controls operate effectively in practice, not just in design. Regulators expect evidence of ongoing monitoring, targeted testing, and objective validation of key compliance risks. Independent reviews help identify control gaps early, support credible remediation, and provide assurance to bank partners, regulators, and investors that compliance risks are being actively managed.
What documentation do regulators expect from fintechs supporting regulated financial products?
Regulators expect fintechs to maintain clear, well-organized documentation that supports governance, control execution, and accountability. This typically includes policies and procedures, risk assessments, compliance testing results, issue tracking and remediation records, training materials, complaint and dispute logs, and evidence of oversight coordination with bank partners. Documentation should be current, consistent with actual practices, and readily available to support examinations and supervisory inquiries.
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