🔹 Situation
A growing fintech in the digital payments space partnered with a regional U.S. bank to access the banking rails.
As the fintech scaled rapidly, federal regulators raised concerns: Who owns KYC? Where’s the third-party monitoring? What happens if there’s a data breach?
With pressure from the OCC and the partner bank’s internal risk team, the fintech was at risk of losing its partnership.
🔹 Our Role
PGMP was brought in to structure a formalized, exam-ready regulatory playbook that satisfied both bank and fintech compliance expectations.
We delivered:
- A shared accountability matrix across bank and fintech functions (KYC, transaction monitoring, fraud, audit)
- A governance model with documented escalation and risk acceptance rules
- Standard operating procedures (SOPs) for key partnership activities
- Regulator-facing presentation materials (playbook, controls map, testing schedule)
- Ongoing advisory support through the next OCC exam
🔹 Results
✅ Partnership retained — fintech passed bank’s annual risk review
✅ OCC examiners acknowledged strength of the control model
✅ Playbook later reused in additional bank partnerships
✅ Reduced manual escalations by 62% within 90 days