Culture of Compliance: Navigating Today’s Regulatory Environment

In today’s environment of intense regulatory scrutiny, choosing your partners wisely is an important strategic decision. With heightened attention on the issue of Third Party Risk, agencies have issued joint guidance that, for all intents and purposes, closely mirrors the lifecycle of risk management and provides a tool for assessing and developing new relationships. Key elements include:

• Strategic Planning in Partner Selection – both banks and fintechs should ensure that new partnerships are aligned with strategic partnership criteria before entering into a new relationship. If partnership criteria isn’t clear and aligned, that’s a good place to start.
• Compliance & Controls for Individual Products – Ensure both expert people resources and product specific processes are in place before launching or onboarding new programs.
• Compliance Due Diligence when Partnering – Financial due diligence is not enough; full compliance due diligence is prudent and important. Evaluate whether partners have compliance processes, resources and culture in place.
• Issues Documentation in Contracts – When forming new relationships, agencies have called out that it’s critical that banks document all potential issues that could arise in a new program or partnership.
• Rigorous Policies to Monitor 3^rd Parties – Its critical to not only have policies in place but also processes that rigorously apply monitoring and oversight.
• Process to Adapt to Changing Regulatory Guidance – Ensure there are mechanisms within the new partner’s organization to adapt to new guidance. Change will be a constant.
• Risk Based Approach to Requirements & Regulations – Including Risk and Compliance experts in the development stages of new programs is a key to long term success.

There is a lot on the plates of banks and fintechs.  A strong organizational commitment to building compliance infrastructure, ensuring a strong culture of compliance and creating a team of critical advisors is key to successfully sustaining programs in market.  To gain more helpful insights into navigating today’s environment, listen to an expert panel on our webinar.