FinTech companies in full stride toward maturity and profitability must outpace mounting risks and overcome an increasing number of regulatory hurdles. Even as “non-banks,” FinTech companies need robust risk and compliance management programs that are purpose-built for their innovative business models. Treliant understands these needs and tailors strategic compliance programs to meet the specific business needs of these unique companies.
The Consumer Financial Protection Bureau (CFPB) has broad authority to regulate FinTech companies that offer consumer and small business financial products and state regulators already oversee online lending operations.
Now, more than ever, FinTech companies need to have their risk and compliance operations in shape so that their business models can continue to operate effectively without disruption from regulatory agencies.
Treliant’s experts specialize in assisting FinTech companies tailor their regulatory compliance programs specifically to meet their needs.
Treliant can help FinTech companies build the ten components of an effective Compliance Management System (CMS):
- Board and Senior Management Oversight. Ensuring active governance of compliance management.
- Policies and Procedures. Drafting, tracking, and updating compliance policies and procedures.
- Monitoring and Testing. Conducting risk-based compliance monitoring and testing, including fair lending testing, to ensure the effectiveness of the compliance program.
- Fair and Responsible Lending. Assessing product risks and performing statistical testing to identify potential discrimination risk arising from disparate treatment or disparate impact.
- Model Validation. Review models and associated policies, procedures, and documentation for consistency with regulatory expectations for robust model risk management.
- Compliance Training. Educating the Board, management, and employees either internally or through external sources such as webinars and conferences.
- Risk Assessments. Identifying compliance risks, evaluating risk controls, and using the results to prioritize compliance resources, and adjust compliance programs to meet new and emerging risks, including from third parties.
- Compliant Handling and Oversight. Establishing a formal complaints program, including, complaint tracking, monitoring issues, and root-cause analysis of complaints and corrective action.
- Corrective Action. Detailed planning and execution of action to correct violations.
- Change Management. Engaging teams to coordinate change, including marketing materials, products, and customer communications/forms/disclosures, including partner advertising.
- Compliance Reporting. Updating the Board and executive management regularly on compliance program performance, regulatory issues and significant metrics.
- Vendor/Partner Management. Developing a formal vendor management policy that identifies, measures, monitors, and controls the risks associated with third-party vendors.
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