MODULE 7 - April 29, 2026
Policy, Procedure & Training Readiness for FI‑Hosted Fintech Programs
Your seventh session focuses on operational maturity—strengthening the FI’s Compliance Management System (CMS) so it can withstand examiner scrutiny when hosting fintech programs through the sidecar. This module reinforces that the FI already performs these functions; fintech hosting simply raises the required scope, cadence, rigor, and evidence. Participants learn how to elevate policies, procedures, and training across the FI, sidecar provider, and fintech partner to meet FDIC CMS expectations and Interagency third‑party risk guidance.
Key Concepts Covered
- Enhancing (not reinventing) FI policies, procedures, and training to meet fintech‑hosting standards
- Mapping FI, sidecar, and fintech partner policies to CMS elements: board oversight, written program, training, monitoring/audit, complaint response
- Stage‑gating for readiness: application‑stage vs. launch‑stage requirements and ongoing refresh cadences
- Role‑based, documented training for all personnel “whose duties require knowledge of the BSA,” aligned to FFIEC guidance
- Policy‑to‑control mapping: every policy must trace to a live sidecar or FI operational control
- Evidence readiness: training logs, board minutes, audit schedules, policy approvals, monitoring results
- Using CMS dashboards to report program health, monitoring results, and compliance trends
Learning Outcome:
By the end of this module, you’ll understand how to build a mature, examiner‑ready CMS framework tailored to fintech hosting. Participants will be able to map policies to controls, document role‑based training, structure application‑stage and launch‑stage readiness gates, and ensure that all governance artifacts—policies, procedures, training logs, runbooks, and board reporting—support safe onboarding and ongoing monitoring of fintech partners in the sidecar environment.