Who We Serve
Digital Banking, Neobank and BaaS Compliance Services
InnReg provides compliance consulting and outsourcing for neobanks, BaaS providers, embedded banking programs, and other digital financial platforms, from regulatory assessments and sponsor bank readiness to program development, ongoing compliance management, testing, and remediation.
Since 2013
100+ fintechs supported
Sponsor bank readiness
SOC 2® Type 2 Report
As seen on:
Compliance That Connects the Bank, Platform, and Customer Experience
Compliance That Connects the Bank, Platform, and Customer Experience
A neobank or BaaS platform is not a regulatory category by itself. The compliance framework depends on what each entity actually does.
A typical digital banking program may involve an FDIC-insured bank, a consumer or business-facing fintech, a BaaS or middleware provider, card and payment processors, KYC vendors, fraud tools, customer-service teams, and other service providers. Deposit accounts may legally sit at the partner bank even though the fintech controls much of the customer experience. Payment, lending, servicing, or other activities performed by the nonbank can create separate regulatory obligations.
That structure makes allocation of responsibilities critical. The partner bank remains responsible for complying with the laws and regulations applicable to its activities even when third parties perform operational functions. At the same time, the fintech may have its own regulatory, licensing, consumer-protection, privacy, information-security, or financial-crime obligations. Agreements can also assign operational requirements that go beyond the nonbank's direct regulatory minimums.
InnReg helps turn those overlapping responsibilities into an operating compliance framework. We assess the entities and money flows, prepare platforms for sponsor bank diligence, develop policies and workflows, define responsibilities across the program, administer recurring compliance work, support bank reviews, and help remediate identified gaps.
Preparing for Sponsor Bank Due Diligence?
InnReg can assess your business model, money flows, compliance framework, policies, vendors, and operating controls before the bank begins or completes its review. We can also support due diligence responses, remediation, and implementation as the bank's requirements are clarified.
Firm Types
Who We Work With
InnReg supports broker-dealers with different business models, operating structures, and compliance needs.
Consumer Neobanks
Nonbank fintechs providing consumers with access to deposit accounts, debit cards, payments, savings features, or other banking services through one or more partner banks.
Consumer Neobanks
Nonbank fintechs providing consumers with access to deposit accounts, debit cards, payments, savings features, or other banking services through one or more partner banks.
Business Banking Platforms
Platforms offering business checking, cards, expense management, payments, treasury features, or related financial services through bank and technology-provider relationships.
Business Banking Platforms
Platforms offering business checking, cards, expense management, payments, treasury features, or related financial services through bank and technology-provider relationships.
BaaS and Banking Middleware Providers
Platforms connecting banks with fintech programs and providing account, ledger, onboarding, transaction, compliance, or orchestration infrastructure across multiple parties.
BaaS and Banking Middleware Providers
Platforms connecting banks with fintech programs and providing account, ledger, onboarding, transaction, compliance, or orchestration infrastructure across multiple parties.
Embedded Banking Platforms
Software companies, marketplaces, and vertical platforms incorporating bank accounts, cards, payments, or related banking features into an existing product or customer experience.
Embedded Banking Platforms
Software companies, marketplaces, and vertical platforms incorporating bank accounts, cards, payments, or related banking features into an existing product or customer experience.
Program Managers and Account Platforms
Businesses coordinating account programs, debit or prepaid cards, FBO or custodial structures, payment functionality, and customer operations between banks and end users.
Program Managers and Account Platforms
Businesses coordinating account programs, debit or prepaid cards, FBO or custodial structures, payment functionality, and customer operations between banks and end users.
Programs Expanding or Changing Bank Partners
Existing programs adding products, entering new customer segments, changing sponsor banks or providers, or restructuring account and funds-flow arrangements that require compliance reassessment and transition planning.
Programs Expanding or Changing Bank Partners
Existing programs adding products, entering new customer segments, changing sponsor banks or providers, or restructuring account and funds-flow arrangements that require compliance reassessment and transition planning.
Requirements
Key Compliance Areas for Digital Banking, Neobanks and BaaS
Digital banking arrangements distribute activities across multiple entities. The correct compliance framework therefore depends on the legal role of each party, the products offered, how money moves, and which party performs each customer-facing and operational function.
Regulatory Roles, Licensing, and Program Governance
"Neobank" and "BaaS provider" are business-model descriptions rather than regulatory categories. A nonbank may provide access to bank products but can have separate licensing obligations for money transmission, lending, servicing, or other activities it performs. Governance should clearly identify which entity provides each product, performs each control, maintains records, and approves material decisions.
Deposit Insurance, FBO Accounts, and Customer Funds
A fintech is not FDIC-insured merely because customer funds are held at an insured bank. FBO, omnibus, and custodial structures require accurate ownership records, subledger data, reconciliation, and record access to support applicable pass-through insurance treatment. Customer communications should clearly identify the insured institution and avoid implying that the nonbank itself is FDIC-insured.
Marketing, Customer Communications, and FDIC Representations
Customer-facing materials should clearly identify which entity provides the financial product and which protections apply. FDIC Part 328 restricts false or misleading deposit-insurance representations, including by nonbanks. Websites, apps, account-opening flows, yield claims, fees, rewards, and customer-service scripts should be reviewed for accurate bank identification and applicable consumer-protection requirements.
Sponsor Bank Oversight and Third-Party Risk
A bank's use of a fintech or BaaS provider does not eliminate the bank's regulatory responsibility for the underlying activity. Sponsor-bank oversight can therefore cover management, compliance, financial condition, customer operations, information security, subcontractors, records, complaints, and business continuity. Programs should support ongoing monitoring and remediation after initial due diligence is complete.
Consumer Accounts, Payments, Disputes, and Disclosures
Regulation E governs covered electronic fund transfers, including disclosures, unauthorized transactions, and error resolution, while Regulation DD governs covered deposit disclosures. In bank-fintech programs, the bank may hold the legal obligation while the fintech performs the customer-facing workflow. Procedures should therefore align disclosures, transaction records, disputes, fees, and customer service with the bank's requirements.
Privacy, Information Security, Vendors, and Operational Resilience
Digital banking programs can implicate GLBA privacy requirements, Regulation P, the FTC Safeguards Rule, state privacy laws, bank contractual requirements, and other security standards depending on the entity. Controls should cover access, encryption, vendor oversight, incidents, continuity, and data retention, including how critical functions continue if a provider or platform becomes unavailable.
BSA/AML, KYC, KYB, and Sanctions
For bank deposit products, the partner bank retains responsibility for its BSA obligations, including CIP, CDD, suspicious-activity monitoring, and reporting. A fintech may perform operational KYC, KYB, screening, or transaction-monitoring functions on the bank's behalf. The nonbank's own FinCEN, money-transmission, and sanctions obligations must be assessed separately based on its activities.
Credit and Overdraft Features
Adding credit, overdraft, or other financing features can introduce ECOA and Regulation B, FCRA and Regulation V, TILA and Regulation Z, state lending laws, and servicing requirements. The program should clearly identify the lender, decision maker, disclosure owner, servicer, and complaint handler rather than assuming bank origination resolves every obligation of the nonbank platform.
Regulatory Roles, Licensing, and Program Governance
"Neobank" and "BaaS provider" are business-model descriptions rather than regulatory categories. A nonbank may provide access to bank products but can have separate licensing obligations for money transmission, lending, servicing, or other activities it performs. Governance should clearly identify which entity provides each product, performs each control, maintains records, and approves material decisions.
Sponsor Bank Oversight and Third-Party Risk
A bank's use of a fintech or BaaS provider does not eliminate the bank's regulatory responsibility for the underlying activity. Sponsor-bank oversight can therefore cover management, compliance, financial condition, customer operations, information security, subcontractors, records, complaints, and business continuity. Programs should support ongoing monitoring and remediation after initial due diligence is complete.
BSA/AML, KYC, KYB, and Sanctions
For bank deposit products, the partner bank retains responsibility for its BSA obligations, including CIP, CDD, suspicious-activity monitoring, and reporting. A fintech may perform operational KYC, KYB, screening, or transaction-monitoring functions on the bank's behalf. The nonbank's own FinCEN, money-transmission, and sanctions obligations must be assessed separately based on its activities.
Deposit Insurance, FBO Accounts, and Customer Funds
A fintech is not FDIC-insured merely because customer funds are held at an insured bank. FBO, omnibus, and custodial structures require accurate ownership records, subledger data, reconciliation, and record access to support applicable pass-through insurance treatment. Customer communications should clearly identify the insured institution and avoid implying that the nonbank itself is FDIC-insured.
Consumer Accounts, Payments, Disputes, and Disclosures
Regulation E governs covered electronic fund transfers, including disclosures, unauthorized transactions, and error resolution, while Regulation DD governs covered deposit disclosures. In bank-fintech programs, the bank may hold the legal obligation while the fintech performs the customer-facing workflow. Procedures should therefore align disclosures, transaction records, disputes, fees, and customer service with the bank's requirements.
Credit and Overdraft Features
Adding credit, overdraft, or other financing features can introduce ECOA and Regulation B, FCRA and Regulation V, TILA and Regulation Z, state lending laws, and servicing requirements. The program should clearly identify the lender, decision maker, disclosure owner, servicer, and complaint handler rather than assuming bank origination resolves every obligation of the nonbank platform.
Marketing, Customer Communications, and FDIC Representations
Customer-facing materials should clearly identify which entity provides the financial product and which protections apply. FDIC Part 328 restricts false or misleading deposit-insurance representations, including by nonbanks. Websites, apps, account-opening flows, yield claims, fees, rewards, and customer-service scripts should be reviewed for accurate bank identification and applicable consumer-protection requirements.
Privacy, Information Security, Vendors, and Operational Resilience
Digital banking programs can implicate GLBA privacy requirements, Regulation P, the FTC Safeguards Rule, state privacy laws, bank contractual requirements, and other security standards depending on the entity. Controls should cover access, encryption, vendor oversight, incidents, continuity, and data retention, including how critical functions continue if a provider or platform becomes unavailable.
Regulatory Roles, Licensing, and Program Governance
"Neobank" and "BaaS provider" are business-model descriptions rather than regulatory categories. A nonbank may provide access to bank products but can have separate licensing obligations for money transmission, lending, servicing, or other activities it performs. Governance should clearly identify which entity provides each product, performs each control, maintains records, and approves material decisions.
Sponsor Bank Oversight and Third-Party Risk
A bank's use of a fintech or BaaS provider does not eliminate the bank's regulatory responsibility for the underlying activity. Sponsor-bank oversight can therefore cover management, compliance, financial condition, customer operations, information security, subcontractors, records, complaints, and business continuity. Programs should support ongoing monitoring and remediation after initial due diligence is complete.
BSA/AML, KYC, KYB, and Sanctions
For bank deposit products, the partner bank retains responsibility for its BSA obligations, including CIP, CDD, suspicious-activity monitoring, and reporting. A fintech may perform operational KYC, KYB, screening, or transaction-monitoring functions on the bank's behalf. The nonbank's own FinCEN, money-transmission, and sanctions obligations must be assessed separately based on its activities.
Deposit Insurance, FBO Accounts, and Customer Funds
A fintech is not FDIC-insured merely because customer funds are held at an insured bank. FBO, omnibus, and custodial structures require accurate ownership records, subledger data, reconciliation, and record access to support applicable pass-through insurance treatment. Customer communications should clearly identify the insured institution and avoid implying that the nonbank itself is FDIC-insured.
Consumer Accounts, Payments, Disputes, and Disclosures
Regulation E governs covered electronic fund transfers, including disclosures, unauthorized transactions, and error resolution, while Regulation DD governs covered deposit disclosures. In bank-fintech programs, the bank may hold the legal obligation while the fintech performs the customer-facing workflow. Procedures should therefore align disclosures, transaction records, disputes, fees, and customer service with the bank's requirements.
Credit and Overdraft Features
Adding credit, overdraft, or other financing features can introduce ECOA and Regulation B, FCRA and Regulation V, TILA and Regulation Z, state lending laws, and servicing requirements. The program should clearly identify the lender, decision maker, disclosure owner, servicer, and complaint handler rather than assuming bank origination resolves every obligation of the nonbank platform.
Marketing, Customer Communications, and FDIC Representations
Customer-facing materials should clearly identify which entity provides the financial product and which protections apply. FDIC Part 328 restricts false or misleading deposit-insurance representations, including by nonbanks. Websites, apps, account-opening flows, yield claims, fees, rewards, and customer-service scripts should be reviewed for accurate bank identification and applicable consumer-protection requirements.
Privacy, Information Security, Vendors, and Operational Resilience
Digital banking programs can implicate GLBA privacy requirements, Regulation P, the FTC Safeguards Rule, state privacy laws, bank contractual requirements, and other security standards depending on the entity. Controls should cover access, encryption, vendor oversight, incidents, continuity, and data retention, including how critical functions continue if a provider or platform becomes unavailable.
How We Help
How InnReg Supports Digital Banking, Neobanks and BaaS
InnReg can support a specific launch or bank-readiness project, supplement an existing compliance team, or provide a broader outsourced compliance function. The scope is structured around the platform's business model, bank relationships, customer journey, funds flows, regulatory footprint, technology, and internal resources.
Assessing the Model and Preparing for Sponsor Bank Due Diligence
Before a bank agrees to support a program, it needs to understand what the platform is offering, who performs each function, how funds and data move, and whether the fintech has the compliance and operational infrastructure to support the relationship.
InnReg helps digital banking businesses assess the model before or during the sponsor bank process. Our sponsor-bank readiness work has included analyzing account structures and payment flows, identifying applicable regulatory frameworks, developing compliance governance, preparing policies, assembling due diligence materials, responding to bank questions, participating in compliance discussions, and implementing changes requested through the review process.
Support can include:
Entity, product, and funds-flow assessment
Regulatory-perimeter and licensing analysis
Sponsor bank readiness assessment
Compliance gap analysis
Due diligence questionnaire and document support
Policy and control documentation
Responsibility and dependency mapping
Vendor and technology documentation
Responses to bank compliance and risk questions
Remediation before or during onboarding
Assessing the Model and Preparing for Sponsor Bank Due Diligence
Before a bank agrees to support a program, it needs to understand what the platform is offering, who performs each function, how funds and data move, and whether the fintech has the compliance and operational infrastructure to support the relationship.
InnReg helps digital banking businesses assess the model before or during the sponsor bank process. Our sponsor-bank readiness work has included analyzing account structures and payment flows, identifying applicable regulatory frameworks, developing compliance governance, preparing policies, assembling due diligence materials, responding to bank questions, participating in compliance discussions, and implementing changes requested through the review process.
Support can include:
Entity, product, and funds-flow assessment
Regulatory-perimeter and licensing analysis
Sponsor bank readiness assessment
Compliance gap analysis
Due diligence questionnaire and document support
Policy and control documentation
Responsibility and dependency mapping
Vendor and technology documentation
Responses to bank compliance and risk questions
Remediation before or during onboarding
Assessing the Model and Preparing for Sponsor Bank Due Diligence
Before a bank agrees to support a program, it needs to understand what the platform is offering, who performs each function, how funds and data move, and whether the fintech has the compliance and operational infrastructure to support the relationship.
InnReg helps digital banking businesses assess the model before or during the sponsor bank process. Our sponsor-bank readiness work has included analyzing account structures and payment flows, identifying applicable regulatory frameworks, developing compliance governance, preparing policies, assembling due diligence materials, responding to bank questions, participating in compliance discussions, and implementing changes requested through the review process.
Support can include:
Entity, product, and funds-flow assessment
Regulatory-perimeter and licensing analysis
Sponsor bank readiness assessment
Compliance gap analysis
Due diligence questionnaire and document support
Policy and control documentation
Responsibility and dependency mapping
Vendor and technology documentation
Responses to bank compliance and risk questions
Remediation before or during onboarding
Building the Compliance Program and Responsibility Framework
A digital banking program needs more than a collection of policies. Compliance has to be translated into the customer journey and into the responsibilities divided among the platform, bank, BaaS provider, processors, vendors, and internal teams.
InnReg develops compliance programs around the actual operating model. Our digital banking work can connect requirements directly to onboarding, account funding, card use, transaction processing, monitoring, customer communications, complaints, vendor oversight, and other platform workflows. InnReg's existing sponsor-bank readiness scope expressly covers BSA/AML, KYC, transaction monitoring, sanctions, fraud controls, onboarding, payment lifecycle controls, customer communications, security, vendor management, recordkeeping, business continuity, and training.
Representative areas of support include:
Compliance risk assessment and governance
AML, KYC, KYB, and sanctions procedures
Transaction-monitoring and escalation workflows
Fraud and account-restriction processes
Customer onboarding and account procedures
Disclosures, complaints, disputes, and error-resolution workflows
Marketing and communication review procedures
FBO account, ledger, and reconciliation controls
Privacy, information-security, and vendor policies
Responsibility matrices and escalation procedures
Training and implementation readiness
Building the Compliance Program and Responsibility Framework
A digital banking program needs more than a collection of policies. Compliance has to be translated into the customer journey and into the responsibilities divided among the platform, bank, BaaS provider, processors, vendors, and internal teams.
InnReg develops compliance programs around the actual operating model. Our digital banking work can connect requirements directly to onboarding, account funding, card use, transaction processing, monitoring, customer communications, complaints, vendor oversight, and other platform workflows. InnReg's existing sponsor-bank readiness scope expressly covers BSA/AML, KYC, transaction monitoring, sanctions, fraud controls, onboarding, payment lifecycle controls, customer communications, security, vendor management, recordkeeping, business continuity, and training.
Representative areas of support include:
Compliance risk assessment and governance
AML, KYC, KYB, and sanctions procedures
Transaction-monitoring and escalation workflows
Fraud and account-restriction processes
Customer onboarding and account procedures
Disclosures, complaints, disputes, and error-resolution workflows
Marketing and communication review procedures
FBO account, ledger, and reconciliation controls
Privacy, information-security, and vendor policies
Responsibility matrices and escalation procedures
Training and implementation readiness
Building the Compliance Program and Responsibility Framework
A digital banking program needs more than a collection of policies. Compliance has to be translated into the customer journey and into the responsibilities divided among the platform, bank, BaaS provider, processors, vendors, and internal teams.
InnReg develops compliance programs around the actual operating model. Our digital banking work can connect requirements directly to onboarding, account funding, card use, transaction processing, monitoring, customer communications, complaints, vendor oversight, and other platform workflows. InnReg's existing sponsor-bank readiness scope expressly covers BSA/AML, KYC, transaction monitoring, sanctions, fraud controls, onboarding, payment lifecycle controls, customer communications, security, vendor management, recordkeeping, business continuity, and training.
Representative areas of support include:
Compliance risk assessment and governance
AML, KYC, KYB, and sanctions procedures
Transaction-monitoring and escalation workflows
Fraud and account-restriction processes
Customer onboarding and account procedures
Disclosures, complaints, disputes, and error-resolution workflows
Marketing and communication review procedures
FBO account, ledger, and reconciliation controls
Privacy, information-security, and vendor policies
Responsibility matrices and escalation procedures
Training and implementation readiness
Managing Ongoing Program Compliance
Passing sponsor bank diligence is not the end of the compliance work. The program then needs to operate under continuing bank oversight while products, customers, transactions, vendors, and regulatory requirements change.
InnReg can operate as an extension of the platform's internal team and administer recurring compliance work across the agreed areas of responsibility. We organize the program around identifiable owners, review standards, deadlines, bank approvals, and escalation paths rather than treating compliance management as a generic retainer.
Ongoing support can include:
Compliance calendar management
Policy and procedure maintenance
Bank compliance reporting
KYC and monitoring oversight support
Marketing and customer-communication reviews
Complaint and dispute tracking
Vendor and provider reviews
Regulatory-change assessments
New-product compliance review
Issue and corrective-action management
Support for bank information requests
Documentation of recurring compliance activities
Responsibilities reserved to the partner bank, another regulated entity, or a specifically designated individual remain with that party unless separately and appropriately assigned.
Managing Ongoing Program Compliance
Passing sponsor bank diligence is not the end of the compliance work. The program then needs to operate under continuing bank oversight while products, customers, transactions, vendors, and regulatory requirements change.
InnReg can operate as an extension of the platform's internal team and administer recurring compliance work across the agreed areas of responsibility. We organize the program around identifiable owners, review standards, deadlines, bank approvals, and escalation paths rather than treating compliance management as a generic retainer.
Ongoing support can include:
Compliance calendar management
Policy and procedure maintenance
Bank compliance reporting
KYC and monitoring oversight support
Marketing and customer-communication reviews
Complaint and dispute tracking
Vendor and provider reviews
Regulatory-change assessments
New-product compliance review
Issue and corrective-action management
Support for bank information requests
Documentation of recurring compliance activities
Responsibilities reserved to the partner bank, another regulated entity, or a specifically designated individual remain with that party unless separately and appropriately assigned.
Managing Ongoing Program Compliance
Passing sponsor bank diligence is not the end of the compliance work. The program then needs to operate under continuing bank oversight while products, customers, transactions, vendors, and regulatory requirements change.
InnReg can operate as an extension of the platform's internal team and administer recurring compliance work across the agreed areas of responsibility. We organize the program around identifiable owners, review standards, deadlines, bank approvals, and escalation paths rather than treating compliance management as a generic retainer.
Ongoing support can include:
Compliance calendar management
Policy and procedure maintenance
Bank compliance reporting
KYC and monitoring oversight support
Marketing and customer-communication reviews
Complaint and dispute tracking
Vendor and provider reviews
Regulatory-change assessments
New-product compliance review
Issue and corrective-action management
Support for bank information requests
Documentation of recurring compliance activities
Responsibilities reserved to the partner bank, another regulated entity, or a specifically designated individual remain with that party unless separately and appropriately assigned.
Providing Outsourced Compliance Leadership
Early-stage and growing digital banking companies often need senior compliance ownership before they can support a full internal department. Other platforms have an existing compliance leader but need additional capacity during launch, expansion, a bank transition, or remediation.
InnReg can provide outsourced or fractional compliance leadership where appropriate to the platform and program. The role is structured around the nonbank's own responsibilities and the governance expected by its partner bank.
Support can include:
Outsourced or fractional CCO support
Compliance-program administration
Compliance priorities and work planning
Sponsor bank compliance coordination
Management reporting
Escalation of significant customer and control issues
Oversight of remediation initiatives
New-product and change-management review
Coordination across product, operations, technology, legal, and finance
Transition support as the internal compliance team grows
Providing Outsourced Compliance Leadership
Early-stage and growing digital banking companies often need senior compliance ownership before they can support a full internal department. Other platforms have an existing compliance leader but need additional capacity during launch, expansion, a bank transition, or remediation.
InnReg can provide outsourced or fractional compliance leadership where appropriate to the platform and program. The role is structured around the nonbank's own responsibilities and the governance expected by its partner bank.
Support can include:
Outsourced or fractional CCO support
Compliance-program administration
Compliance priorities and work planning
Sponsor bank compliance coordination
Management reporting
Escalation of significant customer and control issues
Oversight of remediation initiatives
New-product and change-management review
Coordination across product, operations, technology, legal, and finance
Transition support as the internal compliance team grows
Providing Outsourced Compliance Leadership
Early-stage and growing digital banking companies often need senior compliance ownership before they can support a full internal department. Other platforms have an existing compliance leader but need additional capacity during launch, expansion, a bank transition, or remediation.
InnReg can provide outsourced or fractional compliance leadership where appropriate to the platform and program. The role is structured around the nonbank's own responsibilities and the governance expected by its partner bank.
Support can include:
Outsourced or fractional CCO support
Compliance-program administration
Compliance priorities and work planning
Sponsor bank compliance coordination
Management reporting
Escalation of significant customer and control issues
Oversight of remediation initiatives
New-product and change-management review
Coordination across product, operations, technology, legal, and finance
Transition support as the internal compliance team grows
Testing Controls and Supporting Bank or Regulatory Reviews
Banks need evidence that their partners' controls operate as documented. Digital banking platforms likewise need a way to identify weaknesses before they become bank findings, customer harm, regulatory issues, or operational failures.
InnReg can perform targeted compliance testing and readiness reviews around the workflows relevant to the program. We can also support bank diligence, periodic partner reviews, regulatory inquiries, and remediation.
Testing and review support can include:
Customer onboarding and KYC sample reviews
Transaction-monitoring and escalation testing
AML and sanctions control reviews
Account and transaction record testing
Disclosure and marketing reviews
Regulation E dispute and error-resolution testing
Complaint-management reviews
Vendor and responsibility-control testing
Reconciliation and record-access reviews
Findings and remediation plans
Follow-up validation
Bank or regulator response support
Where a review must satisfy a formal independence requirement, the engagement is separately evaluated and scoped to preserve the required independence.
Testing Controls and Supporting Bank or Regulatory Reviews
Banks need evidence that their partners' controls operate as documented. Digital banking platforms likewise need a way to identify weaknesses before they become bank findings, customer harm, regulatory issues, or operational failures.
InnReg can perform targeted compliance testing and readiness reviews around the workflows relevant to the program. We can also support bank diligence, periodic partner reviews, regulatory inquiries, and remediation.
Testing and review support can include:
Customer onboarding and KYC sample reviews
Transaction-monitoring and escalation testing
AML and sanctions control reviews
Account and transaction record testing
Disclosure and marketing reviews
Regulation E dispute and error-resolution testing
Complaint-management reviews
Vendor and responsibility-control testing
Reconciliation and record-access reviews
Findings and remediation plans
Follow-up validation
Bank or regulator response support
Where a review must satisfy a formal independence requirement, the engagement is separately evaluated and scoped to preserve the required independence.
Testing Controls and Supporting Bank or Regulatory Reviews
Banks need evidence that their partners' controls operate as documented. Digital banking platforms likewise need a way to identify weaknesses before they become bank findings, customer harm, regulatory issues, or operational failures.
InnReg can perform targeted compliance testing and readiness reviews around the workflows relevant to the program. We can also support bank diligence, periodic partner reviews, regulatory inquiries, and remediation.
Testing and review support can include:
Customer onboarding and KYC sample reviews
Transaction-monitoring and escalation testing
AML and sanctions control reviews
Account and transaction record testing
Disclosure and marketing reviews
Regulation E dispute and error-resolution testing
Complaint-management reviews
Vendor and responsibility-control testing
Reconciliation and record-access reviews
Findings and remediation plans
Follow-up validation
Bank or regulator response support
Where a review must satisfy a formal independence requirement, the engagement is separately evaluated and scoped to preserve the required independence.
Assessing Product Changes, Licensing Needs, and Bank Transitions
A digital banking program's compliance framework can change materially when the business adds a product, changes how funds move, introduces credit, adds another bank, changes its BaaS provider, enters a new state, or restructures the customer relationship.
InnReg can assess those changes before implementation and organize the compliance work needed to support them.
Assessments can address:
New account and card products
New payment functionality
Credit or overdraft features
Changes to funds flows or FBO structures
Money-transmission implications
State licensing considerations
New customer segments
Changes to bank or BaaS providers
Changes to onboarding or monitoring tools
New vendors and subcontractors
Changes to customer disclosures
Transition and exit requirements
For bank migrations, we can also help organize the compliance implications of customer communications, account transitions, records, outstanding disputes, open compliance issues, vendor changes, and control implementation at the new institution.
Assessing Product Changes, Licensing Needs, and Bank Transitions
A digital banking program's compliance framework can change materially when the business adds a product, changes how funds move, introduces credit, adds another bank, changes its BaaS provider, enters a new state, or restructures the customer relationship.
InnReg can assess those changes before implementation and organize the compliance work needed to support them.
Assessments can address:
New account and card products
New payment functionality
Credit or overdraft features
Changes to funds flows or FBO structures
Money-transmission implications
State licensing considerations
New customer segments
Changes to bank or BaaS providers
Changes to onboarding or monitoring tools
New vendors and subcontractors
Changes to customer disclosures
Transition and exit requirements
For bank migrations, we can also help organize the compliance implications of customer communications, account transitions, records, outstanding disputes, open compliance issues, vendor changes, and control implementation at the new institution.
Assessing Product Changes, Licensing Needs, and Bank Transitions
A digital banking program's compliance framework can change materially when the business adds a product, changes how funds move, introduces credit, adds another bank, changes its BaaS provider, enters a new state, or restructures the customer relationship.
InnReg can assess those changes before implementation and organize the compliance work needed to support them.
Assessments can address:
New account and card products
New payment functionality
Credit or overdraft features
Changes to funds flows or FBO structures
Money-transmission implications
State licensing considerations
New customer segments
Changes to bank or BaaS providers
Changes to onboarding or monitoring tools
New vendors and subcontractors
Changes to customer disclosures
Transition and exit requirements
For bank migrations, we can also help organize the compliance implications of customer communications, account transitions, records, outstanding disputes, open compliance issues, vendor changes, and control implementation at the new institution.
Our Methodology
How We Work With Digital Banking, Neobanks and BaaS
Digital banking engagements often distribute responsibilities across a platform, partner bank, BaaS provider, processors, compliance vendors, and internal product and operations teams. InnReg uses a structured working model to connect those parties and keep compliance work aligned with the customer experience.
01
Map the Program and Set Priorities
We begin by reviewing the entities, products, customer journey, contracts, account structure, funds flows, bank relationships, systems, providers, jurisdictions, and existing compliance framework.
We identify the principal compliance workstreams and dependencies, including bank requests, policy gaps, licensing questions, disclosures, operational data, vendor information, and product decisions. The workplan distinguishes the platform's responsibilities from functions performed or retained by the bank and other providers.
01
Map the Program and Set Priorities
We begin by reviewing the entities, products, customer journey, contracts, account structure, funds flows, bank relationships, systems, providers, jurisdictions, and existing compliance framework.
We identify the principal compliance workstreams and dependencies, including bank requests, policy gaps, licensing questions, disclosures, operational data, vendor information, and product decisions. The workplan distinguishes the platform's responsibilities from functions performed or retained by the bank and other providers.
02
Establish the Team and Coordinate Responsibilities
Each engagement has a primary InnReg project lead who coordinates the day-to-day work. Additional consultants, AML or consumer-compliance specialists, senior reviewers, or designated compliance professionals are involved based on the scope.
We clarify responsibilities across compliance, product, customer operations, fraud, finance, technology, legal counsel, management, the sponsor bank, and relevant providers. Requests and decisions are directed to the stakeholders responsible for the affected part of the program.
02
Establish the Team and Coordinate Responsibilities
Each engagement has a primary InnReg project lead who coordinates the day-to-day work. Additional consultants, AML or consumer-compliance specialists, senior reviewers, or designated compliance professionals are involved based on the scope.
We clarify responsibilities across compliance, product, customer operations, fraud, finance, technology, legal counsel, management, the sponsor bank, and relevant providers. Requests and decisions are directed to the stakeholders responsible for the affected part of the program.
03
Execute and Track Bank and Platform Workstreams
Policies, bank requests, disclosures, operational controls, reviews, testing, remediation, product changes, deadlines, and client inputs are tracked through an organized project-management process.
InnReg can work within agreed client systems. Regular meetings and established communication channels help coordinate the fintech, bank, and provider workstreams and keep dependencies visible.
03
Execute and Track Bank and Platform Workstreams
Policies, bank requests, disclosures, operational controls, reviews, testing, remediation, product changes, deadlines, and client inputs are tracked through an organized project-management process.
InnReg can work within agreed client systems. Regular meetings and established communication channels help coordinate the fintech, bank, and provider workstreams and keep dependencies visible.
04
Review, Escalate, and Adapt
Matters involving customer funds, financial crime, account restrictions, disclosures, complaints, data access, security incidents, bank findings, or material product changes may require additional review by senior personnel, specialists, counsel, or the responsible bank stakeholders.
We track open findings through defined escalation paths and revisit the compliance framework as products, customer segments, banks, providers, technology, or regulatory requirements change.
04
Review, Escalate, and Adapt
Matters involving customer funds, financial crime, account restrictions, disclosures, complaints, data access, security incidents, bank findings, or material product changes may require additional review by senior personnel, specialists, counsel, or the responsible bank stakeholders.
We track open findings through defined escalation paths and revisit the compliance framework as products, customer segments, banks, providers, technology, or regulatory requirements change.
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Why InnReg
Why Digital Banking Businesses Work With InnReg
InnReg combines fintech compliance experience with a structured delivery model designed for businesses where regulated products, customer-facing technology, and multiple providers need to operate as one program.
Support From Bank Readiness Through Ongoing Operations
InnReg can support the business from regulatory-model assessment and sponsor bank readiness through program development, launch, ongoing compliance management, testing, remediation, and subsequent product or bank changes.
Experience With Innovative Fintech Models
Since 2013, InnReg has supported more than 100 fintechs and regulated financial-services businesses. Our work spans banking relationships, payments, lending, money movement, securities, digital assets, and other models where several regulatory and operational frameworks intersect.
Compliance Across the Customer Journey
We connect requirements to how the platform actually operates, including onboarding, account funding, transactions, monitoring, cards, disclosures, complaints, disputes, records, vendors, and customer support.
Execution, Not Just Advice
Where included in the engagement, InnReg can carry the work forward through policies, bank due diligence, recurring reviews, compliance operations, testing, responses, remediation, and implementation rather than stopping after identifying what needs to be done.
Structured, Team-Based Delivery
Each engagement has a primary day-to-day lead supported by additional compliance specialists and senior reviewers as needed. We coordinate with product, operations, technology, legal, finance, management, bank contacts, and service providers through an organized workplan.
Clear Ownership Across the Program
Digital banking compliance can fail when everyone assumes another party owns the requirement. We document responsibilities, approvals, information dependencies, and escalation paths so the bank, platform, and providers understand who performs each function and where decisions remain with the regulated institution.
FAQ
Digital Banking, Neobank and BaaS Compliance FAQs
Digital Banking, Neobank and BaaS Compliance FAQs
Is a neobank legally considered a bank?
Can InnReg help us prepare for a sponsor bank?
Does using a sponsor bank eliminate our need for licenses?
Who is responsible for KYC and AML in a bank-fintech program?
Are customer funds at a neobank FDIC-insured?
Can InnReg manage our compliance program after launch?
Can InnReg provide an outsourced CCO for a neobank or BaaS platform?
Can InnReg support a sponsor bank or BaaS provider transition?
Our Team
Meet the Team Supporting Digital Banking Compliance
Talk to Our Digital Banking and BaaS Compliance Team
Talk to Our Digital Banking and BaaS Compliance Team
Who We Serve
By Regulated Firm Type
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About InnReg
© 2026 InnReg LLC
305-908-1160
The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.
9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156
Who We Serve
By Regulated Firm Type
Services
How We Help
Resources
Downloads
About InnReg
© 2026 InnReg LLC
305-908-1160
The content provided on this website is for informational purposes only and does not constitute legal, investment, tax, or other professional advice. InnReg LLC is not a law firm, tax advisor, or regulated financial institution. Viewing this site or contacting InnReg does not create a client relationship. Results described in case studies or testimonials may not be typical and do not guarantee future outcomes. Tools, spreadsheets, or guides available on this site are provided for illustrative purposes only and should not be relied upon without professional guidance. Any links to third-party websites are provided for convenience and do not constitute endorsement or responsibility for their content. The information on this site may not be applicable in all jurisdictions. While we strive to provide accurate content, we make no representations as to its completeness or timeliness. Some visual assets on this site are sourced from Freepik.
9100 S Dadeland Blvd
Suite 1500
Miami, Florida 33156