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BaaS sponsor banks for fintech programs
Last updated October 11, 2026
Banking-as-a-service puts a bank behind your program, directly or through a platform. Regulators hold the bank responsible for the whole arrangement, so it will review your program closely. We introduce fintechs, including foreign fintechs that need a US sponsor, to banks that will review the program. The bank decides. Approval is never guaranteed.
We place payment processing, business banking and crypto rails for high-growth, complex businesses with institutions that take the industry, then watch the chargeback ratios, reserves and reviews that get accounts closed, with more than one rail so one bank's no doesn't stop the business. Approval is never guaranteed.
Who it's for
- Fintechs that need accounts, cards, or ACH under their brand
- Programs leaving a BaaS platform
- Foreign fintechs seeking a US bank sponsor
- Teams choosing between a direct sponsor and a platform
What the bank needs
- The product and the end customer
- Compliance ownership: you, the platform, or the bank
- Flow of funds and ledgers
- Existing bank or platform relationships
Who is responsible in a BaaS program?
The bank. Federal guidance says using third parties doesn't reduce a bank's responsibility to operate safely and in compliance with the law (2023 Interagency Guidance on Third-Party Relationships). In September 2026 the agencies proposed replacing that guidance; it is a proposal, not final (OCC NR 2026-77).
What do regulators watch in fintech deposit programs?
Their July 2024 joint statement flags operational, compliance, strategic, liquidity and concentration risks, consumer protection, end-user confusion, and misrepresentation of deposit insurance coverage. It also says banks are neither prohibited nor discouraged from these arrangements (OCC Bulletin 2024-20).
What happens when a sponsor bank gets an enforcement action?
It can be told to slow down. In a 2024 Federal Reserve action, a sponsor bank had to get prior approval before adding new fintech partners (Federal Reserve, June 14, 2024). A platform isn't the bank. If the sponsor changes, your program can change with it.
How do we help?
We're not a bank, processor, or money transmitter. We structure the deal, build the file, and place it with institutions in our network: decades of relationships with 40+ financial institutions and solution providers. The bank decides, and approval is never guaranteed.
Related
Questions
Is a BaaS platform the same as a sponsor bank?
No. The platform is a technology and program layer. The sponsor bank holds the accounts and carries the regulatory responsibility.