Annual Fintech CMS Audits

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Fulfill your sponsor bank's annual CMS audit requirement—with a low-friction, fixed-fee engagement accepted by most major sponsor banks.

The annual audit your sponsor bank requires— without the annual headache

Sponsor banks increasingly require fintechs to undergo independent annual CMS audits. Regulators expect it. Bank examiners look for it. But most audit providers treat it like a custom consulting engagement—slow, expensive, and high-friction.

We built a streamlined, fixed-fee CMS audit specifically for fintechs. Our methodology aligns with FDIC, OCC, and Federal Reserve expectations for third-party risk management. The result: a report your sponsor bank can rely on, delivered faster and at a fraction of the cost of traditional auditors.

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Why fintechs need this

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Sponsor Bank Requirements

Most sponsor banks now require annual independent CMS audits as part of their third-party risk management programs. It's no longer optional—it's table stakes for maintaining your partnership.

Regulatory Expectations

Recent FDIC and OCC enforcement actions have emphasized independent testing of fintech partner compliance programs. Your sponsor bank's examiners expect to see it—and so should you.

Partnership Continuity

A clean, professional CMS audit demonstrates your commitment to compliance maturity—strengthening your relationship with existing sponsors and opening doors to new ones.

Board & Management Oversight

Evaluation of governance structure, compliance reporting, and senior leadership accountability for the compliance program.

Policies & Procedures

Review of documented policies, update cycles, alignment with regulatory requirements, and evidence of employee acknowledgment.

Risk Assessment

Assessment of your compliance risk identification, measurement, and monitoring processes—including product, regulatory, and operational risks.

Training & Competency

Verification of compliance training programs, completion tracking, and role-specific knowledge requirements.

Monitoring & Testing

Review of ongoing compliance monitoring activities, transaction testing, and quality assurance processes.

Consumer Complaint Handling

Evaluation of complaint intake, tracking, resolution, and root cause analysis processes.

Corrective Action & Issue Management

Assessment of how compliance findings are tracked, remediated, validated, and reported to stakeholders.

Third-Party Oversight

Review of your vendor management program, due diligence processes, and ongoing oversight of critical service providers.

BSA/AML Program

Assessment of your BSA/AML program governance, policies, risk assessment, customer due diligence, transaction monitoring, and suspicious activity reporting processes.

What we assess full CMS and AML coverage

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What you get sponsor bank-ready deliverables

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Independent CMS Audit Report

A comprehensive report aligned with regulatory expectations and formatted for sponsor bank review. Clear findings, risk ratings, and recommendations.

Executive Summary

A board-ready summary highlighting key strengths, areas for improvement, and overall CMS maturity assessment.

Findings & Recommendations

Prioritized findings with clear remediation guidance—actionable recommendations you can implement before your next review.

Evidence Workpapers

Organized documentation supporting every finding—available for sponsor bank or examiner review upon request.

Why we're different built for fintechs

Fixed-Fee Pricing

No hourly billing, no scope creep. You know the cost upfront. Our AI-integrated workflows let us deliver faster—and we pass that efficiency to you.

Low-Friction Process

Streamlined document requests, a shared platform for evidence submission, and minimal back-and-forth. We respect your team's time.

Accepted by Major Sponsor Banks

Our methodology and report format are designed to meet the expectations of leading BaaS and sponsor banks. One audit, broad acceptance.

Practitioner-Led Judgment

AI accelerates our work, but every finding and recommendation is reviewed and owned by experienced compliance practitioners who understand fintech operations.

Fast Turnaround

With the information we need available upfront, most engagements move from kickoff to final report in under a month, aligning with sponsor bank expectations.

Real-Time Visibility

Track progress in our shared platform. No waiting for status calls to know where things stand.

Year-Over-Year Context

Return clients benefit from persistent context—next year's audit builds on this year's baseline, tracking remediation and program maturity over time.

How it works simple and fast

Frequently asked questions

Will my sponsor bank accept your audit report?

Our methodology and report format are designed to align with FDIC, OCC, and Federal Reserve guidance on third-party risk management. We've worked with fintechs across multiple sponsor bank relationships, and our reports are accepted by most major BaaS and sponsor banks. If you have specific sponsor requirements, we're happy to discuss during scoping.

What's the difference between this and a SOC 2 audit?

SOC 2 focuses on security controls and is performed by CPAs under AICPA standards. A CMS audit evaluates your overall Compliance Management System—governance, policies, risk assessment, training, monitoring, and consumer protection. Many fintechs need both: SOC 2 for security assurance and CMS audits for regulatory compliance.

How much does it cost?

Pricing is fixed-fee and based on the complexity of your operations—product types, transaction volumes, and regulatory footprint. Contact us for a quote. We're typically 30-50% less expensive than traditional audit firms, with faster turnaround.

What if we have findings?

Most CMS audits identify areas for improvement—that's the point. Our report includes prioritized, actionable recommendations. We can also help you remediate findings through our Elevate Programs or Elevate Readiness services if needed.

Do you cover BSA/AML in the CMS audit?

Yes. Our standard CMS audit includes BSA/AML coverage, as most sponsor banks require both. We assess the governance and structure of your BSA/AML program alongside your overall compliance management system.