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Bluegrass

Fintech partners reviewed at onboarding and monitored for as long as the program runs.

Bluegrass builds partner oversight systems for sponsor banks. Each partner's policies, controls testing, marketing, complaints and compliance reports are read against the program agreement and your requirements, and every gap is drafted as a finding for your oversight team to decide on.

A sponsor bank answers to its examiners for every partner's compliance program, and recent enforcement actions against sponsor banks have centered on whether that oversight kept pace as their programs grew.

What fintech partner oversight involves today

Before a program launches, the partner sends its compliance management system, BSA and consumer compliance policies, complaint procedures, financials and SOC reports, and the bank's team reads all of it against its own standards and the program agreement. After launch the same team reviews the partner's marketing, complaints, monitoring results and periodic compliance reports on the calendar the agreement sets.

Each partner sends documents in its own format and on its own schedule, so most of the work is chasing, reading and reconciling rather than judging. As a bank adds partners, oversight either needs more staff or becomes lighter, and a lighter review is what examiners tend to cite.

How automated fintech partner oversight works

  1. 01

    Collect from each partner

    Documents and reports arrive through a partner portal, email or a shared drive, and each is identified by type and matched to the partner and the obligation it answers.

  2. 02

    Review at onboarding

    The partner's policies, procedures and controls are read against your requirements for the program, covering BSA and AML, consumer compliance, complaints, information security and financial condition, with each gap cited to its page.

  3. 03

    Monitor on a schedule

    Marketing, complaints, monitoring results and compliance reports are reviewed as they arrive, and anything late, missing or out of line with the agreement is listed for your team.

  4. 04

    Draft findings and requests

    Findings, follow-up requests to the partner and the summary for your oversight committee are drafted in your templates.

  5. 05

    Track to closure

    Each finding is tracked until the partner closes it, and the partner's file holds every review, response and decision, ready for an examiner.

Where people stay in the loop

Approving a partner, accepting its remediation and deciding when to escalate stay with your oversight team and committee. The system's findings are first compared with your team's own on past reviews, and each new type of review is added only after that comparison.

The systems it works with

The system works with your third-party risk platform, partner portal or shared drives and with the reports partners already send, so partners can keep delivering them as they do today. Findings and decisions are filed to each partner's record.

When to build it, and when to buy it

Third-party risk platforms handle vendor oversight well, and some now offer modules for fintech partners, so a bank with a few partners on standard programs may find one of those sufficient.

A custom build makes sense when your program agreements carry obligations of their own, when partners report in formats no product expects, or when partner oversight should share its reading with vendor due diligence and marketing review.

We hold no reseller agreements, partner quotas or revenue share with any vendor, so a recommendation to buy is made on its merits.

What this work costs you today

A quick way to put a number on the problem before talking to anyone, using your own figures rather than ours.

Enter your volume and the minutes each one takes to see what the work costs in a year.

The numbers stay in your browser and are not stored or sent anywhere. Bring the figure to the first call, since it is the baseline any system should be measured against.

Questions about fintech partner oversight

Does it review partners' marketing?
It checks each partner's ads, web pages and disclosures against the program agreement and the rules that apply, including how deposit insurance is described, and lists each issue with its passage for your compliance team.
Can partners submit documents through it?
Partners can upload documents and answer follow-up requests through a portal built into the system, or keep sending them as they do today, and either way each item is matched to the partner and the obligation it answers.
Does it monitor partners' transactions?
Transaction monitoring stays with your own tools and the partner's. The system reads the results, alert volumes and reports that come out of them and flags anything that departs from the agreement or from the partner's earlier reporting.

A senior team that has done this before

We are a small, entirely senior team with fifty years of combined AI engineering, multiple granted patents and Y Combinator founders, from Yale, MIT, McKinsey, Goldman Sachs, Microsoft and Vista Equity Partners. The people who scope your work are the people who write the code.

Selected work

We built the AI transformation roadmap for a top-50 P&C brokerage, and it is saving the firm millions of dollars in vendor fees it did not need to pay.

Clients include some of the largest banks, RIAs, fintechs and AI labs, as well as a top-3 P&C carrier, a top-10 P&C brokerage, a top-5 trucking brokerage, a leading specialty MGA and a leading trucking MGA.

We run only 3 to 5 engagements at a time, so that every client works directly with the senior team.

About the team
Dozens
of insurance companies, RIAs, banks and fintechs we have worked with
50 yrs
combined AI engineering experience
10+ Patents
granted to members of the team
100%
of the IP we build is assigned to you

Find out whether this is worth building for your business.

A 30-minute call with an engineer usually shows whether this is worth building. Within a week you will have a free written point of view, including whether a packaged product would serve you better.