Bank Partnership

Bank Partnership Compliance Assessment

Assess partner bank compliance requirements for "$ARGUMENTS". Evaluate regulatory expectations for bank-fintech partnerships, compliance management system pass-through, and examination readiness.

Prerequisites

Read .metapowers/compliance/$ARGUMENTS/00-scope.md. If this file does not exist, tell the user:

> Phase 0 (Scope) has not been completed for "$ARGUMENTS". Run /compliance:regulatory-landscape $ARGUMENTS first, or use --skip-checks to bypass.

If --skip-checks is present in $ARGUMENTS, skip this check.

Process

1. Read context files:

• Read plugins/compliance/shared/grc-lifecycle-guide.md for GRC methodology reference
• Read plugins/compliance/shared/assessment-template.md for output structure
• Read .metapowers/compliance/$ARGUMENTS/00-scope.md for scope and control framework context

1. Regulatory expectations for bank-fintech partnerships:

• Assess alignment with OCC Third-Party Risk Management guidance (OCC 2013-29, 2023-17)
• Evaluate compliance with FDIC Financial Institution Letters on third-party relationships
• Review Federal Reserve SR 13-19 guidance applicability
• Assess interagency guidance on third-party relationships (June 2023)
• Evaluate how the partnership model maps to regulatory definitions (critical activity, significant bank function)

1. Compliance management system requirements:

• Assess compliance management system (CMS) components passed through from partner bank
• Evaluate board/management oversight requirements imposed on the fintech
• Review compliance policies and procedures mandated by the bank partner
• Assess compliance monitoring and testing expectations
• Evaluate complaint management and consumer response requirements

1. Consumer compliance obligations:

• Assess UDAP (Section 5 of FTC Act) compliance in product design and marketing
• Evaluate UDAAP (Dodd-Frank Act) compliance for unfair, deceptive, or abusive acts or practices
• Review fair lending compliance (ECOA, Fair Housing Act) in credit products
• Assess Community Reinvestment Act (CRA) implications and data reporting
• Evaluate Truth in Lending (TILA), Truth in Savings (TISA), EFTA/Reg E compliance
• Review fair debt collection practices where applicable

1. Examination readiness:

• Assess preparedness for regulatory examinations (OCC/FDIC can examine the fintech through the bank)
• Evaluate document production capabilities and response timelines
• Review management's ability to respond to regulatory inquiries
• Assess audit trail completeness for regulatory demonstration
• Evaluate experience with prior examinations and findings remediation

1. Information security requirements from partner:

• Assess information security standards mandated by the bank partner
• Evaluate security assessment and penetration testing requirements
• Review incident response and breach notification obligations to the bank
• Assess access control and data handling requirements
• Evaluate SOC 2 or equivalent certification requirements

1. Data sharing and privacy obligations:

• Assess Gramm-Leach-Bliley Act (GLBA) privacy notice and opt-out requirements
• Evaluate data sharing agreements and permissible use restrictions
• Review data minimization and purpose limitation in the partnership
• Assess cross-border data transfer restrictions imposed by the bank
• Evaluate consumer data rights and request handling procedures

1. Vendor oversight documentation requirements:

• Assess due diligence documentation maintained for the bank partner
• Evaluate ongoing monitoring and reporting cadence (quarterly, annual reviews)
• Review SLA compliance tracking and reporting
• Assess subcontractor/fourth-party oversight obligations
• Evaluate right-to-audit clauses and audit facilitation readiness

1. Contingency and exit planning:

• Assess business continuity planning for partnership disruption
• Evaluate data portability and customer transition procedures
• Review contractual exit provisions (wind-down timelines, customer notification)
• Assess regulatory notification requirements upon partnership termination
• Evaluate alternative partner bank identification and transition planning

1. Write the artifact to .metapowers/compliance/$ARGUMENTS/01-assess/bank-partnership.md following the assessment template structure with:

• Regulatory Framework — applicable guidance and partnership classification
• CMS Pass-Through — compliance management system requirements and adequacy
• Consumer Compliance — UDAP/UDAAP, fair lending, and consumer protection readiness
• Examination Readiness — preparedness for regulatory scrutiny through the bank
• Information Security — bank-mandated security requirements and compliance
• Data Governance — GLBA, data sharing, and privacy obligations
• Vendor Oversight — documentation, monitoring, and reporting requirements
• Contingency Planning — exit strategy and business continuity
• Evidence Inventory — existing evidence and evidence gaps
• Remediation Priorities — ranked list of gaps to address

Output

The bank partnership assessment written to .metapowers/compliance/$ARGUMENTS/01-assess/bank-partnership.md. Present a summary to the user highlighting:

• Overall partnership compliance maturity
• Consumer compliance readiness across key regulations
• Examination readiness assessment
• Top 3 gaps requiring remediation

Source & license

This open-source skill is cataloged on AgentStack and links to its original source — we do not rehost the code.

• Author: bromso
• Source: bromso/metapowers
• License: MIT
• Homepage: https://bromso.github.io/metapowers/

Install and usage instructions live in the source repository linked above.