Fractional CCO and BSA Officer support

What does a fractional CCO do?

A fractional chief compliance officer does the work of the role on a part-time schedule, with the same accountability. In practice that means:

• Preparing and presenting board and compliance committee reports
• Acting as the compliance contact for examiners and, for fintechs, the sponsor bank’s partner oversight team
• Managing exams and sponsor bank reviews, from the first request list to closed findings
• Reviewing and recommending policies for approval
• Running issue management, so findings have owners, dates, and validation before closing
• Overseeing training, and reviewing new products, features, and marketing before launch

What about the BSA Officer role?

Every bank and credit union has to designate a qualified individual to coordinate and monitor day-to-day BSA compliance (for example, 12 CFR 21.21 for national banks and 12 CFR 748.2 for federally insured credit unions), and a fintech’s sponsor bank will expect a named person who owns BSA/AML compliance for the program. Examiners expect that person to have the authority, independence, and resources to run the program day to day. A fractional BSA Officer can fill that role while you recruit, or support the officer your board designates: maintaining the BSA/AML risk assessment, overseeing monitoring and alert decisions, preparing BSA reporting to the board, and getting the program ready for independent testing. How the role is structured is a decision for your board, and for a fintech, one to agree with the sponsor bank in advance.

When does fractional support make sense?

• A fintech before or after launch that needs a credible compliance lead for sponsor bank due diligence but not yet a full-time executive
• A bank or credit union with a vacancy, where the role can’t sit empty during a search or an exam cycle
• A program under remediation, where the existing team needs senior support to work through MRAs or partner bank findings

Fractional support is a poor fit when the volume of day-to-day decisions already calls for a full-time leader. Then it works best as a bridge until that person starts.

How an engagement works

1. A 20-minute call about the role, your deadline, and what needs attention first. We reply to every request within two business days.
2. A written scope: responsibilities, hours, reporting lines, what the board approves, and how the role hands off at the end.
3. An engagement letter, then a first 30 days focused on the documents an examiner or sponsor bank reads first: the risk assessments, the issue log, and the most recent board report.

Fractional leadership is one part of Key Compliance Group’s compliance consulting, alongside program builds, risk assessments, compliance testing, and exam preparation. An engagement can use the program kits as the starting point for policies and workbooks, so the institution keeps documents it owns when the engagement ends.

Related: compliance consulting services · compliance kits for community banks and credit unions · the free Sponsor Bank Readiness Checklist