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description: Assess partner bank compliance requirements — OCC/FDIC expectations, regulatory pass-through
---
# 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
2. **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)
3. **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
4. **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
5. **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
6. **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
7. **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
8. **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
9. **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
10. **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