Minimum Viable Compliance Program: 30-Day Roadmap for Fintechs

Introduction — Why Minimum Viable Compliance?

Regulators can pause launches.

If you’re the COO or General Counsel racing to ship a payments or lending feature, this matters. Many early-stage fintechs ship under regulatory uncertainty and then pay for delays. This guide shows how to build a Minimum Viable Compliance Program in 30 days so you can launch defensibly without bureaucracy.

You’ll follow a week-by-week plan: foundations and triage, program build, licensing and exam prep, and operational handoff.

Rapid 30‑day Milestone Map and Metrics

This 30‑day plan breaks work into clear deliverables: Day 0–7 for stakeholder alignment and rapid risk triage; Days 8–14 to draft policies, controls, and evidence; Days 15–30 to triage licensing, run a mock exam, and prepare regulator scripts.

The “minimum viable” idea means you implement the smallest defensible set of controls that let you launch and answer regulators.

Track progress with three simple metrics:

• Control coverage percentage.
• Number of open compliance questions.
• Licensing risk score by state.

Use CFPB guidance for disclosure and exam priorities. Use NIST CSF for cyber basics. Use FinCEN for AML triggers.

Do this now: create a one‑page deliverables list for each week and pin it in Slack.

Week 0–1: Stakeholder Alignment and Rapid Triage

Day 0: Stakeholder alignment and scope

• Identify core stakeholders: product, engineering, legal, ops, and one compliance owner who makes final calls.
• Produce a one‑page scope describing product features, markets, timeline, and the top three compliance priorities.
• Run a two‑hour kickoff with this agenda: top 3 regulatory risks, owners for evidence, and launch blockers.

Short dialogue example to use in the kickoff:

• Product: "Which data do we store?"
• Compliance: "Map flows first. Then we decide retention."

Keep conversations concrete and time‑boxed.

Days 1–4: Risk inventory and priority mapping

• Map customer journeys that touch money, data, or credit. Flag where flows touch PII, payments, or underwriting.
• Annotate applicable law by flow (TILA for lending, FCRA for credit, GLBA for data handling).
• Prioritize with a heatmap (likelihood × business impact). Use FinCEN for AML triggers and AICPA for SOC expectations when vendor assurance matters.
• Create Jira tickets, assign owners, and set 48‑hour decision SLAs for launch blockers.

Hypothetical case expanded: A payments team skipped consent logs and had to pause a rollout for two months. Engineers scrambled to recreate logs, product lost launch momentum, and leadership had to explain the delay to investors. Document that story in your risk log so the team remembers why consent logging matters.

Days 5–7: Quick controls to remove launch blockers

• Implement three minimum controls: clear consumer disclosures, explicit consent flows, and data classification for customer PII.
• Draft short policies for privacy, AML trigger thresholds, and incident escalation.
• Build an evidence folder per control with screenshots, policy version, and named owner.

One small rule: each evidence folder should include one screenshot, one policy excerpt, and one log export. That triad speeds exam responses.

Week 2: Draft the Minimum Compliance Program

Policies, procedures, and role definitions

• Produce an executive policy pack: Compliance Program Overview, Escalation Matrix, and Roles & Responsibilities.
• Create concise SOPs for highest-risk processes: KYC/KYB, dispute handling, and consumer disclosures.
• Adapt templates from public repos and regulator samples, such as GitHub policy templates and CFPB examiner samples.

What to deliver by the end of Week 2:

• One-page program charter.
• Three SOPs (KYC/KYB, disputes, disclosures).
• Escalation matrix with names and backup contacts.

Add a short SOP excerpt to show tone and length. Keep it to 3–5 sentences so engineers and product can read it.

Controls, monitoring, and testing plan

• Define 5–7 core controls to run daily/weekly: consent logging, transaction reconciliation, data access lists, SOC vendor checks, and dispute triage.
• Set a light testing cadence: owner, frequency, pass criteria, and simple evidence tags (e.g., "last test: 03/01, result: pass").
• Map controls to CIS Controls for prioritized cyber hygiene  and use CIS self‑assessments to score coverage.

Keep it practical: a control should take no more than 15 minutes to test for a startup.

Evidence and onboarding for the owner

• Create a central evidence repository in Notion or Google Drive and map each control to artifacts. Start with Notion templates for SOPs and wikis.
• Draft a 30‑day onboarding checklist for the compliance owner: top evidence, escalation contacts, and key Jira filters.
• Run a 60‑minute tabletop on one customer journey and confirm that controls generate the expected artifacts.

Practical tip: lock a "control owner" calendar reminder for monthly tests. It prevents quiet drift.

Days 15–30: Licensing, Exam Readiness and Prep

Licensing triage and state filing plan

• Map product activities to state triggers (money transmission, lending, collections). Use CSBS for money transmission resources and NMLS for mortgage and MSB checks.
• Build a prioritized 50‑state filing plan: states to file first, those to avoid, required forms, ballpark fees, and timelines.
• Include a licensing budget estimate and a named owner for filings. Use a quick state checklist like the NerdWallet roundup as a cross‑check.

Example priority: Start with your home state, then CA and NY for consumer products, and delay low‑volume states until you have local counsel mapped.

Audit and exam readiness checklist

• Compile minimum artifacts examiners want: program charter, risk assessment, control evidence, remediation logs, and named spokespeople.
• Build an "exam playbook" with templated responses and contact points. Pull CFPB sample documentation requests for format and expectations.
• Run a mock exam: pick three document requests, time your response, and note gaps. Use AuditBoard resources for templates and playbooks .
• Package evidence with a clear index and direct links so responses are rapid and defensible.

Practice packaging a single request in under 48 hours. If you can do that, you’ve proven the team can respond under pressure.

Regulator communication and escalation protocol

• Draft a short protocol: who speaks externally, escalation thresholds, and template language for regulator emails.
• Decide when to proactively inform regulators (material incident or consumer harm) and when to wait. Keep messages factual and brief.
• Track all regulator contacts in a shared log and preserve contemporaneous notes.

Ongoing Operations: Embed Compliance

Integrate compliance into product sprints

• Add a lightweight gating checklist to sprints: design review → compliance quick review → approval or remediation ticket.
• Create a compliance ticket type in Jira and set SLAs (48 hours for product questions).
• Put compliance questions into PRDs and release checklists so engineers avoid late rework.

Short rule: require a compliance signoff before production rollouts that touch money or consumer data.

Monitoring, reporting, and continuous improvement

• Build a one‑page compliance dashboard: open issues, control test pass rate, licensing status, and recent regulator contacts.
• Schedule monthly control reviews and quarterly risk reassessments.
• Use low‑cost monitoring tools and vendor assurance reports (SOC) to reduce repeated evidence requests. For vendor guidance, consult FFIEC vendor resources.

Conclusion — Next Steps to Take This Week

Do three things this week: map the customer flow, assign a compliance owner, and run the two‑hour kickoff.

FAQs

Q: How long before the MVP program needs expansion?
A: Plan to expand in 3–6 months as you add products or states. Use quarterly reassessments to guide scope changes.

Q: Is a Fractional CCO enough versus hiring full-time?
A: For early-stage fintechs, a Fractional CCO gives senior decision-making without headcount cost. Hire full-time when you need continuous institutional memory.

Q: What controls differ between payments and lending?
A: Payments focus on AML/KYC and money transmission licensing. Lending centers on disclosures (TILA), underwriting records, and FCRA compliance. Start where money and consumer rights intersect.

Q: What low-cost tools work for evidence collection?
A: Notion or Google Drive for repositories, Jira for tracking, and simple CSV exports for logs. Notion templates are a quick starter.

Q: When to begin state licensing checks?
A: Start licensing triage as soon as you map flows that move money or credit. Use CSBS and NMLS for initial validation.

Q: What documents do examiners always ask for?
A: Program charter, risk assessment, control evidence for a sample period, remediation logs, and named contact info. See CFPB sample requests for detail.