Fractional Compliance Officer for Fintech and Payments

Do you need a U.S.-based compliance officer for your launch? Is your program not yet large enough to justify a full-time hire? Would you like a founding team member to become your compliance officer, but they need more experience?

Prepaid Program Management LLC provides U.S.-based fractional compliance officer services for fintech companies and payment card program managers. We provide ongoing compliance leadership, work with your issuing bank, and help your team establish and maintain practical compliance processes.

You get experienced support for the responsibilities your business needs today, with a path to develop internal leadership as your program grows.

What is a Fractional Compliance Officer?

A Fractional Compliance Officer provides ongoing compliance leadership for an agreed scope and level of involvement. The role can include compliance planning, policies and procedures, bank coordination, control oversight, audit preparation, and board/management reporting.

At Prepaid Program Management, we work with your existing employees and service providers. We help establish who owns each activity, what needs to be documented, and when issues need to be escalated.

Compliance leadership for your stage of growth 

Launching a U.S. payment card program

We help you prepare the compliance framework supporting your launch, coordinate bank due diligence requests, and address feedback on policies, procedures, and program controls.

If your engagement includes serving as the designated compliance officer, we define that responsibility and coordinate any required appointment or bank review.

Growing before a full-time hire makes sense

A growing program still needs consistent oversight. We help you maintain a compliance calendar, review emerging issues, manage bank requests, and track corrective actions.

Your leadership team gets visibility into what is working, what needs attention, and which decisions require action.

Developing your future compliance officer

If a founding team member or existing employee will eventually lead compliance, we help them build the knowledge and judgment needed for the role.

Coaching takes place through practical work: reviewing policies, preparing bank responses, evaluating issues, and managing compliance activities. Responsibilities can transition as that person demonstrates readiness.

What our Fractional Compliance Officer services cover

The engagement is tailored to your products, bank relationships, and operational responsibilities. In short, though, we cover everything a full-time employee would do, including communicating through your email domain. 

Compliance assessments and planning

Review your current program, identify gaps, and establish a prioritized action plan with clear responsibilities and deadlines. Maintain a compliance calendar and track outstanding issues through resolution.

Issuing bank coordination

Coordinate compliance requests, due diligence, incident reporting, marketing material approvals, and proposed program changes. Help your team prepare documented responses and follow through on commitments.

Policies, systems, and procedures

Develop and update documentation around your actual products, systems, and processes. Incorporate bank feedback, audit findings, and changes to the program. Work with your Product, Customer Service, and Technology teams to ensure compliance is considered from the outset. 

AML, customer identification, and OFAC oversight

Guide the design and review of anti-money laundering controls, customer identification and due diligence, sanctions screening, transaction monitoring, and escalation procedures. We monitor and optimize these processes to maximize user onboarding and retention. 

Consumer protection and complaints

Support oversight of Regulation E error-resolution processes, consumer complaints, disclosures, and marketing review. Help your team document issues, identify patterns, and address underlying causes.

Third-party, privacy, and information security coordination

Help define and review compliance responsibilities involving vendors, agents, privacy, information security, and business continuity. Coordinate with the people responsible for the technical and operational work.

Audit preparation and remediation

Organize audit requests, coordinate supporting documentation, and track findings through corrective action. Use recurring reviews throughout the year to identify problems before the annual audit.

Training and leadership reporting

Provide employee and board training, coach internal compliance personnel, and develop reporting on open issues, review results, training completion, and remediation. 

How we work with your team

Assess your program. We review your products, bank relationships, documentation, controls, and immediate priorities.

Define the engagement. We agree on responsibilities, decision-making authority, deliverables, and the level of involvement.

Establish a working structure. We put the compliance calendar, issue tracking, reporting, and meeting schedule in place.

Provide ongoing leadership. We review progress, address emerging concerns, coordinate with your partners, and adjust priorities as your business changes.

Your team performs daily operational activities. We provide the agreed compliance leadership, oversight, and coaching.

Payments experience behind the guidance

The service is led by Jake Posey, whose work includes serving as a consulting compliance officer for program managers and helping banks establish and operate payments products.

Jake also created Payments Academy, which provides professional payments education and compliance training.

Our approach connects compliance requirements with the realities of launching and operating a payment card program: customer onboarding, transaction processing, bank relationships, complaints, and ongoing oversight.

Frequently asked questions

Can you provide a U.S.-based compliance officer for our launch?

Yes. We provide U.S.-based fractional compliance leadership for fintech and payment card programs. The engagement defines the role, responsibilities, and any formal appointment requirements, including coordination with your issuing bank.

Can you open and supervise a U.S. office for our launch?

Yes, we have opened offices for clients, set them up, and run them until the U.S. team is in place to ensure you are meeting your partner requirements for a physical U.S. address. 

Can you work with our existing compliance team?

Yes. We can provide leadership and specialist guidance alongside your existing team, including coaching for the compliance lead and reporting into a global Compliance Officer.

Can you train a founder to become our compliance officer?

Yes. We provide hands-on coaching and a structured transition of responsibilities as the founder gains experience. The transition is based on readiness and the requirements of your program and bank relationship.

Do you help with bank reviews and audits?

Yes. Support can include coordinating requests, organizing evidence, preparing responses, and managing remediation. Recurring internal reviews also help your team prepare throughout the year.

What does a Fractional Compliance Officer cost?

Packages start at $5,000 per month.  Pricing depends on your program’s complexity, products, bank relationships, existing controls, and the responsibilities included in the engagement. We define the scope and pricing after learning about your program.

Do I have to sign a long term contract?

We offer both long-term engagements and month-to-month options, and you can scale our hours up or down without penalty. 

Get the compliance leadership your program needs

Whether you are preparing to launch, strengthening an existing program, or developing your future compliance officer, we can help you establish a practical path forward.