Fabric for sponsor banks

Fabric · Nucleus BankOS module

Partner programs the bank can supervise.

A sponsor bank is the chartered bank that holds the deposits and carries the regulatory responsibility for a fintech partner’s accounts and cards. Fabric gives it isolated programs, limits it sets, the KYC decision and an append-only record of every partner action.

Fabric BSA monitoring across partner programs

At a glance

Limits
Set by the bank; enforced on every write
KYC decision
Platform or bank vendors, never the partner
Isolation
Each partner in its own program
Keys
Issued, rotated and revoked by the bank
Monitoring
One view across every partner program
Records
Append-only, including partner-side events

Specifications

Who controls what

The bank owns authority, capability and limits; the partner operates inside them.

Bank and partner responsibilities
Create and configure a programBank
Set the system of record and limitsBank
Issue, rotate and revoke keysBank; the partner can request
Grant API scopesBank; the partner can request
Register webhook endpointsBank or partner, within the grant
Provision sub-programsPartner, within the grant; the bank approves
Decide KYC and KYBPlatform or the bank’s designated vendors
Oversight tools
Transaction limitsPer-transaction ceilings, daily and velocity caps; raising one is a logged action
Approval queueMoney movement above the auto-release ceiling waits for a person
Inline compliance rulesViolations raise a flag and can route to the bank for review
Cross-partner monitorAlerts from every program in one place
Financial-crime monitoringScreening and transaction monitoring in DarkMatter, on the same core
Audit trailEvery API call, money movement, decision and configuration change, append-only
Partner write-backPartners must log access, security and error events to the same trail
Key revocationImmediate and total; rotation can overlap for a no-outage cutover

Questions

What people ask

What is a sponsor bank?

A sponsor bank is the chartered, insured bank behind a banking-as-a-service program. It holds the deposits, issues the accounts and cards, and answers to regulators for the program, while the partner provides the brand and the app.

What do regulators expect from a sponsor bank?

The 2023 interagency guidance on third-party relationships expects banks to oversee partners in proportion to the risk, as they would their own operations. In practice that means knowing each end user’s balance, controlling onboarding and limits, and being able to show examiners what every partner did.

Can a partner change its own limits or scopes?

No. Limits and scopes are set by the bank administrator; a partner can request a change but cannot make one. A sub-program can only narrow what the bank granted its parent.

How does the bank see activity across partners?

A single compliance monitor shows alerts from every program, and screening and transaction monitoring run in DarkMatter on the same core. A pattern spanning two partners is visible to the bank rather than split across two vendors.

What happens if a partner’s key is exposed?

The bank revokes it, which is immediate and total, and issues a new one. Planned rotations can overlap old and new keys for a cutover window, so there is no outage.

Grow partner deposits without exporting the risk.

A working session on your partner program, your controls and your examiners’ questions.