To choose a sponsor bank, check five things before you sign: the bank’s charter and regulator, its enforcement record and any limits on new partners, how it will oversee your program, how customer funds and records will be kept, and what happens if either side exits. Most of these checks use public regulator records, so a fintech or software platform can run them before the first call with the bank.

1. Confirm the charter and the regulator

Look the bank up in FDIC BankFind by name or FDIC certificate number. The charter class tells you which federal agency supervises it, and that decides where its enforcement record is published:

Charter Primary federal regulator Where orders are published
National bank or federal savings association OCC OCC Enforcement Action Search
State bank, Federal Reserve member Federal Reserve Federal Reserve enforcement actions
State bank, not a Federal Reserve member FDIC FDIC Enforcement Decisions and Orders

State banks also answer to their state regulator, which may join the order: Sutton Bank’s 2024 order was issued jointly by the FDIC and Ohio’s Division of Financial Institutions. Our sponsor banks directory lists the charter, regulator and certificate number for each bank we profile.

2. Check the enforcement record

Search the regulator’s database and our sponsor bank enforcement actions tracker. For each order, note three things:

  • Status. In force or terminated, with the terminating document.
  • Restrictions on new business. Cross River Bank’s order requires the FDIC’s written non-objection before a new third-party lending partner or credit product; Evolve Bank & Trust needs its supervisors’ prior written approval before new fintech partners in its Open Banking Division; Lineage Bank may not onboard new fintech partners until its formal onboarding process is in place.
  • Lookbacks and remediation. Sutton Bank must review prepaid card customers back to July 1, 2020; Choice Financial Group must review customers onboarded through third parties.

A restriction does not always rule a bank out, but it can add a regulator’s review to your launch timeline. An order is a fact about the bank’s practices, not a verdict on its partners.

3. Expect the bank to review you

Bank regulators hold the bank responsible for its partners. The Interagency Guidance on Third-Party Relationships of June 6, 2023, issued by the FDIC, the Federal Reserve and the OCC, describes a life cycle of planning, due diligence and selection, contract negotiation, ongoing monitoring and termination. Recent orders show what that means in practice:

  • Thread Bank had to set board-approved risk limits for each fintech partner.
  • Evolve had to rate each partner’s risk and define who keeps ledgers and sub-ledgers.
  • Sutton had to map each program manager’s anti-money-laundering duties, from customer identification to suspicious activity reporting.

On September 11, 2026 the agencies and the NCUA proposed replacing the 2023 guidance with principles-based guidance and rescinding the July 2024 joint statement on bank-fintech deposit arrangements. Comments are due November 16, 2026; until the agencies finalize it, the 2023 guidance stays in effect.

4. Ask how funds and records are kept

The Synapse case shows what goes wrong when records do not match. Synapse Financial Technologies, a middleware provider between fintechs and banks, filed for Chapter 11 on April 22, 2024. The CFPB later alleged a shortfall of $60 million to $90 million between the funds banks held and Synapse’s records, and on November 28, 2025 it allocated $46,248,291 from its Civil Penalty Fund to affected consumers.

In September 2024 the FDIC proposed a rule requiring banks with custodial deposit accounts with transactional features to keep records of each beneficial owner and balance, reconcile at least daily, and keep “direct, continuous, and unrestricted access” to records a third party maintains. As of September 23, 2026 the proposal was neither final nor withdrawn. Ask the bank:

  • Who keeps the ledger of end-customer balances, and how often it is reconciled with the bank’s records.
  • Whether the bank has direct access to the ledger if a third party keeps it.
  • Whether your deposits could count as brokered deposits. The FDIC’s 2020 rule, with its “enabling transactions” exception, still applies; a 2024 proposal to narrow it was withdrawn in March 2025.

5. Plan the exit before you start

Several orders require banks to plan for ending fintech relationships. Lineage Bank must keep contingency plans for an orderly termination of significant fintech partners; Thread Bank had to write an exit plan covering third-, fourth- and fifth-party providers; Evolve must give supervisors a liquidity impact analysis before exiting a partner. Ask for the contract’s termination terms, notice periods, data transfer and how customers would be moved to another bank.

Questions to put to a sponsor bank

  1. Is the bank under any enforcement order, and does it limit new programs?
  2. Which regulator will review our program, and what is the bank’s approval process?
  3. Who performs customer identification and suspicious activity monitoring, and how does the bank test it?
  4. Who keeps the ledger, and how often is it reconciled?
  5. What reports will the bank require from us, and how often?
  6. What are the exit and migration terms?