Banking-as-a-Service and partner risk
BaaS products depend on regulated bank sponsors whose requirements, risk appetite, and operational decisions can determine whether and how the fintech product can operate.
Notes on embedded insurance models, partner roles, licensing analysis, and customer-facing responsibilities.
Embedded insurance and insurance-adjacent fintech models should be reviewed for who is selling, advising, referring, administering, collecting information, and communicating with customers.
Distribution models can raise licensing, disclosure, compensation, marketing, and partner responsibility questions. The contractual structure should reflect the actual customer experience.
BaaS products depend on regulated bank sponsors whose requirements, risk appetite, and operational decisions can determine whether and how the fintech product can operate.
BNPL products in Canada face evolving disclosure and consumer protection requirements that depend on product structure, term length, and cost of credit.
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental โ and most are preventable.
Provincial credit legislation requires specific disclosures to borrowers at the time credit is offered โ and the requirements differ across Canadian jurisdictions.