BaaS Program Governance

BaaS Program Governance

Define how a bank and its technology or distribution providers share operating responsibilities without obscuring the bank's decision authority.

Map the program and its dependencies

Identify the products, customer journeys, contractual parties, systems and data flows in the proposed program. Document which party performs onboarding, servicing, monitoring and complaint handling. Preserve a clear view of subcontractors and downstream providers.

Make oversight evidence available

Agree on reporting, access to records, control testing, incidents and escalation before relying on a provider workflow. Define the data and explanations the bank needs to review exceptions and customer outcomes. Trace unresolved issues to named owners and authorized decisions.

Plan change and exit together

Assess the effect of new products, changed rules and provider transitions on the program. Establish continuity, data return and customer support arrangements. Cicrim can help structure responsibility maps, oversight workflows and readiness reviews for the institution to approve.

Define a focused next step

Bring the current process, known constraints and accountable owners to a working session. Cicrim can help define the scope, working outputs and acceptance criteria before implementation begins.

Discuss baas program governance