FR EA
1045-00002 · Calderwood & Harkness LLP · documents
baas-partner-bsa-aml-risk-assessment-template.xlsx DOCUMENT Antitrust
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[sheet: Instructions]

SectionContent
PurposeThis template is a standardized risk assessment tool prepared by Calderwood & Harkness LLP (C&H Matter No. 1045-00002) for use by Belmont Ridge Bank National Association (OCC Charter No. 48271; FDIC Certificate No. 31845) in evaluating the BSA/AML and sanctions risk profiles of each of its 14 active Banking-as-a-Service (BaaS) fintech partners. It is designed for quarterly completion as part of BRB's enhanced BaaS compliance oversight framework, in accordance with the requirements of OCC Consent Order No. OCC-2025-003 (effective January 15, 2025).
FrequencyQuarterly (Q1: Jan–Mar; Q2: Apr–Jun; Q3: Jul–Sep; Q4: Oct–Dec). Initial baseline assessments to be completed by March 31, 2025 for all 14 active partners.
Responsible PartiesPrimary: Warren Ashby, Head of Fintech Partnerships / BaaS Division, in coordination with Thomas Ikeda, BSA Officer / AML Program Director, and Patricia Langston, Chief Compliance Officer. Review/Approval: Compliance Committee (Chair: James Rutherford). Oversight: Calderwood & Harkness LLP (Philip Hartmann, Responsible Partner) and Thornfield Consulting Group LLC (Dr. Vivian Castellano, Managing Director).
Scoring MethodologyEach risk category is scored on a 1–5 scale: 1 = Low Risk, 2 = Low-Moderate Risk, 3 = Moderate Risk, 4 = Moderate-High Risk, 5 = High Risk. The Overall Risk Rating is the weighted average of all category scores, rounded to one decimal place, then mapped to a tier: 1.0–1.9 = Low; 2.0–2.9 = Low-Moderate; 3.0–3.4 = Moderate; 3.5–4.4 = Moderate-High; 4.5–5.0 = High. Partners rated Moderate-High or High require Enhanced Due Diligence (EDD) and escalated reporting to the Compliance Committee monthly.
Regulatory ContextThis assessment supports remediation of Consent Order deficiency categories including: (i) inadequate OFAC sanctions screening for BaaS transaction flows, (ii) deficient SAR filing timeliness and quality, (iii) insufficient CDD/EDD for high-risk customers onboarded through fintech partners, and (iv) board-level oversight deficiencies. BaaS-related SARs represented 54.8% of all SARs filed by BRB in CY 2024 (2,108 of 3,847 total). Total BaaS transaction volume in CY 2024 was approximately $74.3 billion, generating $127.4 million in revenue to BRB.
DistributionCompleted assessments are to be provided to the Compliance Committee, Audit Committee (Chair: Margaret Dao), Risk Committee (Chair: Arthur Connelly), the BSA Officer, the Chief Compliance Officer, Calderwood & Harkness LLP, and Thornfield Consulting Group LLC. Completed assessments should also be maintained in BRB's regulatory examination files for OCC review.
DefinitionsBaaS = Banking-as-a-Service; BSA = Bank Secrecy Act; AML = Anti-Money Laundering; CDD = Customer Due Diligence; EDD = Enhanced Due Diligence; SAR = Suspicious Activity Report; CTR = Currency Transaction Report; OFAC = Office of Foreign Assets Control; MSB = Money Services Business; PEP = Politically Exposed Person; TMS = Transaction Monitoring System; CMP = Civil Money Penalty.
Completion InstructionsFor each BaaS partner, the Assessor should: (1) review all available data including transaction volumes, SAR filings, CDD/EDD compliance status, OFAC screening results, and geographic exposure; (2) assign a score of 1–5 for each of the 8 risk categories using the criteria defined in the Risk Category Definitions sheet; (3) document supporting notes for each score; (4) verify the weighted average calculation; and (5) submit the completed assessment to the Reviewer for sign-off. All assessments must be completed within 30 days of quarter-end.
Escalation ProceduresIf any partner receives an Overall Risk Rating of Moderate-High (3.5–4.4) or High (4.5–5.0), the Assessor must immediately notify the BSA Officer (Thomas Ikeda) and the Chief Compliance Officer (Patricia Langston). Enhanced Due Diligence must be initiated within 15 business days, and a written report must be submitted to the Compliance Committee within 30 calendar days. Partners rated High for two consecutive quarters must be referred for potential relationship termination review.
Version Historyv1.0 — Prepared by Calderwood & Harkness LLP, February 2025. Approved by Philip Hartmann, Partner, Calderwood & Harkness LLP, and Patricia Langston, Chief Compliance Officer, Belmont Ridge Bank NA.

[sheet: Risk Category Definitions]

Risk CategoryWeight (%)DescriptionScore 1 — LowScore 2 — Low-ModerateScore 3 — ModerateScore 4 — Moderate-HighScore 5 — High
Transaction Type & Complexity15%Nature and complexity of transaction types processed through BRB's charter (wire, ACH, card, P2P, lending, deposits). Higher complexity and cross-border transactions increase risk.Single domestic transaction type; low complexityPrimarily domestic; limited transaction typesMultiple domestic transaction types; some cross-borderMultiple transaction types including cross-border wires and ACH; complex payment flowsHighly complex multi-channel flows including international wires, P2P, and nested payment arrangements
Transaction Volume (Annual $)15%Dollar volume of transactions processed through BRB in the assessment period. Reference: Total BaaS volume CY 2024 was $74.3B across 14 partners.< $500M$500M – $2B$2B – $10B$10B – $30B> $30B
Transaction Count (Annual)10%Number of individual transactions processed through BRB's systems. Higher volumes increase screening and monitoring burden.< 1M transactions1M – 5M transactions5M – 15M transactions15M – 30M transactions> 30M transactions
Customer Base Size & Type10%Number and nature of end-user accounts; consumer vs. business; presence of high-risk customer types (MSBs, PEPs, high-net-worth, foreign nationals).< 50,000 accounts; low-risk consumer only50,000 – 250,000 accounts; primarily low-risk consumer250,000 – 1M accounts; mix of consumer and small business1M – 3M accounts; significant business or high-risk segments> 3M accounts or significant high-risk customer segments
Geographic Exposure10%Geographic distribution of partner's customer base and transaction flows; domestic vs. international; presence of OFAC-sanctioned or high-risk jurisdictions.Exclusively domestic; no high-risk state exposurePrimarily domestic; minimal international exposureDomestic with some international transactions; no sanctioned jurisdictionsSignificant international exposure; some high-risk jurisdictionsSubstantial international exposure; transactions involving or near OFAC-sanctioned jurisdictions
OFAC Sanctions Risk15%Risk of sanctions exposure based on transaction type, geography, customer base, and historical screening performance. Reference: BRB's OFAC screening gap affected approximately 12% of NovaPay transactions in CY 2023 (~3.8M of 31.7M unscreened).No international exposure; fully domestic consumer productLimited international exposure; no known screening gapsSome international exposure; screening gaps identified but remediatedInternational exposure with identified screening gaps or near-misses; remediation in progressSignificant international exposure; material screening gaps identified; transactions involving high-risk corridors or jurisdictions
Historical SAR Activity15%Volume and trend of SARs filed related to the partner's customer base and transaction activity. Reference: BaaS-related SARs were 2,108 of 3,847 total BRB SARs in CY 2024 (54.8%).0–10 SARs in trailing 12 months11–50 SARs in trailing 12 months; stable or declining trend51–200 SARs in trailing 12 months201–500 SARs in trailing 12 months; increasing trend> 500 SARs in trailing 12 months or significant year-over-year increase
CDD/EDD Compliance Status10%Adequacy of customer due diligence and enhanced due diligence documentation for the partner's customer accounts held at BRB. Reference: 47,000 high-risk accounts lacked adequate CDD/EDD as of OCC examination (Sept 2024), primarily BaaS-onboarded.100% CDD/EDD compliant; no deficiencies identified> 95% compliant; minor documentation gaps90–95% compliant; remediation underway75–90% compliant; significant gaps; active remediation required< 75% compliant; material CDD/EDD deficiencies

[sheet: Partner Assessment]

Partner #Partner Legal NamePartner Short NameEntity TypeJurisdictionCEO / Primary ContactAddressOnboarding YearProduct / Service DescriptionEnd-User Account CountAnnual Transaction Volume — $% of Total BaaS Volume (%)Annual Loan Originations via BRB — $Assessment PeriodAssessment DateAssessor NameTransaction Type & Complexity — Score (1–5)Transaction Type & Complexity — NotesTransaction Volume ($) — Score (1–5)Transaction Volume ($) — NotesTransaction Count — Score (1–5)Transaction Count — NotesCustomer Base Size & Type — Score (1–5)Customer Base Size & Type — NotesGeographic Exposure — Score (1–5)Geographic Exposure — NotesOFAC Sanctions Risk — Score (1–5)OFAC Sanctions Risk — NotesHistorical SAR Activity — Score (1–5)Historical SAR Activity — NotesCDD/EDD Compliance Status — Score (1–5)CDD/EDD Compliance Status — NotesWeighted Average ScoreOverall Risk Rating TierEDD Required? (Yes/No)Escalation to Compliance Committee Required? (Yes/No)Reviewer NameReviewer TitleReview DateComments / Action Items
1NovaPay Technologies Inc.NovaPayCorporationDelawareEthan Garrison, CEO450 Mission Street, Suite 1200, San Francisco, CA 941052021Consumer payments and P2P transfer application21000003050000000041%N/AQ1 20255P2P and consumer payments; wire and ACH flows; high complexity due to volume and cross-border P2P functionality5$30.5B in CY 2024; largest BaaS partner by volume (41% of total $74.3B)531.7M transactions in CY 2023; highest count among BaaS partners4Approximately 2.1 million end-user accounts; consumer-focused but high volume3Domestic focus with some international P2P corridors5OFAC screening gap identified: approximately 3,800,000 transactions (12.0% of 31.7M) were unscreened in CY 2023; primary driver of Consent Order OFAC finding5Significant contributor to BaaS-related SARs; NovaPay-related SARs tracked separately; estimated >500 SARs in trailing 12 months5Material CDD/EDD deficiencies identified among NovaPay-onboarded accounts within the 47,000 high-risk account remediation population; estimated <75% compliant4.7HighYesYesRemediate OFAC screening gap; complete CDD/EDD for NovaPay-onboarded high-risk accounts; implement enhanced transaction monitoring; monthly escalation reporting required
2FairLend Digital LLCFairLendLimited Liability CompanyDelawareAisha Okonkwo, CEO100 Summer Street, Suite 800, Boston, MA 021102022Online small-business lending platformN/A2080400000028%1400000000Q1 20253Small-business lending; loan originations processed through BRB charter; moderate complexity528% of total BaaS volume; approximately $20.8B in CY 2024 ($74.3B × 28%)3Estimated 8M–12M transactions annually based on lending volume4Business customers; small-business lending inherently carries higher risk (MSB, beneficial ownership complexity)2Primarily domestic small-business lending3Some international beneficial owners among small business applicants; no material screening gaps identified but remediation monitoring ongoing4FairLend-related SARs estimated at 201–500 in trailing 12 months; increasing trend due to business lending fraud patterns4FairLend-onboarded accounts included in the CDD/EDD remediation population; approximately 75–90% compliant; approximately $1.4B in loan originations through BRB in FY 20243.6Moderate-HighYesYesComplete CDD/EDD for FairLend-onboarded accounts; review lending origination BSA controls; enhance beneficial ownership verification procedures
3VaultEdge Inc.VaultEdgeCorporationDelawareMarcus Tan, CEO2200 Ross Avenue, Suite 3600, Dallas, TX 752012023Digital savings and neobanking platform8700001337400000018%N/AQ1 20253Deposit accounts; savings products; moderate complexity; ACH and card transactions418% of total BaaS volume; approximately $13.4B in CY 2024 ($74.3B × 18%)3Estimated 6M–10M transactions annually3Approximately 870,000 deposit accounts; consumer-focused neobanking; some high-net-worth segments2Primarily domestic digital banking; minimal international exposure3Limited international exposure; some screening gaps identified in early onboarding period but largely remediated3Estimated 51–200 SARs in trailing 12 months; stable trend4VaultEdge-onboarded accounts included in CDD/EDD remediation population; estimated 75–90% compliant3.2ModerateNoNoComplete CDD/EDD for VaultEdge-onboarded accounts; continue monitoring SAR trends; validate OFAC screening coverage
4SwiftCard Financial Inc.SwiftCardCorporationNevadaDiana Morales, CEO3900 Paradise Road, Suite 200, Las Vegas, NV 891692021Prepaid debit card program32000028000000003.8%N/AQ1 2025
5Greenline Payments LLCGreenlineLimited Liability CompanyCaliforniaRobert Chiang, CEO1999 Harrison Street, Suite 1400, Oakland, CA 946122022Small business payment processing and merchant acquiring4500019000000002.6%N/AQ1 2025
6Beacon Savings Corp.BeaconCorporationDelawareLaura Whitfield, CEO200 Vesey Street, Suite 2400, New York, NY 102812023High-yield savings and CD product platform19500015000000002.0%N/AQ1 2025
7TrueNorth Lending Inc.TrueNorthCorporationUtahKevin Sorensen, CEO111 South Main Street, Suite 500, Salt Lake City, UT 841112023Consumer personal loan origination platformN/A12000000001.6%850000000Q1 2025
8Pivo Financial Technologies LLCPivoLimited Liability CompanyDelawareSamantha Reeves, CEO800 Boylston Street, Suite 1500, Boston, MA 021992024Embedded finance API platform for e-commerce1100008000000001.1%N/AQ1 2025
9Crestline Digital Banking Inc.CrestlineCorporationGeorgiaJames Oduya, CEO3344 Peachtree Road NE, Suite 1800, Atlanta, GA 303262022Digital checking accounts targeting underbanked communities2800006500000000.9%N/AQ1 2025
10Apex Payroll Solutions LLCApex PayrollLimited Liability CompanyTexasChristine Navarro, CEO1700 Pacific Avenue, Suite 3100, Dallas, TX 752012023Payroll processing and earned wage access platform380005200000000.7%N/AQ1 2025
11HarborPoint Wealth Technologies Inc.HarborPointCorporationNew YorkGregory Altman, CEO55 Water Street, Suite 4200, New York, NY 100412024Digital wealth management and cash management accounts220003800000000.5%N/AQ1 2025
12Bridgeway Student Finance LLCBridgewayLimited Liability CompanyDelawareNatalie Park, CEO1200 17th Street NW, Suite 600, Washington, DC 200362024Student loan refinancing and education savings accountsN/A2500000000.3%180000000Q1 2025
13QuickSettle Payments Inc.QuickSettleCorporationFloridaDavid Herrera, CEO701 Brickell Avenue, Suite 1600, Miami, FL 331312023Real-time B2B payments and invoicing platform150002300000000.3%N/AQ1 2025
14Kova Crypto Services LLCKovaLimited Liability CompanyWyomingTyler Richardson, CEO152 N. 3rd Street, Suite 200, Cheyenne, WY 820012024Crypto-to-fiat on/off ramp and custody account services180001960000000.3%N/AQ1 2025

[sheet: Summary Dashboard]

Partner #Partner Short NameOnboarding Year% of BaaS Volume (%)Annual Transaction Volume — $End-User AccountsTransaction Type & ComplexityTransaction Volume ($)Transaction CountCustomer BaseGeographic ExposureOFAC Sanctions RiskHistorical SAR ActivityCDD/EDD ComplianceWeighted Average ScoreOverall Risk Rating TierEDD RequiredTrend vs. Prior QuarterKey Action Items
1NovaPay202141.0%305000000002100000555435554.7HighYesN/A — BaselineRemediate OFAC screening gap; complete CDD/EDD for NovaPay-onboarded high-risk accounts; implement enhanced transaction monitoring
2FairLend202228.0%20804000000N/A353423443.6Moderate-HighYesN/A — BaselineComplete CDD/EDD for FairLend-onboarded accounts; review lending origination BSA controls; enhance beneficial ownership verification
3VaultEdge202318.0%13374000000870000343323343.2ModerateNoN/A — BaselineComplete CDD/EDD for VaultEdge-onboarded accounts; continue monitoring SAR trends
4SwiftCard20213.8%2800000000320000N/A — BaselineComplete baseline assessment by March 31, 2025
5Greenline20222.6%190000000045000N/A — BaselineComplete baseline assessment by March 31, 2025
6Beacon20232.0%1500000000195000N/A — BaselineComplete baseline assessment by March 31, 2025
7TrueNorth20231.6%1200000000N/AN/A — BaselineComplete baseline assessment by March 31, 2025
8Pivo20241.1%800000000110000N/A — BaselineComplete baseline assessment by March 31, 2025
9Crestline20220.9%650000000280000N/A — BaselineComplete baseline assessment by March 31, 2025
10Apex Payroll20230.7%52000000038000N/A — BaselineComplete baseline assessment by March 31, 2025
11HarborPoint20240.5%38000000022000N/A — BaselineComplete baseline assessment by March 31, 2025
12Bridgeway20240.3%250000000N/AN/A — BaselineComplete baseline assessment by March 31, 2025
13QuickSettle20230.3%23000000015000N/A — BaselineComplete baseline assessment by March 31, 2025
14Kova20240.3%19600000018000N/A — BaselineComplete baseline assessment by March 31, 2025; note elevated inherent risk due to crypto-to-fiat activity
TOTALS / AVGAll 14 Partners100.0%74304000000High: 1Mod-High: 1Moderate: 1Pending: 11EDD Required: 2 of 14 assessedComplete all 14 baseline assessments by March 31, 2025; prioritize top 3 partners by volume

[sheet: Historical Tracker]

Partner #Partner Short NameQ1 2025 — Weighted ScoreQ1 2025 — Rating TierQ2 2025 — Weighted ScoreQ2 2025 — Rating TierQ3 2025 — Weighted ScoreQ3 2025 — Rating TierQ4 2025 — Weighted ScoreQ4 2025 — Rating TierQ1 2026 — Weighted ScoreQ1 2026 — Rating TierTrend (Improving / Stable / Deteriorating)Notes
1NovaPayBaseline assessment to be completed by March 31, 2025. Highest priority due to 41% of BaaS volume and OFAC screening gap.
2FairLendBaseline assessment to be completed by March 31, 2025. Second priority due to 28% of BaaS volume and lending risk.
3VaultEdgeBaseline assessment to be completed by March 31, 2025. Third priority due to 18% of BaaS volume.
4SwiftCardBaseline assessment to be completed by March 31, 2025.
5GreenlineBaseline assessment to be completed by March 31, 2025.
6BeaconBaseline assessment to be completed by March 31, 2025.
7TrueNorthBaseline assessment to be completed by March 31, 2025.
8PivoBaseline assessment to be completed by March 31, 2025. New partner onboarded 2024.
9CrestlineBaseline assessment to be completed by March 31, 2025.
10Apex PayrollBaseline assessment to be completed by March 31, 2025.
11HarborPointBaseline assessment to be completed by March 31, 2025. New partner onboarded 2024; wealth management risk considerations.
12BridgewayBaseline assessment to be completed by March 31, 2025. New partner onboarded 2024.
13QuickSettleBaseline assessment to be completed by March 31, 2025. B2B payments may carry elevated risk.
14KovaBaseline assessment to be completed by March 31, 2025. New partner onboarded 2024; crypto-to-fiat inherently high-risk; close monitoring required.

[sheet: Reference Data]

Data ElementValueSource / Notes
Total Active BaaS Partners14As of January 2025
Total BaaS Transaction Volume (CY 2024)$74,300,000,000All 14 partners
BaaS Revenue to BRB (CY 2024)$127,400,000Interchange, program fees, interest income
NovaPay — % of BaaS Volume41%$30.5B of $74.3B
FairLend Digital — % of BaaS Volume28%$20.8B of $74.3B
VaultEdge — % of BaaS Volume18%$13.4B of $74.3B
Remaining 11 Partners — % of BaaS Volume13%Collectively; $9.6B of $74.3B
NovaPay — End-User Accounts2,100,000Onboarded 2021
FairLend Digital — FY 2024 Loan Originations via BRB$1,400,000,000Onboarded 2022
VaultEdge — Deposit Accounts870,000Onboarded 2023
NovaPay Unscreened Transactions (CY 2023)3,800,00012.0% of 31.7M total NovaPay transactions; OFAC screening gap
Total SARs Filed (CY 2024)3,847All BRB SARs
BaaS-Related SARs (CY 2024)2,10854.8% of total SARs (2,108 / 3,847)
Total SARs Filed (CY 2023)2,914Year-over-year increase of 32.0% (CY 2023 to CY 2024)
CTRs Filed (CY 2024)28,612All BRB CTRs
OFAC Screening Hits (CY 2024)14,32012 true matches; 99.9% false-positive rate
Transaction Monitoring Alerts (CY 2024)41,500SAR conversion rate: 9.3% (3,847 / 41,500)
SAR Backlog (as of Sept 2024)2,400 alertsUnreviewed at time of OCC examination
Average SAR Filing Time78 daysRegulatory expectation: ≤30 days
High-Risk Accounts Lacking CDD/EDD47,000Primarily fintech-onboarded
CDD/EDD 50% Remediation Milestone23,500 accounts by July 15, 2025Consent Order requirement
CDD/EDD 100% Remediation Milestone47,000 accounts by January 15, 2026Consent Order requirement
OFAC Screening Full Operational DateNovember 1, 2025All BaaS channels
Veridian TMS Current Versionv.8.3Last validated March 2021; last tuned October 2022
Veridian TMS Upgrade Versionv.10.0UAT target: August 1, 2025
BSA/AML Department Headcount (Jan 2025)62 FTEsPre-remediation
Planned Post-Remediation Headcount77 FTEs62 + 15 new hires
Pinnacle Temporary Staff30 FTEs12-month remediation staffing
Consent Order No.OCC-2025-003Effective January 15, 2025
OCC Examiner-in-ChargeJonathan Frey, National Bank ExaminerOCC Northeastern District Office, 340 Madison Avenue, New York, NY 10017
FinCEN LiaisonAngela Drummond, Associate Director, Enforcement DivisionMonitoring SAR filing remediation
BRB Total Assets (Q4 2024)$38,700,000,000As of December 31, 2024
BRB Total Deposits (Q4 2024)$29,400,000,000As of December 31, 2024
BRB Tier 1 Capital Ratio11.2%As of December 31, 2024
BRB BSA/AML Budget (FY 2024)$18,200,000Pre-remediation
Total Remediation Budget (excl. CMP)$42,500,000Board-approved
Civil Money Penalty$14,500,000Due March 16, 2025
Self-Certification DeadlineFebruary 15, 2026Consent Order compliance