Training That Actually Works: Why Banks and Credit Unions Need to Hold Fintechs and MSBs to a Higher Standard

Let’s be honest, the concept of training might not be what gets a fintech or MSB team excited. But if you’re a bank or credit union partnering with one, you need to think of your partner’s training not as fluff, but as a frontline control. The quality of your partner’s training program is one of the clearest indicators of whether a fintech or MSB takes compliance seriously, and whether they’ll cause you risk down the line.

This isn’t just about them checking a box. It’s about you, as the financial institution,

being able to demonstrate to regulators and examiners that you’ve vetted your partners, that you’re overseeing them effectively, including the quality of their training program, and that you’re not outsourcing your compliance responsibilities.

You Can’t Outsource Responsibility

We see it all the time: a fintech is onboarded, the due diligence looks fine, and everyone moves on. But then months later, the partner launches a new product, hires new staff, or tweaks a policy, and no one asks whether the team been retrained. Do they understand the regulatory implications? What if a new hire in marketing doesn’t realize certain claims trigger UDAAP scrutiny?

From a third-party risk management perspective, banks and credit unions need to go beyond onboarding checklists. Ongoing oversight means regularly checking that your partners:

• Conduct training at onboarding and at regular intervals

• Update training materials when laws or products change

• Tailor training to actual risks — not just generic slide decks

• Can explain compliance expectations in plain English

If your fintech partner can’t answer these questions, examiners will likely ask you why.

Training Helps Prevent (Avoidable) Risk

Most issues that land a fintech or MSB — and by extension, their bank partner — in hot water stem from basic errors that proper training could’ve prevented. Like:

• A product manager skipping compliance review on a feature rollout

• A customer support agent misapplying Reg E refund timelines

• Someone handling customer data without understanding privacy protocols

These aren’t just internal mistakes — they can lead to enforcement actions, reputational damage, and strained relationships with your regulators. By holding your partners accountable for training, you're protecting your institution.

Examiners Are Watching

In today’s regulatory environment, banking regulators are zeroing in on how financial institutions manage their third-party relationships. They’re asking how you ensure partners aren’t creating compliance gaps, and training is one of the easiest ways to show you’re doing your job.

Make sure your partners document their training programs. Ask for evidence. Review the content. Confirm they’re not using the same recycled deck from 2021. Training should evolve with the risks, and you should be able to evidence how it is doing so.

Training Isn’t a Burden, it’s a Signal

When your fintech or MSB partner invests in practical, relevant training, it signals

maturity. It tells you they understand their obligations and are building a compliance culture, not just a compliance checklist.

And for banks and credit unions, that kind of partner is gold. It reduces your risk, builds regulator confidence, and makes your oversight easier.

Training might not be exciting, but it works. It’s one of the clearest signs that a fintech is serious about doing things right from a compliance perspective.

Training isn’t fluff. It’s your quiet advantage. Make it count.

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This blog was written and provided by Justin Muscolino, CEO & Co-Founder of highriskeducation.com. High Risk Education (HRE) delivers expert-led training for professionals working in high-risk environments — from legal and compliance to fintech, banking, and MSBs. Their courses focus on fast-moving topics like AI, crypto, fraud, sanctions, and consumer protection — areas under increasing scrutiny from regulators and enforcement agencies.