SOC 2 for fintech, bank-grade.
Fintech audits demand more than a Security-only report. Skadi scopes and delivers SOC 2 Type II with Processing Integrity, Confidentiality, and Availability — the criteria your sponsor bank and enterprise clients actually require. Every engagement is led by a senior CPA who has worked with ledger, payments, and lending platforms and knows where money movement risk actually lives.
Audit challenges we solve for you.
Partner banks run their own vendor reviews and expect SOC 2 evidence that matches their control matrix. A generic Security-only report reads as under-scoped and delays or blocks program approval.
Every code path that touches a ledger, transfer, or payout is high-risk. Controls must prove authorization, segregation of duties, completeness of processing, and end-to-end traceability from initiation to settlement.
SOC 2 sits alongside PCI DSS, state money-transmitter licenses, NYDFS Part 500, and future SOX obligations. Scoping must anticipate the full stack without duplicating evidence collection.
Daily recs are the fintech control — auditors, banks, and regulators all read them. Missing breaks, late resolution, or manual overrides without approval are the most common findings we see in fintech transitions.
Controls that matter most for your business.
Completeness, validity, accuracy, timeliness, and authorization on every transaction path. Tested with end-to-end walkthroughs and detailed sampling — not accepted on a control-owner assertion.
Engineers cannot unilaterally push money-moving code. Author ≠ approver ≠ deployer, enforced in the pipeline, evidenced from GitHub and deploy tooling with cross-referenced sampling.
Daily reconciliations against bank and processor statements, documented break investigation, aging thresholds, and evidence discrepancies are resolved within a stated SLA.
Access controls on customer PII and identity documents, monitoring on identity vendor calls, and evidence that flagged accounts follow the documented playbook (hold, SAR filing, closure).
KMS/HSM usage for keys protecting financial data, dual-control rotation cadence, and separation of key custodians from data owners. Bank reviewers ask about this by name.
Elevated approval requirements — including a second reviewer with financial-operations context — for any change to services that authorize or move funds. Evidenced end-to-end and sampled at higher rates than normal changes.
Annual review of every sub-service organization's SOC report, tracking of complementary user entity controls, and evidence you actually operate the CUECs they list.
Rules coverage, alert triage SLAs, and evidence of investigation-to-resolution — increasingly asked for by both bank partners and regulated end customers.
What actually fails in this vertical.
Real deviations we see in SOC 2 Type II fieldwork — and what your platform and security teams should fix before the observation window starts.
Recon runs but no signed artifact showing breaks investigated and resolved. Processing Integrity (PI1) exception writes itself if the recon output is not retained.
- Daily recon report archive with sign-off per business day
- Break-investigation ticket log with root cause + resolution
- Recon runbook and control-owner assignment
- Screenshot of variance thresholds and alerting rules
Production DB access allows direct writes to the ledger. Segregate duties technically — engineers cannot approve their own transactions, ever.
- Production DB access matrix showing no write on ledger tables
- Change-management ticket for any break-glass DB write
- SoD policy naming approver ≠ initiator
- Approval-workflow config in the treasury/ops tool
BaaS/sponsor bank contract obligations (BSA/AML monitoring, reporting cadence) live only in a legal folder. Map to controls with owners and cadence.
- Obligation register mapping each clause to a control + owner
- Monthly/quarterly report archive sent to the sponsor bank
- AML/BSA transaction-monitoring rule set and tuning log
- Meeting minutes from sponsor-bank oversight cadence
PAN accidentally logged in application logs. Tokenize at ingress and prove non-CDE systems never see raw PAN — attestations from the auditor rely on it.
- Tokenization architecture diagram + vendor attestation
- Log-scrubbing rules for PAN + sample logs from the window
- Data-flow diagram of the CDE
- SAQ / AoC and quarterly ASV scan reports
Vendor returns decisions but you keep only the pass/fail — auditors need the underlying evidence set for a sample of decisions during the window.
- Sample KYC case files (ID doc, liveness, watchlist hit) for the window
- Retention policy referencing regulatory requirements
- Vendor contract + latest SOC 2 report
- Escalation runbook for edge-case decisions
Deploys during settlement windows caused reconciliation gaps. Change management must consider financial timing, not just uptime.
- Deploy-freeze calendar overlaid on settlement windows
- Release policy referencing freeze rules
- Change-management ticket showing timing review sign-off
- Post-deploy recon report for a sampled release
Why fintech SOC 2 is different
A generic SaaS can pass SOC 2 with Security only. A fintech usually cannot. Sponsor banks, card networks, and enterprise clients want proof that your ledger is complete and accurate (PI1), that customer financial data is protected (C1), and that your platform stays available under load (A1). Getting the scope right on day one saves a re-audit and — more importantly — the trust of your bank partner.
Bank sponsor readiness
Sponsor banks conduct their own vendor reviews and increasingly ask for SOC 2 reports as a baseline. We have seen fintechs delayed by 3–6 months because their initial report did not include Processing Integrity or did not reflect their actual money-movement architecture. Skadi scopes correctly on day one, and drafts your system description in a way that maps cleanly to the OCC-style questionnaires banks actually send.
Segregation of duties done properly
In fintech, SoD is not a policy statement — it is a technical control. Author, reviewer, and deployer must be distinct principals in the pipeline; ledger reads and writes must be separated from application engineers; and any manual override must generate an auditable ticket with independent approval. We test this by pulling live samples from your VCS, deploy system, and ledger — not by reading a policy PDF.
Pre-IPO and SOX-adjacent programs
For fintechs on an IPO track, SOC 2 controls become the foundation of future SOX 404 ITGCs. We design your program so the same evidence (change management, logical access, backups, monitoring) can be reused for SOX with minimal duplication — a significant cost saving in a future S-1 audit and less noise for your finance team when the external auditor arrives.
Questions we hear from teams like yours.
Ready to scope your SOC 2 Type II?
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