Banking-as-a-Service integration — build on the right partner for the programme.

A provider gives you the licence, the rails (accounts, payments, sometimes cards) and an API. What they deliberately don’t give you is the programme-management layer: onboarding orchestration, account lifecycle, limits and fees, customer servicing, real-time reconciliation, and the customer-funds-location records a regulator expects. That gap — provider sandbox to production programme — is the work. Most firms underestimate it by a factor of two or three.

It’s a canonical, event-sourced record where every customer pound or dollar has exactly one location at any moment — partner account, sub-ledger, FBO designation, settlement-in-flight. State changes are timestamped events, so you can reconstruct “where was customer X’s money on date Y.” It matters now because the CFPB has started enforcing against firms that “failed to maintain adequate records of the location of consumers’ funds” — the failure mode at the heart of the 2024 BaaS collapses. If you can’t answer the question in real time, it’s your top remediation priority.

Yes — and for any programme at scale we recommend planning for it from day one. The pattern is a provider-abstraction layer: thin per-provider adapters beneath a canonical programme model, so the product reads the canonical model and a commercial change or outage at one provider is an adapter swap, not a rebuild. You don’t have to launch on two — but the cost of designing for two and using one is small, and the cost of retrofitting multi-provider later is large.

Yes. Modulr (FCA EMI, direct Faster Payments / Bacs / SEPA participant) is a common choice for accounts and payments; Moorwand (FCA EMI, BIN sponsorship and card issuing) is a common choice for card programmes. We’re provider-pragmatic — we’ll build on whichever partner fits the programme’s licence model, scheme access, geography and economics, and we’ll tell you honestly where a provider’s operational layer is thin enough that you’ll need to engineer around it.

The e-money your BaaS partner holds on your customers’ behalf is safeguarded, and from 7 May 2026 the FCA’s enhanced regime expects continuous, evidenced segregation rather than periodic attestation. Even though your partner holds the funds, you sit in the operational chain that determines where they are — so your programme needs reconciliation and evidence that support the partner’s safeguarding obligations and your own customer-funds-location records.