Eric Kruglak | AVP, Strategic Partnerships
Bill Turley | VP, Regulatory Compliance
Continental Bank is a privately owned FDIC insured bank founded in 2003 and headquartered in Salt Lake City, Utah. Through their national strategic partnership platforms, the bank issues consumer and small business credit, payment and deposit products through retailers, manufacturers, finance companies, software as a service (SaaS) providers and fintechs. The bank helps its strategic partners drive financial innovation and inclusion by embedding digital financing and banking products. It also provides revolving, asset-based lending facilities to its strategic partners, and a full suite of banking products and services to SMBs nationwide.
Continental Bank’s investment to scale their fintech partnerships required a more comprehensive, purpose-built tool to manage the entire partner relationship from due diligence, to ongoing compliance oversight to reporting approvals in a rapidly changing ecosystem. Faced with complexities in their internal non-fintech vendor programs, they sought an end-to-end governance, compliance, risk, document management, and task management solution to enhance fintech partner engagement, collaboration and communication.
Prior to leveraging Themis, Continental was not using any software–compliance or otherwise–to operate their strategic lending partnerships.
All communication with their fintech prospects was initially handled through email, Excel, and complicated shared-drive document storage. This created inefficiencies and logistical challenges in partner engagement such as: extensive time spent on calls to review documentation needs, where to put them, and how to redline and provide them, rather than discussing the partner growth opportunities and the onboarding process itself.
In addition, they knew that marketing approvals needed to be efficiently managed for each of their partners. Approving marketing material through email chains with different redlines and versioning histories would be cumbersome and create significant overhead during an audit or exam process.
Outside of the fintech partnerships, Continental also needed to manage their internal vendor program, complaint management and their policies and procedures. Excel sheets and shared drives were the primary tools to organize all of their vendor details, questionnaires, risk assessments, policies and procedures. This created a fragmented, disarray of unconnected documents that were often out of date, or inaccurate.
Continental decided to look for a compliance platform to simplify, enhance their processes and accelerate partnerships. They selected Themis for 3 primary reasons:
An integral component of onboarding new partners is the collection, review, and approval of Policies, Procedures and other Documents by the bank. Previously, Continental had a spreadsheet of around 300 items where this was stored and organized. Themis’ Policies, Procedures, and Documents modules provide a clean and organized location for these documents. These modules clearly outline document owners, due dates, comments and approval stage. Leveraging Themis eliminates the confusion around next steps during onboarding and provides a singular hub for both fintechs and the bank to interact.They went from different locations to share and store their (and their fintech partners’) documents, policies and procedures to one single platform that hosts it all in a collaborative, real-time environment.
To manage their marketing program, Continental uses the Marketing module for both their partner relationships, and their internal marketing teams.
Since launching Themis the Continental team has reviewed over 130 individual marketing records. By leveraging the Marketing module, Continental has permanent access to each record's comment history, approval information, and audit trail, all easily shared through a simple pdf export that can be provided to auditors at a moment’s notice. Themis has built-in Figma and Google integrations across the entire platform, allowing the bank and its fintech partners to easily review, edit and approve of materials in real-time inside the native software environments in which they’re created. Once finalized, the Bank publishes the final version in Themis with a single click.
Continental has over 100 direct vendors across the entire organization (with many more fourth-party vendors it must manage through its strategic partners), and keeping these updated and organized was a challenge. By leveraging Themis’ Vendor Due Diligence (VDD) model, that is a problem of the past. Continental now stores all vendor information in a single location; including contracts, risk assessments, and all supplemental documentation. Leveraging VDD allows Continental to have a clear and accurate understanding of which vendors are critical or higher risk, which vendors require a periodic review to be performed by a certain time, and if their vendors have access to any PII.
By leveraging Themis, the Continental team has accomplished three primary goals:
1) they are better prepared for more efficient audits and regulatory exams than ever before;
2) they can onboard new partners faster and with less pain; and
3) they efficiently manage changes to ongoing partnerships more smoothly.
Most importantly, they’ve done this without adding any additional resources to the team and have opened up time to focus on other tasks.
Continental recently launched two new fintech partners, with a third currently in enhanced due diligence and several more in the pipeline. Launching new partners at this scale had required significant personnel resources. Now with Themis, their lean team can handle policy and document collection, review, and approve/deny approval in both a timely and efficient manner.
With the technology and processes that Themis provides, Continental estimates that they and their strategic partners have saved between 25%-30% of the time they previously took to review, approve, send and document everything in due diligence. That doesn’t include time savings on time spent performing post-launch testing, monitoring & reviews, and ongoing program & document management.
Keep your team aligned by drafting, finalizing and collaborating on important documents (e.g. annual plans) in a centralized repository.
Manage your company and partners’ procedures with live collaboration, version history, and attestation capabilities to simplify your processes.
Store important documents such as legal agreements, pricing sheets and terms and conditions so all stakeholders have access to the latest versions.
Collaborate on sales material between departments and provide real-time comments with an easy to use interface.