What Enterprise Banks Expect from Your Fintech SOC 2 Report

At Agency, we've guided dozens of fintech companies through the bank vendor evaluation process. One of the most common surprises our clients face is just how differently enterprise banks evaluate SOC 2 reports compared to typical enterprise buyers. Here's what we've learned — and what you need to know before your report lands on a bank TPRM team's desk.

Enterprise banks evaluate fintech SOC 2 reports differently than other enterprise buyers. Bank risk and compliance teams are trained auditors — they read the entire SOC 2 report, not just the auditor's opinion. They scrutinize the system description for architectural completeness, evaluate every exception for downstream risk, verify that the Trust Service Criteria scope covers their specific regulatory concerns, and request supplementary documentation that extends far beyond what the SOC 2 report alone provides. A SOC 2 report that satisfies a typical enterprise SaaS buyer may fall short of what a bank's third-party risk management (TPRM) team requires.

This guide explains exactly what enterprise banks, credit unions, and financial institutions look for when reviewing a fintech vendor's SOC 2 report, including which report sections receive the most scrutiny, which Trust Service Criteria banks consider mandatory, how bank examiners evaluate third-party risk, and what supplementary documentation banks request alongside the SOC 2 report. The target audience is fintech companies preparing their SOC 2 report for bank partnerships, banking-as-a-service integrations, or core banking vendor assessments.

Why Banks Review SOC 2 Reports Differently

Regulatory Pressure

Banks operate under regulatory frameworks that require formal third-party risk management programs. The OCC (Office of the Comptroller of the Currency), Federal Reserve, FDIC, and NCUA all publish guidance requiring financial institutions to evaluate and monitor the risks posed by third-party service providers. When a bank partners with a fintech company, the bank's regulators expect documented evidence that the bank has evaluated the fintech's control environment — and your SOC 2 report is the primary artifact they review.

This regulatory context means your SOC 2 report is not just evaluated by the bank's procurement team — it may be reviewed by bank examiners during regulatory examinations. A weak SOC 2 report does not just risk losing a bank partnership; it creates regulatory risk for the bank itself.

Professional Review Capability

Bank TPRM teams typically include professionals with audit, risk management, and compliance certifications (CISA, CRISC, CISM, CPA). They read SOC 2 reports with the same analytical rigor that auditors apply. They know what a well-designed control environment looks like, they understand the significance of different exception types, and they can identify gaps in system descriptions that less sophisticated buyers overlook.

Downstream Accountability

Banks are accountable to their regulators for the actions of their third-party vendors. If a fintech vendor experiences a security incident that affects bank customers, the bank faces regulatory consequences — even though the incident occurred at the vendor. This downstream accountability makes banks more conservative in their vendor evaluation and more demanding in their SOC 2 report requirements.

What Banks Evaluate in Your SOC 2 Report

The Auditor's Opinion

Opinion Type	Bank Response
Unqualified (clean)	Proceeds to detailed report review
Qualified	Evaluates each exception for materiality and downstream risk; may accept with conditions or reject
Adverse	Rejects the vendor; an adverse opinion is a disqualifier for bank partnerships
Disclaimer	Rejects the vendor; insufficient assurance for regulatory compliance

An unqualified opinion is necessary but not sufficient for bank acceptance. Banks treat the clean opinion as a baseline requirement and then conduct their own detailed review of the report contents.

The System Description

Banks review the system description more carefully than any other report section. They look for:

System Description Element	What Banks Want to See
Service architecture	Clear documentation of system components, data flows, network architecture, and integration points with bank systems
Data handling	How customer (bank) data is received, processed, stored, transmitted, and disposed of
Encryption specifications	Specific encryption algorithms and key lengths for data at rest and in transit (not just "data is encrypted")
Multi-tenancy architecture	How tenant isolation is implemented if the fintech serves multiple bank clients
Subservice organizations	Which third parties the fintech relies on and how they are addressed in the report (inclusive vs carve-out)
Geographic data location	Where data is physically stored and processed — critical for banks with data residency requirements
Personnel and access	How the fintech organization manages access to bank data, including privileged access controls

A system description that lacks architectural detail, uses vague language about security controls, or omits key system components will raise immediate flags with bank reviewers.

Trust Service Criteria and Controls

Banks expect specific Trust Service Criteria based on the nature of the fintech service:

TSC	Bank Expectation	Why Banks Require It
Security (Common Criteria)	Mandatory	Required for all SOC 2 engagements; non-negotiable
Availability	Required for all operational services	Bank operations depend on fintech service uptime; downtime affects bank customers directly
Processing Integrity	Required for transaction and data processing services	Financial data processing must be accurate, complete, and timely; errors create regulatory and financial risk
Confidentiality	Required for services handling bank or customer data	Bank customer data confidentiality is a regulatory requirement; fintech must demonstrate controls
Privacy	Required if fintech handles consumer personal data	Privacy regulations (GLBA, state privacy laws) require banks to ensure vendor privacy controls

In our experience, most bank TPRM teams expect at minimum Security, Availability, and Processing Integrity. Omitting Availability or Processing Integrity from a fintech SOC 2 report is one of the most common reasons banks request additional documentation or delay vendor approvals.

Exceptions and Observations

Banks evaluate every exception in the report against their own risk tolerance:

Exception Type	Bank Response
Access management exceptions (unauthorized access, deprovisioning delays)	High concern — access control failures at a fintech create direct data exposure risk for bank customers
Change management exceptions (unapproved deployments, missing code reviews)	Moderate-high concern — uncontrolled changes to systems processing bank data represent operational risk
Monitoring exceptions (logging gaps, alert failures)	Moderate concern — monitoring gaps reduce the fintech's ability to detect and respond to incidents
Policy exceptions (incomplete training, unsigned policies)	Lower concern but still noted — indicates organizational control maturity gaps
Availability exceptions (SLA breaches, incident response delays)	High concern — availability failures directly affect bank customer experience

Banks do not simply count exceptions. They evaluate each exception for:

1. Root cause: Was this a one-time failure or a systemic control weakness?
2. Remediation: Has the fintech implemented corrective action? Is the remediation documented?
3. Impact scope: Could this exception have affected bank data or bank customer services?
4. Recurrence risk: Is this exception likely to appear in the next audit cycle?

Observation Period and Report Currency

Report Attribute	Bank Requirement
Report type	Type II strongly preferred; Type I may be accepted for initial evaluation only
Observation period	Minimum six months; twelve months preferred and often required for ongoing partnerships
Report age	Less than twelve months; many banks require reports covering the most recent fiscal quarter
Gap between report periods	No gaps — each report period must begin immediately after the prior period ends

Banks are particularly strict about report currency. A SOC 2 report that expired three months ago — even if a new audit is in progress — creates a compliance gap that the bank must document and justify to regulators. We recommend maintaining a continuous audit cycle with no gaps between observation periods.

Supplementary Documentation Banks Request

Your SOC 2 report alone is rarely sufficient for bank vendor evaluation. Banks typically request the following additional documentation:

Standard Supplementary Requests

Document	What Banks Want	Typical Format
Penetration test report	Most recent external penetration test results, including findings and remediation status	Full report from qualified penetration testing firm
Business continuity plan (BCP)	Documented BCP including recovery procedures for critical systems	Policy document with specific recovery procedures
Disaster recovery (DR) test results	Evidence that DR procedures have been tested — not just documented, but actually executed	DR test report with results, timing data, and lessons learned
Incident response plan	Documented incident response procedures with escalation paths and communication templates	Policy document including bank-specific notification procedures
Insurance certificates	Cyber liability insurance, errors and omissions, and general liability coverage amounts	Certificate of insurance from carrier
Vendor management program	How the fintech manages its own third-party vendors	Vendor risk management policy and critical vendor assessment results
Security awareness training records	Evidence that all employees completed security awareness training	Training completion reports with dates and pass rates
Data flow diagrams	Visual representation of how bank data moves through the fintech's systems	Network and data flow diagrams with encryption points identified
Encryption key management	How encryption keys are generated, stored, rotated, and retired	Key management procedures and evidence of key rotation
Regulatory compliance attestations	Evidence of compliance with applicable regulations (PCI DSS, GLBA, state regulations)	Compliance reports, audit results, or self-assessments

Bank-Specific Questionnaires

Beyond the SOC 2 report and supplementary documentation, banks typically require completion of their proprietary vendor risk assessment questionnaire. These questionnaires often include two hundred to five hundred questions covering:

• Information security policies and procedures
• Data handling and privacy practices
• Business continuity and disaster recovery
• Incident response and notification commitments
• Financial stability and insurance coverage
• Regulatory compliance status
• Subcontractor and fourth-party risk management
• Physical security (if applicable)

Many of these questions overlap with SOC 2 content, and an organized SOC 2 program makes questionnaire completion significantly faster. We recommend referencing specific controls, policies, and report sections in your questionnaire responses to demonstrate alignment between your answers and your audited control environment.

How to Build a Bank-Ready SOC 2 Report

System Description Best Practices

• Be specific about architecture: Include component-level detail, not just general statements. Name your cloud provider, region, and services used. Describe network architecture including segmentation, load balancing, and traffic routing.
• Document data flows completely: Trace data from bank system ingestion through processing, storage, and transmission. Include encryption status at every stage.
• Address multi-tenancy explicitly: If you serve multiple bank clients, describe how tenant isolation is implemented at the infrastructure, application, and data layers.
• List all subservice organizations: Identify every third-party vendor that interacts with bank data and explain how they are addressed in the report (carve-out or inclusive method).
• Include geographic details: Specify where data is stored and processed. Banks with data residency requirements need this information for their compliance programs.

Control Implementation Priorities

Priority	Control Area	Why Banks Care
1	Access management — privileged access, access reviews, deprovisioning	Unauthorized access to bank data is the highest-risk scenario
2	Encryption — at rest, in transit, key management	Bank data must be encrypted at all stages; regulators verify this through vendor reports
3	Monitoring and logging — SIEM, alerting, log retention	Detection capability is critical; banks need confidence that incidents will be identified quickly
4	Incident response — plan, testing, bank notification	Banks must be notified of incidents affecting their data within specific contractual timeframes
5	Change management — code review, approval, testing	Uncontrolled changes to systems processing bank data represent operational risk
6	Availability — SLA, redundancy, failover, DR testing	Bank operations depend on fintech service availability
7	Vendor management — critical vendor assessment, monitoring	Banks evaluate the entire supply chain; your vendor management affects their risk posture

Auditor Selection for Bank Partnerships

Bank TPRM teams evaluate the credibility of your CPA firm. Factors that influence bank confidence:

• Firm reputation and size: Reports from established, recognized CPA firms carry more weight with bank risk teams
• Financial services experience: Auditors with financial services industry experience understand bank-specific requirements and produce reports that address bank concerns
• AICPA SOC 2 specialization: Firms that specialize in SOC 2 attestation (Schellman, A-LIGN, KirkpatrickPrice) are recognized by bank TPRM teams
• Consistent quality: Banks that review multiple vendor SOC 2 reports recognize quality differences between auditor firms

Common Reasons Banks Reject or Delay Fintech SOC 2 Reports

Rejection Reason	How to Avoid It
Missing Availability or Processing Integrity criteria	Include Security, Availability, and Processing Integrity from your first Type II engagement
Significant access management exceptions	Implement quarterly access reviews, enforce MFA for all users, automate deprovisioning
Report expired or gap between periods	Maintain continuous annual audit cycle; begin next observation period immediately after prior period ends
Vague system description	Provide component-level architecture detail, specific encryption standards, complete data flow documentation
No penetration testing evidence	Conduct annual penetration testing from a qualified third-party firm
No DR testing evidence	Conduct and document disaster recovery testing at least annually
Type I report only	Type I is acceptable for initial evaluation; transition to Type II immediately
Unrecognized auditor	Select an established CPA firm with SOC 2 attestation specialization and financial services industry experience
Incomplete CUECs	Document specific Complementary User Entity Controls so the bank knows what they need to implement on their side

Bank Evaluation Timeline

Typical Vendor Onboarding Timeline for Bank Partnerships

Phase	Duration	What Happens
Initial request	Week 1	Bank requests SOC 2 report, questionnaire, and supplementary documents
Document review	Weeks 2-4	Bank TPRM team reviews all submitted documentation
Clarification questions	Weeks 3-5	Bank asks follow-up questions about report findings, system architecture, or controls
Risk rating	Weeks 5-7	Bank assigns a vendor risk rating (critical, high, medium, low) based on review
Approval decision	Weeks 6-8	Bank risk committee approves, conditionally approves, or rejects the vendor
Ongoing monitoring	Continuous	Bank requests updated SOC 2 report annually; may request interim attestation for high-risk vendors

The total vendor onboarding timeline for bank partnerships is typically six to twelve weeks — significantly longer than standard enterprise procurement. Having a comprehensive, current SOC 2 report with supporting documentation ready before the process begins can reduce this timeline by two to four weeks.

Key Takeaways

• We consistently see bank TPRM teams read the entire SOC 2 report — system description, controls, and every exception — with professional audit expertise
• What we recommend: include Security, Availability, and Processing Integrity at minimum. Omitting Availability or Processing Integrity is one of the most common rejection reasons we encounter
• In our experience, Type II reports with twelve-month observation periods are strongly preferred; Type I is only accepted for initial evaluation
• We advise clients to ensure the system description includes specific architecture details, data flows, encryption specifications, and multi-tenancy isolation — vague descriptions trigger additional scrutiny
• What we see most often flagged: access management exceptions are the highest-concern finding for banks because unauthorized access creates direct data exposure risk
• We recommend preparing supplementary documentation beyond the SOC 2 report well in advance: penetration test results, BCP/DR testing evidence, incident response plans, insurance certificates, and proprietary risk questionnaires
• What we tell every client: maintain a continuous audit cycle with no gaps between observation periods — expired reports create regulatory risk for bank partners
• We consistently advise that auditor selection matters: established CPA firms with financial services experience produce reports that bank risk teams trust
• Based on what we see, bank vendor evaluation takes six to twelve weeks; having comprehensive documentation ready before the process begins shortens the timeline

Frequently Asked Questions

Will a SOC 2 report alone satisfy bank vendor requirements?

What we tell clients is: no. A SOC 2 report is the foundation, but banks require supplementary documentation including penetration test results, business continuity and disaster recovery plans with testing evidence, incident response plans, insurance certificates, and completion of their proprietary vendor risk assessment questionnaire. Based on what we see, the SOC 2 report provides the core security assurance, while the supplementary documentation addresses specific regulatory and operational requirements that the SOC 2 framework does not fully cover.

Do banks accept Type I reports?

Based on what we see, banks may accept a Type I report for initial vendor evaluation — typically accompanied by a documented timeline for when the Type II report will be available. However, Type I is not accepted as a permanent solution. What we tell clients is: bank TPRM programs require ongoing vendor monitoring with current Type II reports. If you are pursuing a bank partnership, we recommend planning to have your Type II report available within twelve months of the initial engagement.

How do bank requirements differ from standard enterprise SOC 2 expectations?

What we tell clients is: the primary differences are (1) banks require broader Trust Service Criteria — Availability and Processing Integrity are effectively mandatory, not optional; (2) banks evaluate exceptions at a deeper level, assessing root cause, remediation, and recurrence risk; (3) banks request extensive supplementary documentation beyond the SOC 2 report; (4) banks expect the system description to include specific architectural detail and data flow documentation; (5) bank evaluation timelines are longer (six to twelve weeks) due to formal risk committee approval processes.

What happens if our SOC 2 report has exceptions?

Based on what we see, exceptions do not automatically disqualify your report, but each exception is evaluated for materiality and downstream risk. Access management exceptions (unauthorized access, deprovisioning delays) are the most concerning for banks. What we tell clients is: if your report contains exceptions, prepare to explain what caused the exception, what remediation you have implemented, and what evidence demonstrates the issue has been resolved. Banks may accept a report with minor exceptions accompanied by documented remediation — but significant access management or processing integrity exceptions are likely to require additional review or delay approval.

How far in advance should we prepare for bank SOC 2 evaluation?

What we recommend is starting twelve to eighteen months before you expect to begin bank partnership discussions. This timeline allows you to: (1) complete a gap analysis and remediation (two to four months), (2) achieve Type I if you do not already have a SOC 2 report (three to five months), (3) complete a Type II observation period (six to twelve months), and (4) prepare supplementary documentation (concurrent with audit preparation). In our experience, approaching a bank without a current Type II report and supporting documentation will significantly delay the partnership timeline.