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CFES Announces New Payment Standards Module to Evaluate the Maturity of Nonbank Payment Programs

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The module establishes a common framework for assessment of design, implementation, operation, and enhancement of payment-related controls and processes.

The Coalition for Financial Ecosystem Standards (CFES), an industry-led organization that sets audit-ready standards for banks, fintechs, and financial services companies, today announced the launch of the Payments Standard Module. Building upon CFES’ established standards, the new Payments Module introduces both a mature 5-Tier Payments Standards matrix and a practical Payments Pre-Launch Checklist designed to ensure operational readiness across bank-supervised payment programs.

Nonbank payment providers such as embedded banking and card program managers, digital wallet providers, payments facilitators, merchant acquirers, and more, are increasingly becoming primary conduits for transaction activity. While this shift has increased convenience and speed for businesses and consumers it has also introduced intricate operational structures across bank-supervised payment programs. With transactions flowing through multi-party networks, clarity around execution readiness and program integrity is critical.

“As payment structures grow more complex, we believe that proactive, industry-led standards are best suited to fill gaps between technology advancements and regulatory oversight,” said Sima Gandhi, Co-Founder of CFES. “The launch of this Payments Module and Pre-Launch Checklist gives nonbank providers and their bank partners a shared, repeatable roadmap to track launch readiness and mitigate settlement and operational risks."

The Module functions as a living framework that helps organizations of all sizes evaluate maturity from rudimentary practices to optimized operations without imposing rigid, one-size-fits-all mandates. In tandem with the standards, the Payments Pre-Launch Checklist provides a baseline tool outlining the essential risk, operational, and customer-readiness controls that nonbank payment providers should satisfy before launching new payment products.

The standard’s five categories address distinct aspects of payments programs: Payments Governance and Risk Management, Payment Product Design and Fund Management, Payment Processing and Operations, Merchant Risk Management, and Consumer Protection.

Designed to complement the CFES Core Risk and Compliance Standards, these new payments standards work alongside existing frameworks governing key discipline areas such as BSA/AML, fraud, compliance management, privacy, information security, and third-party risk management. The standards are not intended to create new regulatory requirements, replace supervisory expectations, or prescribe a single operating model. Rather, they provide a consistent method for evaluating the effectiveness and maturity of practices that support the safe and responsible operation of payment programs.

To learn more about CFES and join the dialogue on building a safer financial ecosystem, visit https://thecfes.com.

About the Coalition for Financial Ecosystem Standards

Founded in 2024, the Coalition for Financial Ecosystem Standards (CFES) is an initiative of FS Vector, a strategic consulting firm, dedicated to developing standards that improve the performance, safety, and efficiency of the evolving financial system. The member-led coalition engages policymakers and industry innovators to deliver actionable risk frameworks and practical operational standards. By bridging the gap between innovative technology and regulatory oversight, CFES is building a safer and more effective financial ecosystem for businesses and consumers.

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