Automating the Process of Process Flows

Dmitry Gritskevich
By Dmitry Gritskevich ·

Banks invest heavily in building out process flows for each of their products. It's not exactly the sexiest topic, but it's done for good reason – financial products are inherently complex and require substantial documentation outlining each step in the manufacturing process. These aren't just boxes and arrows. Each flow serves as a regulatory blueprint that informs product teams about compliance requirements and potential pitfalls. It looks something like this:

Reg E Monitoring and Workflow

Fintechs often overlook this critical step, focusing instead on rapid product development and user experience. Or they do have the flows but end up building products without consulting them, which might actually be worse. So financial institutions normally document everything to death and startups typically lack both the expertise and patience to properly map out their product flows. Good deal.

The Process Flow Gap

Traditional banks excel at documentation because they've been forced to by decades of regulatory scrutiny. Their compliance departments meticulously map every customer interaction, decision point, disclosure delivery, and data handoff. They treat these diagrams as risk management tools that help identify regulatory gaps.

Fintechs, meanwhile, approach this from a technology perspective and prioritize speed to market by building a minimal viable product. They typically only deal with compliance documentation when requested, often scrambling to retroactively document what's already been built. When compliance gaps are inevitably discovered, product changes are made on the fly, disrupting development cycles and creating technical debt.

So we have a paradox: banks document extensively but might not know what's actually happening with their products when the rubber meets the road, while fintechs iterate quickly but lack the expertise to bake compliance requirements into their product architecture from day one. This needs to be reconciled.

Why Process Flows Matter

  1. Sequential dependencies: Certain disclosures must occur before others, and certain consents must be obtained in specific orders
  2. Regulatory timing requirements: Many regulations specify precise timing for notifications, disclosure delivery, and customer responses
  3. Complex handoffs: Multiple third parties are involved in most financial products (identity verification services, credit bureaus, fraud prevention tools)
  4. Branching decision trees: Customer journeys diverge based on verification results, eligibility criteria, and user choices
  5. Evidence requirements: Institutions must prove compliance with an audit trail showing exact sequences and timing Many decision points and compliance touchpoints exist in even basic financial products. Take a simple deposit account opening—you're navigating USA PATRIOT Act requirements, ESIGN consent, CIP program requirements, specialty consumer reporting agency disclosures, and TCPA notices before you even get to the actual account agreement.
Process Flow

How Do We Solve This

Here's where I see a massive opportunity to solve this problem. What if we created a platform that:

  1. Takes product specifications as inputs (account types, features, jurisdictions, customer types)
  2. Identifies all applicable regulatory requirements automatically
  3. Generates compliant process flows showing all required steps, disclosures, and decision points
  4. Produces visual diagrams that product and engineering teams can implement – or better yet, configures another system automatically based on a single source of truth This platform would encode regulatory knowledge into a system that makes compliance accessible to fintech teams without requiring deep regulatory backgrounds. It would also provide monitoring of runtime data to confirm the flow is followed precisely in production environments.

How Does It Work?

The automation would function as a rules engine with a comprehensive regulatory database behind it. Using a simple example:

IF product_type = "consumer_credit_card"
AND customer_acquisition_channel = "online"
AND jurisdiction = "US_nationwide"
THEN
    REQUIRE_DISCLOSURE("FCRA_permissible_purpose", timing = "before_credit_pull")
    REQUIRE_DISCLOSURE("Reg_Z_credit_card_fees", timing = "before_application_submission")
    REQUIRE_CHECK("OFAC", timing = "before_approval")
    etc.

The engine would generate a comprehensive flow based on product attributes, then produce visual documentation showing exactly how to implement a compliant product. It could even produce a digestible output for another system to use – removing yet another manual process from the compliance stack.

Key components would include:

  1. Product taxonomy: Categorization system for financial products and their features
  2. Regulatory corpus: Database of requirements indexed by product types, features, jurisdictions, and customer types.
  3. Temporal logic engine: System to ensure proper sequencing of compliance steps
  4. Visual output generator: Tool to produce implementable diagrams
  5. Change management system: Process to keep requirements current as regulations evolve

Benefits Beyond Documentation

  1. Reduces time-to-market: Fintechs get compliant flows immediately instead of through multiple iterations
  2. Enables more innovation: With compliance handled systematically, teams can focus on differentiation
  3. Supports partner due diligence: Bank partners can review automatically generated flows as part of their diligence process
  4. Creates audit-ready documentation: Flows become documentation that demonstrates compliance intent as well as system configuration
  5. Adapts to regulatory changes: Updates can be pushed automatically as requirements evolve

Can It Work Today?

I think we're pretty close. We already have:

  1. Ways to encode regulation as a knowledge base
  2. Low-code systems generating complex workflows
  3. Data integrations connecting disparate compliance systems The missing piece is connecting product specification directly to regulatory requirements in an automated fashion.

Path Forward

In an ideal world, a fintech should be able to define a product and instantly receive a complete, compliant process flow showing every step, disclosure, and decision point required; in other words, a product development accelerator from a compliance standpoint.

If fintechs could implement robust, compliant processes from day one, we'd see fewer regulatory actions, more successful bank partnerships, and ultimately more responsible innovation. Building financial products is complex enough without having to rediscover compliance requirements with each new product. By embedding regulatory intelligence into product development, we can marry the careful documentation of traditional banks and fintech’s speed of development.

Ready For Data-Driven Compliance?