SOC 2 for US Fintech Companies: What Banks and Buyers Require

• Done for you, end to end

  We write the policies, set up the controls and evidence, run the internal audit and coordinate the independent audit. You deal with one team from first call to final report.

• Simple and quick

  A free gap assessment, then one plan with dates from day one. Effivity, our GRC automation platform, is included to keep the evidence moving.

• 8,100+ client engagements

  In 60+ countries over 20+ years, with experts who bring 30+ years of experience.

• Under US$10,000, all-inclusive

  For most start-ups and SMEs: SOC 2, ISO 27001, ISO 42001, HIPAA or ISO 9001, including the independent audit. A fixed quote follows a free gap assessment.

Every Sterling consulting engagement comes with the following, so you are not buying extras to get to the finish line:

• Effivity, Sterling's GRC automation platform, with a full-year subscription, to run your controls, evidence, tasks and audits in one place.
• Sterling Academy: preferential course access, with complimentary awareness training for your people.
• Internal auditor training for your audit team, as applicable to your standard.
• For information-security engagements, a vulnerability assessment.

These are part of the engagement, not a separate purchase. The details depend on the standard you are working toward, which we confirm during the free gap assessment.

Consulting and auditing are always separated: the people who consult never audit you. That keeps your internal audit objective and protects the independence of the CPA firm, Qualified Security Assessor or certification body that performs the final step.

Behind this are 8,100+ client engagements in 60+ countries over 20+ years, led by experts with 30+ years of experience.

What the fee covers, and what it doesn't:

• It is the fee for your first SOC 2 report or your first certification only.
• Annual work is always additional and billed the following year: later SOC 2 report periods, and ISO surveillance and recertification audits.
• It assumes a typical start-up or SME scope: one product or service and one main location.
• Larger or multi-site scopes get a fixed quote after the gap assessment.
• PCI DSS is quoted separately: a fixed quote follows a free gap assessment.

^[1] Occupational Employment and Wage Statistics, May 2025: 15-1212 Information Security Analysts, national annual median wage. US Bureau of Labor Statistics. accessed October 23, 2026.

The outcome: one independent report that clears US bank vendor reviews, enterprise procurement and investor diligence, instead of a new questionnaire for every deal. We get you ready and coordinate everything; the SOC 2 report is issued by a US-licensed CPA firm, as AICPA standards require.

SOC 2 belongs to the AICPA's System and Organization Controls suite, through which CPAs report to users on a service organization's controls^[1]. An examination covers your system and the controls relevant to security, availability, processing integrity, confidentiality or privacy^[2]. For a product that moves money, that maps closely to what a US buyer worries about. In Sterling's experience, the request reaches a fintech in four ways:

• US banks and credit unions. Offering your product to members puts you in their vendor inventory, and the latest report is due before signature.
• Lenders, wallets and card programs. Platforms building on your API send a diligence pack that wants evidence, not assurances.
• Enterprise finance teams. Security groups that will not approve a vendor on a questionnaire alone.
• US investors. Technical diligence that flags a missing independent report as a risk to revenue.

No US law requires you to hold a SOC 2 report. It is a commercial requirement: you are buying shorter sales cycles, not avoiding a penalty.

The outcome: one security program that serves your regulator and your report, so nothing is built twice. A SOC 2 report is not a regulatory filing, but the work overlaps heavily.

• FTC Safeguards Rule, 16 CFR Part 314. It applies to financial institutions under FTC jurisdiction, with examples including mortgage lenders, finance companies, account servicers, check cashers, wire transferors, collection agencies and certain investment advisors^[3]. Required elements include a Qualified Individual, a written risk assessment, access controls, encryption of customer information in transit and at rest, multi-factor authentication, logging, a written incident response plan and a written report to the board at least annually^[3]. It also requires oversight of service providers^[3], which is why your customers keep asking you for evidence.
• NYDFS, 23 NYCRR Part 500. The New York Department of Financial Services' cybersecurity regulation applies to entities operating under a license, registration, charter or similar authorization under New York's Banking, Insurance or Financial Services Law^[4]. If you hold a New York license it is your own obligation; if you serve license holders, it reaches you through their vendor reviews.

The outcome: a report that covers the service your US customers actually buy, with no categories they did not require.

For most fintechs the right scope is the production service, which typically means:

• the customer-facing application and the APIs other platforms call;
• the cloud accounts, databases and queues holding account, identity and transaction records;
• ledger, reconciliation and payout processes you run yourself;
• identity verification and fraud tooling, with the vendors behind them;
• staff with production or customer-data access, and their devices.

Sterling's recommendation on categories: start with security; add availability when customers depend on you for time-critical funds movement, processing integrity when transaction accuracy is the product, and confidentiality for other companies' data held under contract. Add privacy only when a buyer requires it. Card data is a separate track: SOC 2 does not replace PCI DSS, which is quoted separately.

The outcome: controls that read well to a bank's third-party risk team, written around how your engineers already ship.

• Access to money and data. Role-based, approved by someone other than the requester, reviewed on schedule, removed on the leaving date.
• Multi-factor sign-in. For staff, the cloud console and anything that can move funds or export customer records.
• Change control. A second reviewer before release and a recorded pipeline. Where a bug can misplace money, this carries the most weight.
• Reconciliation. Your records compared with banks and processors, with breaks investigated and closed.
• Encryption and keys. Customer information protected in transit and at rest, with a named key owner.
• Vendor oversight. The vendors behind the product, what each can reach, and evidence you reviewed the important ones.
• Incident response. A written plan, named roles, a tested exercise and logs that reconstruct events.

The outcome: we remove these before your observation period starts.

• Calling the report a regulatory filing. Describe it accurately to a bank's compliance team: an independent examination of controls.
• Two risk documents. The risk assessment your regulator expects and the register your examiner tests should be one current document.
• Picking Type 1 or Type 2 by deadline alone. Plan the Type 2 from day one.
• An over-generous system description. A control that runs only in one region or for new customers becomes an exception.
• Starting the period too early. We run an internal audit first so the period opens clean.

The outcome: a report in hand on schedule, with the work done for you. Sterling's record is 100% success and on-time completion across 8,100+ client engagements in 60+ countries over 20+ years, led by experts with 30+ years of experience. The SOC 2 report is issued by a US-licensed CPA firm, as AICPA standards require; we coordinate the examination, and the people who consult never audit you.

1. Free gap assessment. Your system, cloud set-up and evidence against the Trust Services Criteria and any Safeguards Rule elements you are subject to, with a proposed scope. 2. Policies and controls. We write them around your teams and guide the technical fixes. 3. Evidence. Effivity, our GRC automation platform, holds the control register, tasks and evidence. 4. Internal audit. Independent of the advisers, before the examination begins. 5. Examination. We coordinate the CPA firm's schedule, requests and follow-up.

Ready to begin? Use Get started and a Sterling expert will respond.

A SOC 2 engagement has one deliverable that no consultant can hand you: the report. The SOC 2 report is issued by a US-licensed CPA firm, as AICPA standards require^[1]. What Sterling does is make sure you get there ready, and that nothing between today and the report lands on your desk.

With Sterling, you deal with one team from start to finish. We coordinate:

• a readiness review and a gap assessment against the Trust Services Criteria;
• the policies, procedures and controls you need, written for how your company actually works;
• evidence collection, so the examination does not become a scramble;
• an internal audit before the examiner arrives, carried out by people who did not advise you on the controls;
• the Type 1 or Type 2 path that fits your deal timeline, and the examination itself, including scheduling, requests and follow-ups.

Our experts bring 30+ years of experience, and the firm has completed 8,100+ client engagements in 60+ countries over 20+ years. You get a single plan, a single point of contact and a clear view of what happens next.

^[1] SOC (System and Organization Controls) Suite of Services. AICPA & CIMA. accessed October 23, 2026.

• SOC 2: standard overviewStandard overview
• ISO/IEC 27001: standard overviewStandard overview
• Clear US Enterprise Security Reviews and Questionnaires FastUnited States
• Pass US Investor Due Diligence on Security, FastUnited States
• SOC 2 Type 1 vs Type 2: Which Report US Buyers ExpectUnited States
• How US Start-ups Answer Security Questionnaires FastUnited States
• PCI DSS for US Fintechs: What Acquirers and Card Programs RequireUnited States
• ISO/IEC 27001 for US Fintech Companies: Banks, Regulators, BuyersUnited States
• Sterling in the United StatesUnited States

1. SOC (System and Organization Controls) Suite of Services. AICPA & CIMA. accessed October 23, 2026.

2. SOC 2 Reporting on an Examination of Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy. AICPA & CIMA. accessed October 23, 2026.

3. 16 CFR Part 314, Standards for Safeguarding Customer Information (Safeguards Rule), sections 314.1, 314.2, 314.4, 314.5 and 314.6. Electronic Code of Federal Regulations. accessed October 23, 2026.

4. Cybersecurity Resource Center (23 NYCRR Part 500). New York State Department of Financial Services. accessed October 23, 2026.

The information on this page is provided for general informational purposes only. It is not legal advice, and it is not a substitute for advice from a qualified attorney about your own situation.

Requirements depend on your scope, your customers' contracts, your industry and the regulations that apply to you. Two companies asking for the same standard can have very different obligations. We confirm yours during a gap assessment, and we update our content as standards change, but you should check the current text of any standard or rule that matters to you.

Sterling consults and prepares. It does not decide whether you meet a standard. That decision belongs to the independent party that performs the final step: the US-licensed CPA firm for a SOC 2 report, the Qualified Security Assessor or acquirer for PCI DSS, and the accredited certification body for ISO certificates. Timelines and outcomes depend on your readiness and on those parties.

Standards and marks named on this site belong to their respective owners.