Decision / Product
Launching embedded accounts or cards on a platform
What does the platform become when it offers accounts?
Embedded products change the platform, not just its product line. The platform starts to sit inside a regulated flow, with responsibilities that depend on how the programme is structured.
Simulation shows the consequence across platform, partner and end customer rather than for the platform alone.
Regulatory delta
What this decision tends to move
The delta is the difference between the institution's position today and its position if this decision were executed.
- Activity
- What the platform is doing in the flow.
- Structure
- Which party is the regulated one.
- Dependencies
- What the platform relies on the partner for.
- Controls
- What the platform must operate and evidence.
- Disclosure
- What the end customer must be told.
Design space
Ways to reach the same commercial objective
Two configurations that achieve the same outcome frequently produce materially different regulatory deltas. Comparing them is how the decision is made.
Option 01
Fully partner-issued
Smallest platform delta.
Option 02
Platform as programme manager
More control, more obligation.
Option 03
Platform holds its own permissions
Largest delta, most independence.
Before committing
What management should establish first
- Which model the commercial economics require
- What each model obliges the platform to run
- How the structure looks under partner diligence
Common questions
Questions this page answers
Can a platform stay outside the regulatory perimeter?
Sometimes, depending on structure and substance. Simulation is how that is tested rather than assumed.
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