Fractional CISO services for fintechs, banks, and regulated financial institutions

Your regulator expects a named information security officer. Your board needs someone accountable for cybersecurity risk. Your bank partner wants a security program that meets GLBA, SOC 2, and examiner expectations. A fractional CISO gives you senior information security leadership, including named officer designation, without the cost of a full-time executive hire.

Equinox Compliance provides virtual CISO services that go beyond advisory: our fractional CISOs serve as your CISO of record, carry personal regulatory accountability, and build the security program your business requires.

Whether you are searching for a vCISO, a fractional chief information security officer, or an outsourced information security officer, the core need is the same: examiner-ready security leadership on a retained basis. At Equinox, we deliver fractional CISO consulting with named officer accountability, not just a ciso consultant behind the scenes.

Regulators, auditors, and bank partners evaluate your information security posture as a core component of every examination and oversight review. GLBA Safeguards Rule compliance, cybersecurity risk assessments, SOC 2 readiness, incident response, and third-party security oversight all require a senior leader who owns the program end to end.

The challenge for most fintechs, BaaS programs, and bank partnership products is that a full-time CISO commands a salary and benefits package that early and growth-stage companies cannot justify. Outsourced CISO services and virtual CISO consulting services have emerged to fill this gap, but many vCISO companies deliver advisory reports with no personal accountability. When an examiner asks who owns your information security program, “our consultant” is not the answer they are looking for.

A fractional CISO solves this problem: a senior information security leader embedded in your organization on a retained basis, with the authority, accountability, and regulatory fluency to satisfy examiners, auditors, and bank partners. vCISO meaning, in the way Equinox structures these engagements, is a named security officer who carries the same accountability a full-time CISO would. At Equinox, our fractional CISO engagements are structured so your CISO carries named officer designation and is accountable to your board from day one.

We build and manage your information security program from the ground up, aligned with GLBA and the regulatory frameworks that govern your business.

• Design information security programs aligned with GLBA Safeguards Rule compliance, FFIEC guidance, NIST, and ISO 27001 frameworks
• Establish security governance structures including policies, standards, procedures, and control documentation
• Conduct and manage ongoing cybersecurity risk assessments calibrated to your product, your regulator, and your bank partner’s expectations
• Own the information security program as your fractional chief information security officer with full accountability to your board and regulators

We serve as your designated CISO of record with personal regulatory liability, structured to meet examiner expectations for named officer accountability.

• Carry named officer designation documented in a signed engagement letter with clearly defined responsibilities and regulatory accountability
• Report to your board on information security posture, risk exposure, and program effectiveness
• Interface directly with examiners, auditors, and bank partner oversight teams as your named security officer
• Provide the examiner-ready leadership that regulators expect, priced separately from CISO advisory work to reflect the accountability involved

We prepare your organization for SOC 2 Type I and Type II engagements with a compliance-integrated approach that reduces duplication and accelerates certification.

• Conduct SOC 2 readiness assessments including control mapping, gap analysis, and remediation planning
• Design and document controls across security, availability, processing integrity, confidentiality, and privacy trust service criteria
• Coordinate with external auditors and manage evidence collection, testing, and remediation throughout the audit process
• Align SOC 2 controls with your existing CMS and regulatory compliance framework to avoid building redundant control structures

We design and manage your business continuity and disaster recovery capabilities to meet regulatory expectations and operational resilience requirements.

• Review and update business continuity plans and disaster recovery procedures for regulatory alignment
• Design and execute BCP/DRP testing programs with documented results and remediation tracking
• Align continuity and recovery capabilities with bank partner SLAs, regulatory guidance, and examiner expectations

We manage the security testing lifecycle from vendor coordination through finding remediation, ensuring your penetration testing program produces actionable results.

• Coordinate penetration testing engagements with qualified third-party vendors
• Review penetration test results, prioritize findings by risk severity, and develop remediation plans
• Track remediation progress and validate that fixes address the root cause
• Maintain documentation that demonstrates control effectiveness to examiners and auditors

We establish the governance practices and change management controls that regulators expect to see in a mature information security environment.

• Design change management processes for technology changes that produce auditable approval records and satisfy examiner expectations
• Establish IT governance frameworks covering access control, configuration management, and system administration
• Build approval workflows and documentation standards that integrate into your engineering team’s existing processes

We evaluate AI and machine learning vendors with the rigor regulators increasingly expect, covering model risk, data governance, and third-party oversight.

• Conduct AI vendor due diligence assessments covering model documentation, training data governance, and output validation
• Review model cards and vendor-provided documentation against regulatory expectations for explainability, fairness, and performance monitoring
• Design ongoing AI vendor oversight cadence aligned with model risk management guidance and bank partner requirements

1. Assessment and gap analysis: We evaluate your current security posture, existing policies, and regulatory obligations. We identify gaps, prioritize remediation, and define the scope of the fractional CISO engagement.
2. Program design and documentation: We design your information security program framework, draft policies and procedures, and establish the governance structures regulators expect. If you need named officer designation, we formalize the CISO of record arrangement.
3. Implementation and operations: We implement security controls, launch risk assessment and testing programs, and begin managing day-to-day information security operations. We assume accountability as your fractional CISO and begin interfacing with your board, examiners, and bank partners.
4. Ongoing management and scaling: We manage recurring security deliverables including cybersecurity risk assessments, BCP/DRP testing, and SOC 2 audit cycles. We maintain exam readiness, refine the program as your regulatory environment evolves, and support transition to in-house security leadership when your organization is ready.

Named officer accountability, not just advisory. Our fractional CISOs serve as your CISO of record with personal regulatory liability. We carry the designation, face the examiners, and own the outcomes. This is what separates a fractional CISO from standard vCISO solutions or CISO consulting engagements.

Regulatory framework fluency. We design security programs against GLBA, FFIEC, NIST, SOC 2, and interagency guidance. Your information security posture reflects the specific frameworks that govern your business.

Integrated with your compliance program. Information security does not operate in isolation. Our CISOs work alongside your compliance, risk, and AML functions to ensure that controls, policies, and reporting are coordinated rather than duplicated.

Built for fintechs and regulated financial services. We operate across fintech, banking, BaaS, embedded finance, lending, payments, and digital assets. Your fractional CISO understands the shared control dynamics, fractional CISO bank partnership expectations, and examiner priorities specific to your business model.

Reduce audit and exam friction. Organizations with compliance-aware security leadership spend less time scrambling for evidence and remediating findings. We build the documentation, logging, and control evidence into the program from the start.

• Fintechs that need a named CISO for sponsor bank onboarding, regulatory examinations, or SOC 2 certification
• Early and growth-stage companies that need senior security leadership but cannot justify a full-time CISO hire, including fractional CISO for startups preparing for their first examination
• Bank partnership and BaaS programs that require examiner-ready information security oversight and CISO compliance for fintech banking operations
• Organizations preparing for SOC 2 Type I or Type II engagements and needing integrated compliance and security leadership
• Companies responding to security-related exam findings, MRAs, or incidents that require experienced leadership to manage remediation
• Regulated companies evaluating virtual CISO companies and fractional CISO firms looking for a provider that carries named officer accountability
• Fintechs navigating GLBA Safeguards Rule compliance for the first time and needing a fractional security consultant with regulatory depth
• Companies looking for a CISO for hire, vCISO as a service, or vciso consulting engagement with real accountability

• BSA/AML compliance program development: Build the anti-money laundering program that operates alongside your information security controls
• Compliance management system (CMS) design: Establish the policies, procedures, and governance structures that regulators expect
• SOC 2 compliance: Prepare for SOC 2 Type I and Type II certification with integrated compliance and security support
• Regulatory readiness assessments: Identify security and compliance gaps before regulators do
• Earned wage access compliance: Navigate the licensing and regulatory requirements specific to EWA platforms

Whether you need a fractional CISO to build your security program from the ground up, a named CISO of record for regulatory accountability, or virtual CISO services to prepare for SOC 2 certification and GLBA compliance, Equinox Compliance delivers senior information security leadership calibrated to the regulatory environment you operate in.