Sample CompanyScope Profile
SoFi Technologies, Inc. (NASDAQ: SOFI)
Report Date: September 26, 2026 · Gap Mode — Preliminary (public sources only) · RCPS Methodology v1.2
SAMPLE DOCUMENT — ILLUSTRATIVE USE ONLY
This profile was produced entirely from public sources as a sample deliverable for the RuleboardAI marketing website. No client engagement exists between RuleboardAI and SoFi Technologies, Inc. No client documentation was reviewed. All data is sourced from public filings and regulatory records as cited below.
Not an audit, legal opinion, or attestation. Built from public sources only.
What a purchase covers. This sample shows the full report structure across every category. A CompanyScope profile ($500 one-time) covers one category you choose, in the same structure.
Table of Contents
- 1. Executive Summary & Risk Posture
- 1A. Control Maturity Scorecard
- 1B. Risk Appetite Conformance
- 2. RCPS Classification Profile
- 3. Workflow Scope Determination
- 3B. Detailed Workflow Assessment
- 4. Detailed Risk Findings
- 5. Regulatory Obligation Map
- 6. Workflow Linkage Map
- 7. Escalations — Items Requiring Review
- 8. Next Actions — Prioritized
- 9. Peer Context
- 10. RuleboardAI Engagements
- 11. Confidence Legend, Data Gaps & Disclaimers
- Source Appendix
Executive summary at a glance
Public-source, preliminary — figures summarize the detail below.RCPS maturity
Composite maturity
Composite maturity
2.8 / 5.0
Defined
Illustrative target — not a promised outcome
3.9 / 5.0
What this number means
Each GRC category is scored from 1 to 5: Initial, Developing, Defined, Managed, Optimized. The composite is the average of the category scores, shown to one decimal.
The word beside it is the nearest whole level. A score of 2.8 is closest to 3, so it reads Defined.
Scores come from public sources only. A low score usually means the evidence is not visible from outside, not that a control is absent.
The target is the average of what each category could realistically reach for an institution of this size and stage. It is not a promise and not a benchmark. Full rule in the methodology.
Scored categories
- Internal Governance
- ESG & Non-Financial Reporting
- Operational Risk
- Third-Party / Supply Chain Risk
- Cybersecurity
- SOC 2 (Trust Services)
- Financial Regulation
- International Frameworks
- Privacy & Data Protection
- Ongoing / Scheduled
- HR & People Risk
A full assessment scores each category 1–5. This sample publishes only its composite — the mean of its category scores — so no per-category scores are shown here. Illustrative.
Composite 2.6 of 5 — the mean of the category scores in the maturity scorecard. Illustrative target 3.8 of 5, not a promised outcome.
Workflow scoping
Every client is assessed against the same set of applicable regulatory workflows across the relevant GRC domains. Each workflow is sorted into one of three buckets, and the determination is recorded so you can see why a workflow was included or left out.
- In scope
Applies to this client — runs this cycle.
- Conditional
Applies only if a trigger is met — flagged for review.
- Out of scope
Not applicable to this client — documented, not ignored.
Illustrative — the actual scope is determined per client during RCPS classification.
RCPS classification
Type 7 National Bank / BHC (primary) · Type 4 Broker-Dealer · Type 5 RIA · Type 16 Fintech Platform (secondary)
Every score and label in this profile follows the published RCPS Methodology & Scoring Standards — including what the scores mean and what they cannot conclude.
1. Executive Summary & Risk Posture
Overall Posture
SoFi Technologies, Inc. is a publicly traded (NASDAQ: SOFI), Delaware-incorporated bank holding company and financial holding company headquartered at 234 1st Street, San Francisco, CA 94105. As of December 31, 2025, SoFi reported total assets of $50.7 billion (up 40% year over year), total deposits of $37.5 billion, total net revenue of $3.6 billion (up 35%), and net income of $481.3 million. The company employs approximately 6,100 people, about 82% in the United States, across three reported segments: Lending, Financial Services, and Technology Platform. With 13.7 million members and 20.2 million products at year-end 2025, SoFi has grown from a pre-bank fintech into a nationally chartered bank holding company subject to multi-regulator oversight (OCC, Federal Reserve, CFPB, SEC, FINRA, FinCEN/BSA, FDIC, and state regulators). This profile is produced entirely from public sources; no internal documentation was reviewed (Gap Mode). Overall preliminary risk posture: Elevated, driven by rapid asset growth, multi-regulator complexity, the $50 billion asset threshold, and historical enforcement actions across multiple subsidiaries.
Top Risk
The single highest-priority build item identified from public sources is BSA/AML and KYC program adequacy at scale. SoFi Bank and its affiliates became subject to CFPB supervision and examination on January 1, 2024, and at $50.7 billion in total assets at December 31, 2025 the bank sits above the current $50 billion OCC heightened-standards threshold; a December 23, 2025 OCC proposal would raise that threshold to $700 billion, and nothing here treats the proposal as settled. Publicly, SoFi Bank's BSA/AML program is acknowledged in the 10-K but not described. Two subsidiary enforcement actions (FINRA, $1.1 million, May 2024, for 2018–2019 CIP and identity-theft-program failures; SEC, $300,000, August 2021, for undisclosed conflicts of interest) and an FTC consent order (2019, in force until 2039) are the public record of compliance program maturity lagging growth in earlier periods. Current program details cannot be confirmed from public sources; this is the most material data gap.
Regulatory Stack
Primary federal regulators: OCC (SoFi Bank, N.A., Cottonwood Heights, UT, charter no. 20862, listed active on the OCC national bank list as of August 31, 2026); Federal Reserve (bank holding company and financial holding company, BHCA §4(l)); CFPB (supervision and examination of SoFi Bank and its affiliates from January 1, 2024); FinCEN/BSA (Bank Secrecy Act obligations for SoFi Bank and affiliates); SEC (SoFi is a public reporting company, CIK 0001818874; SoFi Wealth LLC is an SEC-registered investment adviser; SoFi Securities LLC is an SEC-registered broker-dealer); FINRA (SoFi Securities LLC, CRD 151717); FDIC (deposit insurer for SoFi Bank, N.A., with secondary supervisory authority; expanded coverage up to $3 million through a reciprocal deposit program). State regulators: the 10-K states that the company and its affiliates are subject to supervision and examination by various state regulators. International: the company operates in Latin America, Canada and Switzerland largely through the Technology Platform segment, and in Hong Kong through SoFi Holdings (Hong Kong) Limited.
Fund / BDC Overlay
SoFi is not a registered investment company. SoFi Wealth LLC operates a robo-advisory service and is the group's SEC-registered investment adviser. SoFi Capital Advisors LLC, named in earlier filings, shows an inactive adviser registration in the SEC adviser registry as of September 26, 2026. Social Finance, Inc. sponsors registered ETFs advised by a third-party adviser: the SoFi Next 500 ETF (SFYX) was liquidated in February 2026, while the SoFi Select 500 ETF (SFY) and two other SoFi-branded ETFs remain registered per a June 2026 filing. SoFi Crypto launched November 2025 and SoFiUSD launched December 2025, both at SoFi Bank, N.A. Fund overlay: sponsor role only; no SoFi entity acts as adviser to a registered fund per public sources.
Key Person Risk
Anthony Noto (CEO, age 57, Director) is the key executive whose departure the 10-K risk factors identify as material (loss of key management members). CFO: Chris Lapointe. CRO: Arun Pinto (since February 2024). General Counsel: Rob Lavet. CTO: Jeremy Rishel. Board: Tom Hutton, independent Chair, separate from the CEO. Auditor: Deloitte & Touche LLP (since 2017). Key-person concentration is a Likely medium risk; succession planning details are Unresolved from public sources.
1A. Control Maturity Scorecard
Scores are Likely/Conditional inferences from public disclosures only. No internal documentation reviewed. Many scores reflect a data gap rather than a confirmed deficiency.
| GRC Category | Current Maturity | Target | Evidence / Basis |
|---|---|---|---|
| 1. SOC 2 (Trust Services) | 3 — Defined (Likely) | 4 | FY2025 10-K states that SOC 2 and PCI-DSS "apply to or are maintained by certain of our solutions" and that third-party attestations and assessments are conducted periodically. Which entities and systems are covered, and the report itself, are not public. |
| 2. Financial Regulation | 3 — Defined (Likely) | 5 | Multi-regulator structure confirmed (OCC, Fed, CFPB, SEC, FINRA, FinCEN). SoFi Bank "well capitalized" under all regulatory definitions at December 31, 2025 per 10-K. BSA/AML program acknowledged but not described publicly. Historical enforcement: FINRA $1.1M (May 2024, 2018–2019 CIP/ITPP conduct), SEC $300K (2021 conflicts), FTC consent order (2019–2039). |
| 3. International Frameworks | 2 — Developing (Conditional) | 3 | No DORA applicability confirmed. ISO 27002:2013 referenced in 10-K Item 1C. BCP/ISO 22301 status not publicly disclosed. Technisys S.A. (Luxembourg) and operations in Latin America, Canada, Switzerland and Hong Kong may trigger non-U.S. obligations; Unresolved from public sources. |
| 4. Internal Governance | 3 — Defined (Likely) | 4 | Independent Chair (Hutton); Audit (chair Meltzer), Risk (chair Hele), Compensation and Nominating committees all independent per DEF 14A 2026. Risk Committee oversees cybersecurity and the BSA/AML program; met six times in 2025. Enterprise Risk Management program referenced in 10-K. Internal audit team conducts annual IS/IT audits. Policy library details not public. |
| 5. Ongoing / Scheduled | 3 — Defined (Conditional) | 4 | Regulatory change management implied by the multi-regulator environment. CISO provides quarterly cybersecurity updates to the Risk Committee (10-K Item 1C). Training completion details not public. Third-Party Security Risk Management program includes ongoing monitoring and contract review. |
| 6. Privacy & Data Protection | 3 — Defined (Likely) | 4 | CCPA/CPRA obligations confirmed in 10-K. GDPR exposure conditional on offering services into the EU/UK per 10-K risk factor. Privacy policy public on sofi.com. Data retention and privacy impact assessment details not public. |
| 7. Cybersecurity | 3 — Defined (Likely) | 4 | Frameworks in 10-K Item 1C: ISO 27002:2013, NIST CSF, PCI-DSS, FFIEC guidelines, CIS controls. CISO in role since June 2025 with over 25 years' experience. Annual internal audits and internal and external penetration tests confirmed. No material incidents identified per 10-K. Zero Trust maturity not publicly assessable. |
| 8. HR & People Risk | 2 — Developing (Conditional) | 3 | Securities Trading and Section 16 Compliance Policy filed as Exhibit 19.1 to the 10-K. FINRA registration applies to SoFi Securities personnel. Public-company whistleblower channel under Dodd-Frank applies; internal whistleblower program details not public. Background check program details not public. |
| 9. Third-Party / Supply Chain Risk | 3 — Defined (Likely) | 4 | Formal Third-Party Security Risk Management program confirmed (10-K Item 1C): risk-based onboarding due diligence, ongoing monitoring, contract review. Technology Platform is also a supplier to third parties. A large Galileo client fully transitioned off the platform in 2025, taking total accounts from 167.7 million to 128.5 million (down 23%): a confirmed public signal of concentration risk. |
| 10. ESG & Non-Financial Reporting | 3 — Defined (Conditional) | 4 | FY2025 10-K states that SoFi published its third comprehensive ESG report in 2025 and communicates climate-related commitments in that report. The report's content and any TCFD alignment were not reviewed in this pass. The SEC climate disclosure rules have been stayed since April 2024 and rescission was proposed in May 2026, so no SEC climate filing obligation is treated as active. SFDR/CSRD not applicable. |
| 11. Operational Risk | 3 — Defined (Likely) | 4 | Enterprise Risk Management program referenced in 10-K. Business continuity and disaster recovery details not public. Rapid balance sheet growth ($50.7B, +40%) and the $50B threshold create operational scaling risk. OCC proposed raising the heightened-standards threshold from $50B to $700B (December 23, 2025); proposed, not final. |
GRC Category
1. SOC 2 (Trust Services)
Current Maturity
3 — Defined (Likely)
Target
4
Evidence / Basis
FY2025 10-K states that SOC 2 and PCI-DSS "apply to or are maintained by certain of our solutions" and that third-party attestations and assessments are conducted periodically. Which entities and systems are covered, and the report itself, are not public.
GRC Category
2. Financial Regulation
Current Maturity
3 — Defined (Likely)
Target
5
Evidence / Basis
Multi-regulator structure confirmed (OCC, Fed, CFPB, SEC, FINRA, FinCEN). SoFi Bank "well capitalized" under all regulatory definitions at December 31, 2025 per 10-K. BSA/AML program acknowledged but not described publicly. Historical enforcement: FINRA $1.1M (May 2024, 2018–2019 CIP/ITPP conduct), SEC $300K (2021 conflicts), FTC consent order (2019–2039).
GRC Category
3. International Frameworks
Current Maturity
2 — Developing (Conditional)
Target
3
Evidence / Basis
No DORA applicability confirmed. ISO 27002:2013 referenced in 10-K Item 1C. BCP/ISO 22301 status not publicly disclosed. Technisys S.A. (Luxembourg) and operations in Latin America, Canada, Switzerland and Hong Kong may trigger non-U.S. obligations; Unresolved from public sources.
GRC Category
4. Internal Governance
Current Maturity
3 — Defined (Likely)
Target
4
Evidence / Basis
Independent Chair (Hutton); Audit (chair Meltzer), Risk (chair Hele), Compensation and Nominating committees all independent per DEF 14A 2026. Risk Committee oversees cybersecurity and the BSA/AML program; met six times in 2025. Enterprise Risk Management program referenced in 10-K. Internal audit team conducts annual IS/IT audits. Policy library details not public.
GRC Category
5. Ongoing / Scheduled
Current Maturity
3 — Defined (Conditional)
Target
4
Evidence / Basis
Regulatory change management implied by the multi-regulator environment. CISO provides quarterly cybersecurity updates to the Risk Committee (10-K Item 1C). Training completion details not public. Third-Party Security Risk Management program includes ongoing monitoring and contract review.
GRC Category
6. Privacy & Data Protection
Current Maturity
3 — Defined (Likely)
Target
4
Evidence / Basis
CCPA/CPRA obligations confirmed in 10-K. GDPR exposure conditional on offering services into the EU/UK per 10-K risk factor. Privacy policy public on sofi.com. Data retention and privacy impact assessment details not public.
GRC Category
7. Cybersecurity
Current Maturity
3 — Defined (Likely)
Target
4
Evidence / Basis
Frameworks in 10-K Item 1C: ISO 27002:2013, NIST CSF, PCI-DSS, FFIEC guidelines, CIS controls. CISO in role since June 2025 with over 25 years' experience. Annual internal audits and internal and external penetration tests confirmed. No material incidents identified per 10-K. Zero Trust maturity not publicly assessable.
GRC Category
8. HR & People Risk
Current Maturity
2 — Developing (Conditional)
Target
3
Evidence / Basis
Securities Trading and Section 16 Compliance Policy filed as Exhibit 19.1 to the 10-K. FINRA registration applies to SoFi Securities personnel. Public-company whistleblower channel under Dodd-Frank applies; internal whistleblower program details not public. Background check program details not public.
GRC Category
9. Third-Party / Supply Chain Risk
Current Maturity
3 — Defined (Likely)
Target
4
Evidence / Basis
Formal Third-Party Security Risk Management program confirmed (10-K Item 1C): risk-based onboarding due diligence, ongoing monitoring, contract review. Technology Platform is also a supplier to third parties. A large Galileo client fully transitioned off the platform in 2025, taking total accounts from 167.7 million to 128.5 million (down 23%): a confirmed public signal of concentration risk.
GRC Category
10. ESG & Non-Financial Reporting
Current Maturity
3 — Defined (Conditional)
Target
4
Evidence / Basis
FY2025 10-K states that SoFi published its third comprehensive ESG report in 2025 and communicates climate-related commitments in that report. The report's content and any TCFD alignment were not reviewed in this pass. The SEC climate disclosure rules have been stayed since April 2024 and rescission was proposed in May 2026, so no SEC climate filing obligation is treated as active. SFDR/CSRD not applicable.
GRC Category
11. Operational Risk
Current Maturity
3 — Defined (Likely)
Target
4
Evidence / Basis
Enterprise Risk Management program referenced in 10-K. Business continuity and disaster recovery details not public. Rapid balance sheet growth ($50.7B, +40%) and the $50B threshold create operational scaling risk. OCC proposed raising the heightened-standards threshold from $50B to $700B (December 23, 2025); proposed, not final.
Composite: 2.8 — Defined → Target 3.9 — Managed
How the composite is calculated: categories scored, 11. Sum of the scores, 31. 31 ÷ 11 = 2.82, shown as 2.8; the nearest whole level is Defined. Target: 43 ÷ 11 = 3.91, shown as 3.9; nearest level Managed. The target is illustrative, not a promised outcome.
Dominant uplift priorities: BSA/AML program documentation; SOC 2 scope confirmation; BCP/DR testing evidence; whistleblower and HR program detail; ESG report content review.
1B. Risk Appetite Conformance
External benchmarks: OCC Heightened Standards (12 CFR Part 30), CFPB Supervision and Examination Manual, FFIEC BSA/AML Examination Manual, SEC Regulation Best Interest / fiduciary standard (SoFi Wealth), NIST CSF 2.0. Verdicts are Conditional inferences from public evidence only.
| Domain | Inherent Risk | Within Tolerance? | Basis |
|---|---|---|---|
| BSA/AML / KYC | High | Unresolved | FINRA $1.1M CIP/ITPP fine (May 2024, conduct December 2018–April 2019). Bank-level BSA program mandated; program quality not verifiable from public sources. |
| Capital Adequacy | Medium | Within Tolerance | SoFi Bank "well capitalized" under all regulatory definitions at December 31, 2025 (10-K FY2025). $10B+ and $50B+ triggers active. |
| Consumer Protection / UDAAP | High | Unresolved | CFPB supervision commenced January 1, 2024. FTC consent order (in force to 2039) on savings-claim advertising. No CFPB enforcement action found; examination outcomes are not public. |
| Cybersecurity / Data | Medium | Conditional | ISO 27002 and NIST CSF referenced; no material incidents per 10-K. Zero Trust, SIEM and EDR maturity not publicly confirmable. |
| Fiduciary / Conflicts of Interest | Medium | Non-Conformance (historical) | SEC $300K order (2021) against SoFi Wealth LLC for undisclosed proprietary-ETF conflicts. Undertakings ordered; current monitoring status Unresolved. |
| Operational Resilience | Medium | Unresolved | BCP/DR testing not publicly disclosed. Rapid growth ($50.7B assets) increases operational complexity. |
| Model / Credit Risk | High | Conditional | Loans at fair value of $36.4B at December 31, 2025 (Q4 2025 earnings release). Credit model details proprietary. 10-K cites model risk as a key risk factor. |
| ESG Disclosure | Low | Conditional | Third comprehensive ESG report published in 2025 per 10-K; content not reviewed. SEC climate rules stayed and proposed for rescission; no active federal climate filing obligation. |
Domain
BSA/AML / KYC
Inherent Risk
High
Within Tolerance?
Unresolved
Basis
FINRA $1.1M CIP/ITPP fine (May 2024, conduct December 2018–April 2019). Bank-level BSA program mandated; program quality not verifiable from public sources.
Domain
Capital Adequacy
Inherent Risk
Medium
Within Tolerance?
Within Tolerance
Basis
SoFi Bank "well capitalized" under all regulatory definitions at December 31, 2025 (10-K FY2025). $10B+ and $50B+ triggers active.
Domain
Consumer Protection / UDAAP
Inherent Risk
High
Within Tolerance?
Unresolved
Basis
CFPB supervision commenced January 1, 2024. FTC consent order (in force to 2039) on savings-claim advertising. No CFPB enforcement action found; examination outcomes are not public.
Domain
Cybersecurity / Data
Inherent Risk
Medium
Within Tolerance?
Conditional
Basis
ISO 27002 and NIST CSF referenced; no material incidents per 10-K. Zero Trust, SIEM and EDR maturity not publicly confirmable.
Domain
Fiduciary / Conflicts of Interest
Inherent Risk
Medium
Within Tolerance?
Non-Conformance (historical)
Basis
SEC $300K order (2021) against SoFi Wealth LLC for undisclosed proprietary-ETF conflicts. Undertakings ordered; current monitoring status Unresolved.
Domain
Operational Resilience
Inherent Risk
Medium
Within Tolerance?
Unresolved
Basis
BCP/DR testing not publicly disclosed. Rapid growth ($50.7B assets) increases operational complexity.
Domain
Model / Credit Risk
Inherent Risk
High
Within Tolerance?
Conditional
Basis
Loans at fair value of $36.4B at December 31, 2025 (Q4 2025 earnings release). Credit model details proprietary. 10-K cites model risk as a key risk factor.
Domain
ESG Disclosure
Inherent Risk
Low
Within Tolerance?
Conditional
Basis
Third comprehensive ESG report published in 2025 per 10-K; content not reviewed. SEC climate rules stayed and proposed for rescission; no active federal climate filing obligation.
Read-out: Three domains are Unresolved (BSA/AML, Consumer Protection, Operational Resilience) and one is a historical Non-Conformance (fiduciary/conflicts). Capital adequacy is Within Tolerance. Full conformance assessment requires client engagement and internal documentation review.
2. RCPS Classification Profile
Institution types assigned: Type 7 — National Bank / Bank Holding Company (PRIMARY) + Type 4 — Broker-Dealer (SECONDARY, SoFi Securities LLC) + Type 5 — Investment Adviser (SECONDARY, SoFi Wealth LLC / SoFi Capital Advisors LLC) + Type 16 — Fintech / Payments Platform (SECONDARY, Technology Platform segment: Galileo + Technisys)
RCPS Classification by Axis
| RCPS Axis | Code | Classification | Basis / Note |
|---|---|---|---|
| 1 — Listing Status | PUB | Publicly listed | NASDAQ: SOFI; CIK 0001818874; SEC reporting company (Exchange Act) |
| 1A — Fund Overlay | SPONSOR | Sponsor of registered ETFs; no adviser role | Social Finance, Inc. sponsors the SoFi Select 500 ETF (SFY) and two other SoFi-branded ETFs advised by Tidal Investments LLC (485BPOS, June 26, 2026); the SoFi Next 500 ETF (SFYX) was liquidated February 2026. SoFi Wealth LLC robo-advisory does not constitute a fund complex. |
| 2 — Company Size | S5 | Large Enterprise | Total assets $50.7B (Dec 31, 2025); total net revenue $3.6B (FY2025); ~6,100 employees |
| 3 — Industry | I-FINTECH / I-BANK | Fintech + National Bank | Nationally chartered bank (SoFi Bank, N.A.); bank holding company; financial holding company; technology platform (Galileo, Technisys) serving third-party institutions |
| 4 — Geography | US-PRIMARY / INTL-SECONDARY | US-primary with international operations | Per 10-K: operates primarily in the United States, and internationally in Latin America, Canada and Switzerland (largely Technology Platform) and Hong Kong (SoFi Holdings (Hong Kong) Limited; SoFi Securities (Hong Kong) Limited launched crypto trading in 2025). No EU-regulated entity confirmed. |
| 5 — Data Intensity | D4 | Maximum data intensity | Consumer financial data (13.7M members); deposit, lending, investment and payment data; technology platform serves 128.5M accounts; crypto trading (November 2025) and a bank-issued stablecoin (December 2025) |
| 6 — Ownership | PUB-PARENT | Public corporate parent | SoFi Technologies, Inc. is the publicly traded parent; SoFi Bank, N.A. is a wholly owned subsidiary; no PE or private ownership layer |
| 7 — Growth Stage | G4 | Scale-up / Rapid Growth | 35% YoY member growth; 40% YoY total asset growth; adjusted EBITDA of $1.05B in 2025 (Q4 2025 earnings release); 2026 guidance issued January 30, 2026 |
RCPS Axis
1 — Listing Status
Code
PUB
Classification
Publicly listed
Basis / Note
NASDAQ: SOFI; CIK 0001818874; SEC reporting company (Exchange Act)
RCPS Axis
1A — Fund Overlay
Code
SPONSOR
Classification
Sponsor of registered ETFs; no adviser role
Basis / Note
Social Finance, Inc. sponsors the SoFi Select 500 ETF (SFY) and two other SoFi-branded ETFs advised by Tidal Investments LLC (485BPOS, June 26, 2026); the SoFi Next 500 ETF (SFYX) was liquidated February 2026. SoFi Wealth LLC robo-advisory does not constitute a fund complex.
RCPS Axis
2 — Company Size
Code
S5
Classification
Large Enterprise
Basis / Note
Total assets $50.7B (Dec 31, 2025); total net revenue $3.6B (FY2025); ~6,100 employees
RCPS Axis
3 — Industry
Code
I-FINTECH / I-BANK
Classification
Fintech + National Bank
Basis / Note
Nationally chartered bank (SoFi Bank, N.A.); bank holding company; financial holding company; technology platform (Galileo, Technisys) serving third-party institutions
RCPS Axis
4 — Geography
Code
US-PRIMARY / INTL-SECONDARY
Classification
US-primary with international operations
Basis / Note
Per 10-K: operates primarily in the United States, and internationally in Latin America, Canada and Switzerland (largely Technology Platform) and Hong Kong (SoFi Holdings (Hong Kong) Limited; SoFi Securities (Hong Kong) Limited launched crypto trading in 2025). No EU-regulated entity confirmed.
RCPS Axis
5 — Data Intensity
Code
D4
Classification
Maximum data intensity
Basis / Note
Consumer financial data (13.7M members); deposit, lending, investment and payment data; technology platform serves 128.5M accounts; crypto trading (November 2025) and a bank-issued stablecoin (December 2025)
RCPS Axis
6 — Ownership
Code
PUB-PARENT
Classification
Public corporate parent
Basis / Note
SoFi Technologies, Inc. is the publicly traded parent; SoFi Bank, N.A. is a wholly owned subsidiary; no PE or private ownership layer
RCPS Axis
7 — Growth Stage
Code
G4
Classification
Scale-up / Rapid Growth
Basis / Note
35% YoY member growth; 40% YoY total asset growth; adjusted EBITDA of $1.05B in 2025 (Q4 2025 earnings release); 2026 guidance issued January 30, 2026
Entity Profile — Key Attributes
| Attribute | Value |
|---|---|
| Legal Name | SoFi Technologies, Inc. |
| HQ | 234 1st Street, San Francisco, CA 94105 |
| Founded | 2011 (as Social Finance, Inc.); public 2021 via merger with Social Capital Hedosophia Holdings Corp. V |
| CIK (SEC) | 0001818874 |
| NASDAQ Ticker | SOFI |
| Shares Outstanding (Jan 30, 2026) | 1,275,263,850 shares (common stock, $0.0001 par) |
| Market Value Held by Non-Affiliates (June 30, 2025) | ~$20.0 billion (per 10-K cover) |
| Bank Charter | SoFi Bank, National Association — OCC-chartered national bank; conditionally approved January 18, 2022; merger closed February 2022; charter no. 20862; HQ 2750 East Cottonwood Parkway, Cottonwood Heights, UT (OCC national bank list, active as of August 31, 2026) |
| Bank Holding Company | Yes — regulated by the Federal Reserve under the BHCA; financial holding company elected under §4(l) |
| CFPB Supervision | SoFi Bank and its affiliates subject to CFPB supervision and examination from January 1, 2024 |
| Total Assets | $50.7 billion (Dec 31, 2025) |
| Total Deposits | $37.5 billion (Dec 31, 2025) |
| Total Net Revenue (FY2025) | $3.6 billion (+35% YoY) |
| Net Income (FY2025) | $481.3 million |
| Members | 13.7 million (Dec 31, 2025, +35% YoY) |
| Products | 20.2 million (Dec 31, 2025, +37% YoY) |
| Tech Platform Accounts | 128.5 million (Dec 31, 2025; 167.7 million a year earlier) |
| Employees | ~6,100 (Dec 31, 2025; ~82% US, ~18% international) |
| Three Business Segments | Lending ($1.85B net revenue); Financial Services ($1.54B, +88% YoY); Technology Platform ($450.2M, +14% YoY) |
| CEO | Anthony Noto (age 57) |
| CFO | Chris Lapointe |
| CRO | Arun Pinto (since February 2024) |
| General Counsel | Rob Lavet |
| CTO | Jeremy Rishel |
| Board Chair | Tom Hutton (independent; separate from CEO) |
| Auditor | Deloitte & Touche LLP (since 2017) |
| Key Subsidiaries | SoFi Bank, N.A.; SoFi Securities LLC (CRD 151717); SoFi Wealth LLC (SEC-registered adviser); Galileo Financial Technologies; Technisys S.A. (Luxembourg); Wyndham Capital Mortgage (acquired 2023); SoFi Holdings (Hong Kong) Limited. SoFi Digital Assets LLC's legacy crypto structure was discontinued in 2023 and its accounts closed by Q1 2024. |
| RuleboardAI Classification | Type 7 National Bank/BHC (Primary) + Type 4 Broker-Dealer + Type 5 RIA + Type 16 Fintech Platform (Secondary) |
Attribute
Legal Name
Value
SoFi Technologies, Inc.
Attribute
HQ
Value
234 1st Street, San Francisco, CA 94105
Attribute
Founded
Value
2011 (as Social Finance, Inc.); public 2021 via merger with Social Capital Hedosophia Holdings Corp. V
Attribute
CIK (SEC)
Value
0001818874
Attribute
NASDAQ Ticker
Value
SOFI
Attribute
Shares Outstanding (Jan 30, 2026)
Value
1,275,263,850 shares (common stock, $0.0001 par)
Attribute
Market Value Held by Non-Affiliates (June 30, 2025)
Value
~$20.0 billion (per 10-K cover)
Attribute
Bank Charter
Value
SoFi Bank, National Association — OCC-chartered national bank; conditionally approved January 18, 2022; merger closed February 2022; charter no. 20862; HQ 2750 East Cottonwood Parkway, Cottonwood Heights, UT (OCC national bank list, active as of August 31, 2026)
Attribute
Bank Holding Company
Value
Yes — regulated by the Federal Reserve under the BHCA; financial holding company elected under §4(l)
Attribute
CFPB Supervision
Value
SoFi Bank and its affiliates subject to CFPB supervision and examination from January 1, 2024
Attribute
Total Assets
Value
$50.7 billion (Dec 31, 2025)
Attribute
Total Deposits
Value
$37.5 billion (Dec 31, 2025)
Attribute
Total Net Revenue (FY2025)
Value
$3.6 billion (+35% YoY)
Attribute
Net Income (FY2025)
Value
$481.3 million
Attribute
Members
Value
13.7 million (Dec 31, 2025, +35% YoY)
Attribute
Products
Value
20.2 million (Dec 31, 2025, +37% YoY)
Attribute
Tech Platform Accounts
Value
128.5 million (Dec 31, 2025; 167.7 million a year earlier)
Attribute
Employees
Value
~6,100 (Dec 31, 2025; ~82% US, ~18% international)
Attribute
Three Business Segments
Value
Lending ($1.85B net revenue); Financial Services ($1.54B, +88% YoY); Technology Platform ($450.2M, +14% YoY)
Attribute
CEO
Value
Anthony Noto (age 57)
Attribute
CFO
Value
Chris Lapointe
Attribute
CRO
Value
Arun Pinto (since February 2024)
Attribute
General Counsel
Value
Rob Lavet
Attribute
CTO
Value
Jeremy Rishel
Attribute
Board Chair
Value
Tom Hutton (independent; separate from CEO)
Attribute
Auditor
Value
Deloitte & Touche LLP (since 2017)
Attribute
Key Subsidiaries
Value
SoFi Bank, N.A.; SoFi Securities LLC (CRD 151717); SoFi Wealth LLC (SEC-registered adviser); Galileo Financial Technologies; Technisys S.A. (Luxembourg); Wyndham Capital Mortgage (acquired 2023); SoFi Holdings (Hong Kong) Limited. SoFi Digital Assets LLC's legacy crypto structure was discontinued in 2023 and its accounts closed by Q1 2024.
Attribute
RuleboardAI Classification
Value
Type 7 National Bank/BHC (Primary) + Type 4 Broker-Dealer + Type 5 RIA + Type 16 Fintech Platform (Secondary)
3. Workflow Scope Determination
All applicable regulatory workflows evaluated, within the U.S. institution types the engine covers. Status: In Scope (confirmed applicable), Conditional (depends on trigger/confirmation), Suppressed (not applicable, with rationale).
Category 1 — SOC 2 Compliance
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 1.1 | Control Inventory Audit | In Scope | 10-K states SOC 2 applies to or is maintained by certain solutions; scope by entity and system is not public |
| 1.2 | Evidence Collection Checklist | In Scope | SOC 2 maintained for certain solutions per 10-K; Galileo/Technisys B2B clients are the likely drivers |
| 1.3 | Gap Analysis Report | In Scope | Referenced frameworks (NIST CSF, ISO 27002, FFIEC) confirm gap analysis applicability |
| 1.4 | Vendor Risk Assessment | In Scope | Third-Party Security Risk Management program confirmed in 10-K Item 1C |
| 1.5 | Penetration Test Review Memo | In Scope | Internal and external penetration tests confirmed per 10-K Item 1C |
#
1.1
Workflow
Control Inventory Audit
Status
In Scope
Trigger / Rationale
10-K states SOC 2 applies to or is maintained by certain solutions; scope by entity and system is not public
#
1.2
Workflow
Evidence Collection Checklist
Status
In Scope
Trigger / Rationale
SOC 2 maintained for certain solutions per 10-K; Galileo/Technisys B2B clients are the likely drivers
#
1.3
Workflow
Gap Analysis Report
Status
In Scope
Trigger / Rationale
Referenced frameworks (NIST CSF, ISO 27002, FFIEC) confirm gap analysis applicability
#
1.4
Workflow
Vendor Risk Assessment
Status
In Scope
Trigger / Rationale
Third-Party Security Risk Management program confirmed in 10-K Item 1C
#
1.5
Workflow
Penetration Test Review Memo
Status
In Scope
Trigger / Rationale
Internal and external penetration tests confirmed per 10-K Item 1C
Category 2 — Financial Regulation
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 2.1 | Capital Adequacy Report | In Scope | OCC and Federal Reserve capital requirements confirmed; SoFi Bank well capitalized at December 31, 2025 |
| 2.2 | AML Transaction Monitoring | In Scope | BSA/AML obligations confirmed for SoFi Bank N.A. and affiliates; FinCEN investment adviser AML rule (effective January 1, 2028, under review) will apply to SoFi Wealth LLC |
| 2.3 | SAR Draft | In Scope | SoFi Bank SAR filing obligations under 31 CFR 1020.320; prior FINRA CIP/ITPP action heightens materiality |
| 2.4 | SEC Filing Readiness Check | In Scope | Public reporting company (10-K, 10-Q, 8-K, proxy); SoFi Wealth files Form ADV |
| 2.5 | KYC Onboarding Audit | In Scope | FINRA $1.1M CIP/ITPP action (May 2024) for December 2018–April 2019 conduct confirms a demonstrated gap area; high priority |
#
2.1
Workflow
Capital Adequacy Report
Status
In Scope
Trigger / Rationale
OCC and Federal Reserve capital requirements confirmed; SoFi Bank well capitalized at December 31, 2025
#
2.2
Workflow
AML Transaction Monitoring
Status
In Scope
Trigger / Rationale
BSA/AML obligations confirmed for SoFi Bank N.A. and affiliates; FinCEN investment adviser AML rule (effective January 1, 2028, under review) will apply to SoFi Wealth LLC
#
2.3
Workflow
SAR Draft
Status
In Scope
Trigger / Rationale
SoFi Bank SAR filing obligations under 31 CFR 1020.320; prior FINRA CIP/ITPP action heightens materiality
#
2.4
Workflow
SEC Filing Readiness Check
Status
In Scope
Trigger / Rationale
Public reporting company (10-K, 10-Q, 8-K, proxy); SoFi Wealth files Form ADV
#
2.5
Workflow
KYC Onboarding Audit
Status
In Scope
Trigger / Rationale
FINRA $1.1M CIP/ITPP action (May 2024) for December 2018–April 2019 conduct confirms a demonstrated gap area; high priority
Category 3 — International Frameworks (DORA / ISO 27001 / BCP)
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 3.1 | DORA ICT Risk Assessment | Conditional | Technisys S.A. (Luxembourg) may serve EU-regulated entities; Unresolved from public sources |
| 3.2 | ISO 27001 Gap Report | In Scope | ISO 27002:2013 referenced in 10-K; ISO 27001 certification status not public |
| 3.3 | BCP Review | In Scope | OCC and FFIEC business continuity expectations apply to SoFi Bank; documentation not public |
| 3.4 | IR Playbook Audit | In Scope | SEC cyber incident disclosure (Reg S-K Item 106) applies; GDPR Art. 33 conditional |
| 3.5 | Data Residency Check | Conditional | Operations in Latin America, Canada, Switzerland and Hong Kong may implicate local data residency rules; Unresolved |
#
3.1
Workflow
DORA ICT Risk Assessment
Status
Conditional
Trigger / Rationale
Technisys S.A. (Luxembourg) may serve EU-regulated entities; Unresolved from public sources
#
3.2
Workflow
ISO 27001 Gap Report
Status
In Scope
Trigger / Rationale
ISO 27002:2013 referenced in 10-K; ISO 27001 certification status not public
#
3.3
Workflow
BCP Review
Status
In Scope
Trigger / Rationale
OCC and FFIEC business continuity expectations apply to SoFi Bank; documentation not public
#
3.4
Workflow
IR Playbook Audit
Status
In Scope
Trigger / Rationale
SEC cyber incident disclosure (Reg S-K Item 106) applies; GDPR Art. 33 conditional
#
3.5
Workflow
Data Residency Check
Status
Conditional
Trigger / Rationale
Operations in Latin America, Canada, Switzerland and Hong Kong may implicate local data residency rules; Unresolved
Category 4 — Internal Governance
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 4.1 | Policy Library Review | In Scope | Securities Trading and Section 16 Compliance Policy filed (Ex-19.1); full policy library not public |
| 4.2 | Board Risk Report | In Scope | Risk Committee (min. three members, meets at least four times a year; met six times in 2025) receives quarterly cybersecurity updates from the CISO |
| 4.3 | Control Testing Schedule | In Scope | Internal audit conducts annual IS/IT audits per 10-K Item 1C |
| 4.4 | Remediation Tracker | In Scope | Three settled actions (FTC 2019, SEC 2021, FINRA 2024) confirm the need for ongoing remediation tracking |
| 4.5 | Audit Committee Prep Pack | In Scope | Audit Committee chaired by Gary Meltzer; Deloitte & Touche LLP auditor; met seven times in 2025 |
#
4.1
Workflow
Policy Library Review
Status
In Scope
Trigger / Rationale
Securities Trading and Section 16 Compliance Policy filed (Ex-19.1); full policy library not public
#
4.2
Workflow
Board Risk Report
Status
In Scope
Trigger / Rationale
Risk Committee (min. three members, meets at least four times a year; met six times in 2025) receives quarterly cybersecurity updates from the CISO
#
4.3
Workflow
Control Testing Schedule
Status
In Scope
Trigger / Rationale
Internal audit conducts annual IS/IT audits per 10-K Item 1C
#
4.4
Workflow
Remediation Tracker
Status
In Scope
Trigger / Rationale
Three settled actions (FTC 2019, SEC 2021, FINRA 2024) confirm the need for ongoing remediation tracking
#
4.5
Workflow
Audit Committee Prep Pack
Status
In Scope
Trigger / Rationale
Audit Committee chaired by Gary Meltzer; Deloitte & Touche LLP auditor; met seven times in 2025
Category 5 — Ongoing / Scheduled
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 5.1 | Regulatory Change Impact Review | In Scope | OCC proposed $50B→$700B heightened-standards change (Dec 2025); CFPB supervision active; FinCEN adviser AML rule (2028, under review); GENIUS Act implementation; crypto guidance evolving |
| 5.2 | Vendor Renewal Risk Flag | In Scope | Third-party program includes contract review; 2025 Galileo client exit underscores concentration monitoring |
| 5.3 | Training Compliance Tracker | In Scope | Cybersecurity awareness training on hire and periodically, including phishing campaigns (10-K Item 1C); completion tracking not public |
| 5.4 | Access Review Report | In Scope | ISO 27002 and FFIEC expectations apply; access review details not public |
#
5.1
Workflow
Regulatory Change Impact Review
Status
In Scope
Trigger / Rationale
OCC proposed $50B→$700B heightened-standards change (Dec 2025); CFPB supervision active; FinCEN adviser AML rule (2028, under review); GENIUS Act implementation; crypto guidance evolving
#
5.2
Workflow
Vendor Renewal Risk Flag
Status
In Scope
Trigger / Rationale
Third-party program includes contract review; 2025 Galileo client exit underscores concentration monitoring
#
5.3
Workflow
Training Compliance Tracker
Status
In Scope
Trigger / Rationale
Cybersecurity awareness training on hire and periodically, including phishing campaigns (10-K Item 1C); completion tracking not public
#
5.4
Workflow
Access Review Report
Status
In Scope
Trigger / Rationale
ISO 27002 and FFIEC expectations apply; access review details not public
Category 6 — Privacy & Data Protection
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 6.1 | GDPR Compliance Audit | Conditional | 10-K: GDPR obligations arise if services are offered into the EU/UK; Unresolved whether they are |
| 6.2 | CCPA DSR Tracker | In Scope | SoFi serves California consumers at scale; CCPA/CPRA cited in 10-K |
| 6.3 | Data Retention Policy Review | In Scope | SEC recordkeeping (17a-3/17a-4) applies to SoFi Securities; BSA recordkeeping applies to SoFi Bank |
| 6.4 | Privacy Impact Assessment | Conditional | SoFi Crypto (November 2025) and SoFiUSD (December 2025) involve new data processing; assessment status not public |
#
6.1
Workflow
GDPR Compliance Audit
Status
Conditional
Trigger / Rationale
10-K: GDPR obligations arise if services are offered into the EU/UK; Unresolved whether they are
#
6.2
Workflow
CCPA DSR Tracker
Status
In Scope
Trigger / Rationale
SoFi serves California consumers at scale; CCPA/CPRA cited in 10-K
#
6.3
Workflow
Data Retention Policy Review
Status
In Scope
Trigger / Rationale
SEC recordkeeping (17a-3/17a-4) applies to SoFi Securities; BSA recordkeeping applies to SoFi Bank
#
6.4
Workflow
Privacy Impact Assessment
Status
Conditional
Trigger / Rationale
SoFi Crypto (November 2025) and SoFiUSD (December 2025) involve new data processing; assessment status not public
Category 7 — Cybersecurity
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 7.1 | Vulnerability Management Review | In Scope | ISO 27002 and NIST CSF confirmed in 10-K; penetration testing confirmed; scan cadence not public |
| 7.2 | Security Awareness Training | In Scope | Phishing training campaigns confirmed in 10-K Item 1C |
| 7.3 | Endpoint Security Audit | In Scope | FFIEC and NIST CSF scope confirmed; EDR coverage not public |
| 7.4 | Zero Trust Architecture Gap | Conditional | NIST SP 800-207 not cited; posture not publicly assessable |
#
7.1
Workflow
Vulnerability Management Review
Status
In Scope
Trigger / Rationale
ISO 27002 and NIST CSF confirmed in 10-K; penetration testing confirmed; scan cadence not public
#
7.2
Workflow
Security Awareness Training
Status
In Scope
Trigger / Rationale
Phishing training campaigns confirmed in 10-K Item 1C
#
7.3
Workflow
Endpoint Security Audit
Status
In Scope
Trigger / Rationale
FFIEC and NIST CSF scope confirmed; EDR coverage not public
#
7.4
Workflow
Zero Trust Architecture Gap
Status
Conditional
Trigger / Rationale
NIST SP 800-207 not cited; posture not publicly assessable
Category 8 — HR & People Risk
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 8.1 | Background Check Compliance | In Scope | FINRA registration requirements for SoFi Securities personnel; bank officer standards for SoFi Bank |
| 8.2 | Insider Threat Policy Review | In Scope | Securities Trading and Section 16 Compliance Policy filed (Ex-19.1); SEC Rule 204A-1 code of ethics (SoFi Wealth) |
| 8.3 | Offboarding Access Revocation | In Scope | Standard expectation for a bank-regulated entity; details not public |
| 8.4 | Whistleblower Program Assessment | In Scope | SEC whistleblower program (Exchange Act §21F) applies to a public company; internal program details not public |
#
8.1
Workflow
Background Check Compliance
Status
In Scope
Trigger / Rationale
FINRA registration requirements for SoFi Securities personnel; bank officer standards for SoFi Bank
#
8.2
Workflow
Insider Threat Policy Review
Status
In Scope
Trigger / Rationale
Securities Trading and Section 16 Compliance Policy filed (Ex-19.1); SEC Rule 204A-1 code of ethics (SoFi Wealth)
#
8.3
Workflow
Offboarding Access Revocation
Status
In Scope
Trigger / Rationale
Standard expectation for a bank-regulated entity; details not public
#
8.4
Workflow
Whistleblower Program Assessment
Status
In Scope
Trigger / Rationale
SEC whistleblower program (Exchange Act §21F) applies to a public company; internal program details not public
Category 9 — Third-Party / Supply Chain Risk
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 9.1 | Vendor Onboarding Due Diligence | In Scope | Risk-based due diligence during supplier onboarding confirmed in 10-K Item 1C |
| 9.2 | Ongoing Vendor Monitoring | In Scope | Ongoing monitoring, assessment and contract review confirmed in 10-K Item 1C |
| 9.3 | Concentration Risk Assessment | In Scope | A large Galileo client fully transitioned off in 2025; accounts fell 23% (10-K, Q4 2025 release) |
| 9.4 | Vendor Exit & Termination Plan | In Scope | The 2025 client exit demonstrates the need; exit plan details not public |
#
9.1
Workflow
Vendor Onboarding Due Diligence
Status
In Scope
Trigger / Rationale
Risk-based due diligence during supplier onboarding confirmed in 10-K Item 1C
#
9.2
Workflow
Ongoing Vendor Monitoring
Status
In Scope
Trigger / Rationale
Ongoing monitoring, assessment and contract review confirmed in 10-K Item 1C
#
9.3
Workflow
Concentration Risk Assessment
Status
In Scope
Trigger / Rationale
A large Galileo client fully transitioned off in 2025; accounts fell 23% (10-K, Q4 2025 release)
#
9.4
Workflow
Vendor Exit & Termination Plan
Status
In Scope
Trigger / Rationale
The 2025 client exit demonstrates the need; exit plan details not public
Category 10 — ESG / Non-Financial Reporting
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 10.1 | ESG Program Readiness | In Scope | Third comprehensive ESG report published 2025 per 10-K; content not reviewed in this pass |
| 10.2 | Climate / TCFD Disclosure | Conditional | 10-K references climate-related commitments in the ESG report; SEC climate rules stayed since April 2024 with rescission proposed May 2026, so no active federal filing obligation |
| 10.3 | SFDR Classification Review | Suppressed | No EU-distributed investment products confirmed |
| 10.4 | CSRD / ESRS Reporting Assessment | Suppressed | No EU subsidiary triggering CSRD confirmed |
#
10.1
Workflow
ESG Program Readiness
Status
In Scope
Trigger / Rationale
Third comprehensive ESG report published 2025 per 10-K; content not reviewed in this pass
#
10.2
Workflow
Climate / TCFD Disclosure
Status
Conditional
Trigger / Rationale
10-K references climate-related commitments in the ESG report; SEC climate rules stayed since April 2024 with rescission proposed May 2026, so no active federal filing obligation
#
10.3
Workflow
SFDR Classification Review
Status
Suppressed
Trigger / Rationale
No EU-distributed investment products confirmed
#
10.4
Workflow
CSRD / ESRS Reporting Assessment
Status
Suppressed
Trigger / Rationale
No EU subsidiary triggering CSRD confirmed
Category 11 — Operational Risk
| # | Workflow | Status | Trigger / Rationale |
|---|---|---|---|
| 11.1 | Operational Risk Register Review | In Scope | Enterprise Risk Management program referenced in 10-K; details not public |
| 11.2 | DR Gap Report | In Scope | FFIEC business continuity expectations apply; DR documentation not public |
| 11.3 | BCP Test & Exercise Review | In Scope | OCC heightened-standards implications at $50.7B; exercise results not public |
| 11.4 | Process Resilience & Outsourcing Review | In Scope | Galileo provides technology infrastructure to SoFi and to third parties; dual exposure confirmed |
#
11.1
Workflow
Operational Risk Register Review
Status
In Scope
Trigger / Rationale
Enterprise Risk Management program referenced in 10-K; details not public
#
11.2
Workflow
DR Gap Report
Status
In Scope
Trigger / Rationale
FFIEC business continuity expectations apply; DR documentation not public
#
11.3
Workflow
BCP Test & Exercise Review
Status
In Scope
Trigger / Rationale
OCC heightened-standards implications at $50.7B; exercise results not public
#
11.4
Workflow
Process Resilience & Outsourcing Review
Status
In Scope
Trigger / Rationale
Galileo provides technology infrastructure to SoFi and to third parties; dual exposure confirmed
3B. Detailed Workflow Assessment — Selected In-Scope / Conditional Workflows
2.5 | KYC Onboarding Audit In Scope
Objective: Verify that SoFi's customer identification program (CIP) and identity theft prevention program (ITPP) meet BSA and FinCEN requirements across all regulated subsidiaries.
Frameworks: 31 CFR 1023.220 (broker-dealer CIP); 31 CFR 1020.220 and 1010.230 (bank CIP and CDD); FINRA Rule 3310; Regulation S-ID (17 CFR 248.201).
Observation: FINRA censured and fined SoFi Securities LLC $1.1 million on May 2, 2024 (AWC No. 2019062705801) for failing to establish and maintain a reasonable CIP and a reasonably designed ITPP for SoFi Money cash management accounts from December 2018 through April 2019. Approximately 800 accounts were opened using stolen or fictitious identities; about $8.6 million was transferred from customers of other institutions and about $2.5 million withdrawn; all injured parties were reimbursed. The largely automated approval process did not act on red flags such as invalid or mismatched Social Security numbers and addresses. SoFi self-reported the matter and undertook remediation beginning in February 2019, and closed SoFi Money to new customers in June 2022. Post-remediation program quality cannot be confirmed from public sources.
Next Action: Obtain current CIP/ITPP policy documentation and evidence of post-2019 program enhancements; validate current fraud-alert metrics against BSA examination standards.
2.2 | AML Transaction Monitoring In Scope
Objective: Confirm existence and adequacy of the BSA/AML transaction monitoring program at SoFi Bank, N.A.
Frameworks: Bank Secrecy Act (31 U.S.C. 5318); 31 CFR 1020.210; 12 CFR 21.21; FFIEC BSA/AML Examination Manual; FinCEN investment adviser AML rule (31 CFR Part 1032, effective January 1, 2028, under review).
Observation: SoFi Bank is subject to full BSA/AML program requirements as a national bank, and the 10-K acknowledges those obligations. No public enforcement action by FinCEN or the OCC on the AML program was found. With $37.5B in deposits, 13.7M members, crypto and stablecoin activity at the bank, and cross-border Technology Platform clients, transaction volume and complexity are material. FinCEN's investment adviser AML rule, delayed to January 1, 2028 and under review, would extend program obligations to SoFi Wealth LLC.
Next Action: Request BSA/AML program documentation, transaction monitoring system details, SAR filing statistics (if disclosable), and the BSA Officer's assessment of crypto-related controls.
9.3 | Concentration Risk Assessment In Scope
Objective: Assess client and vendor concentration risk in SoFi's Technology Platform segment.
Frameworks: OCC Bulletin 2023-17 (Interagency Guidance on Third-Party Relationships); FFIEC IT Handbook; DORA (Conditional for a U.S. entity); internal ERM.
Observation: In 2025 a large Galileo client fully transitioned off the platform, and Technology Platform total accounts fell from 167.7 million to 128.5 million, a 23% decline, per the 10-K and the Q4 2025 earnings release. The concentration of revenue from a small number of clients is a risk the 10-K itself identifies. Client identity, contractual terms and the concentration risk management framework are not public.
Next Action: Request client concentration analysis for the Technology Platform; review third-party risk management documentation; validate exit and termination planning per 9.4.
4. Detailed Risk Findings + Strategic Alternatives
F-001 | KYC / CIP Program — Prior Enforcement + Evolving Obligations
HIGHConfidence: Confirmed (public enforcement record); Conditional (post-remediation status)
Regulatory Citation: FINRA AWC No. 2019062705801 (May 2, 2024); FINRA Rule 3310(b); Regulation S-ID Rule 201 (17 CFR 248.201); 31 U.S.C. 5318; 31 CFR 1010.230; FinCEN investment adviser AML rule (31 CFR Part 1032; effective January 1, 2028, under review)
FINRA censured and fined SoFi Securities LLC $1.1 million on May 2, 2024 for failing to maintain a reasonable CIP and a reasonably designed ITPP for SoFi Money cash management accounts from December 2018 through April 2019. Approximately 800 accounts were opened with stolen or fictitious identities; about $8.6 million was transferred from other institutions' customers and about $2.5 million withdrawn; all injured parties were reimbursed. Separately, FinCEN's investment adviser AML rule, delayed to January 1, 2028 and under review, would require SoFi Wealth LLC to implement an AML/CFT program.
Data gap / current gap: Post-remediation CIP/ITPP documentation and testing results are not confirmable from public sources. The adviser AML program for SoFi Wealth LLC is not yet required; planning status is not public.
Remediation: Obtain CIP/ITPP program documentation; conduct a gap assessment against current FFIEC and FinCEN standards; track the adviser AML rule and design SoFi Wealth's program for the effective date.
Owner: Chief Risk Officer; BSA/AML Officer
Deadline: Adviser AML rule: January 1, 2028 (under review); CIP validation: next examination cycle
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | Enhance BSA/Compliance team | Owner: CRO + BSA Officer; internal AML program refresh and adviser AML readiness assessment. Est. Lift: Medium |
| Option 2 — Vendor | Engage AML regulatory consulting firm | Pros: specialized expertise; benchmarking against banks at similar scale. Cons: cost; integration with existing transaction monitoring. |
| Option 3 — Risk Acceptance | Accept residual gap for pre-2028 adviser AML | Viable when: only for the adviser rule timeline; not viable for bank CIP obligations. Approval: CRO + General Counsel |
Option
Option 1 — Internal
Action
Enhance BSA/Compliance team
Details
Owner: CRO + BSA Officer; internal AML program refresh and adviser AML readiness assessment. Est. Lift: Medium
Option
Option 2 — Vendor
Action
Engage AML regulatory consulting firm
Details
Pros: specialized expertise; benchmarking against banks at similar scale. Cons: cost; integration with existing transaction monitoring.
Option
Option 3 — Risk Acceptance
Action
Accept residual gap for pre-2028 adviser AML
Details
Viable when: only for the adviser rule timeline; not viable for bank CIP obligations. Approval: CRO + General Counsel
F-002 | CFPB Supervision — Commenced January 1, 2024
HIGHConfidence: Confirmed
Regulatory Citation: 12 U.S.C. 5515 (Dodd-Frank §1025); 12 U.S.C. 5531 (UDAAP); CFPB Supervision and Examination Manual
The FY2025 10-K states that beginning January 1, 2024 SoFi Bank and its affiliates became subject to supervision and examination by the CFPB; 12 U.S.C. 5515 assigns that authority for insured depository institutions with more than $10 billion in total assets. This is a structural change in supervisory regime: as of this report date the CFPB has held examination authority for approximately 33 months.
Data gap / current gap: The outcome of any CFPB examination since January 1, 2024 is not public. UDAAP compliance posture under CFPB examination cannot be confirmed from public sources. The FTC consent order (in force to 2039) on advertising savings claims may inform examination scope.
Remediation: Engage counsel to review CFPB examination findings to date; conduct a UDAAP self-assessment across consumer-facing products; review advertising claims against the FTC order.
Owner: General Counsel; Chief Compliance Officer
Deadline: Ongoing; examination cycles under way since 2024
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | UDAAP self-assessment | Owner: Compliance; map consumer-facing product flows to CFPB examination priorities. Est. Lift: Medium |
| Option 2 — Vendor | Engage CFPB-specialized regulatory counsel | Pros: examination knowledge. Cons: cost; coordination across member-facing products. |
| Option 3 — Risk Acceptance | Not viable | CFPB supervision applies by statute above $10B in assets. Approval: N/A |
Option
Option 1 — Internal
Action
UDAAP self-assessment
Details
Owner: Compliance; map consumer-facing product flows to CFPB examination priorities. Est. Lift: Medium
Option
Option 2 — Vendor
Action
Engage CFPB-specialized regulatory counsel
Details
Pros: examination knowledge. Cons: cost; coordination across member-facing products.
Option
Option 3 — Risk Acceptance
Action
Not viable
Details
CFPB supervision applies by statute above $10B in assets. Approval: N/A
F-003 | FTC Consent Order — In Force Until 2039
MEDIUMConfidence: Confirmed
Regulatory Citation: FTC Docket No. C-4673, Decision and Order (February 2019); In re Social Finance, Inc. and SoFi Lending Corp.; FTC Act §5 (15 U.S.C. 45)
The FTC approved a final consent order against Social Finance, Inc. and SoFi Lending Corp. in February 2019. The complaint alleged that since April 2016 SoFi's television, print and internet advertisements made false statements about student loan refinancing savings, with average-savings figures that excluded large categories of consumers and were sometimes double the actual figure. The order prohibits misrepresenting savings and requires that savings claims be substantiated by competent and reliable evidence. It terminates on February 22, 2039, or 20 years from the most recent federal complaint alleging a violation, whichever is later.
Data gap / current gap: Ongoing compliance with the order is not publicly verified. The order required a sworn compliance report one year after issuance and further reports on request; whether any were requested is not public.
Remediation: Confirm an advertising substantiation review process tied to the order; retain the records the order requires for ten years after issuance.
Owner: General Counsel; Chief Marketing Officer
Deadline: Ongoing through 2039
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | Advertising compliance review program | Owner: Legal + Marketing; periodic review of savings-related claims against the order. Est. Lift: Low |
| Option 2 — Vendor | Engage advertising law specialist | Pros: FTC substantiation expertise. Cons: cost; capability likely already built after seven years under the order. |
| Option 3 — Risk Acceptance | Accept residual compliance management risk | Viable when: base program already established. Approval: General Counsel |
Option
Option 1 — Internal
Action
Advertising compliance review program
Details
Owner: Legal + Marketing; periodic review of savings-related claims against the order. Est. Lift: Low
Option
Option 2 — Vendor
Action
Engage advertising law specialist
Details
Pros: FTC substantiation expertise. Cons: cost; capability likely already built after seven years under the order.
Option
Option 3 — Risk Acceptance
Action
Accept residual compliance management risk
Details
Viable when: base program already established. Approval: General Counsel
F-004 | SEC Conflict-of-Interest Order — SoFi Wealth LLC (2021)
MEDIUMConfidence: Confirmed
Regulatory Citation: SEC Investment Advisers Act Release No. 5826 (August 19, 2021); Advisers Act §206(2) and §206(4) (15 U.S.C. 80b-6); Rule 206(4)-7 (17 CFR 275.206(4)-7)
The SEC instituted settled charges against SoFi Wealth LLC on August 19, 2021 for breaching its fiduciary duty when, on April 12, 2019, it moved assets in approximately 20,000 automated accounts from third-party ETFs into two new SoFi-sponsored ETFs (SFY and SFYX) without disclosing SoFi's economic interest, and without considering tax consequences (over 15,000 clients incurred about $772,000 in short-term and $662,000 in long-term capital gains). SoFi Wealth agreed to a cease-and-desist order, a censure, a $300,000 penalty and undertakings, without admitting or denying the findings.
Data gap / current gap: Completion of the undertakings and current conflict-disclosure practice at SoFi Wealth are not publicly verifiable.
Remediation: Confirm the undertakings were certified as complete; review current conflict-of-interest disclosures against the fiduciary standard; verify no recurrence in later product rollouts, including SoFi Crypto and SoFiUSD.
Owner: SoFi Wealth Chief Compliance Officer; General Counsel
Deadline: Order compliance ongoing; crypto-related conflict review: immediate
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | Conflict review for new products | Owner: SoFi Wealth CCO; pre-launch conflict review for all new products. Est. Lift: Low |
| Option 2 — Vendor | Third-party adviser compliance consultant | Pros: independent review of Form ADV disclosures and conflicts policy. Cons: limited marginal value if already enhanced. |
| Option 3 — Risk Acceptance | Accept residual compliance management risk | Viable when: undertakings confirmed complete. Approval: General Counsel |
Option
Option 1 — Internal
Action
Conflict review for new products
Details
Owner: SoFi Wealth CCO; pre-launch conflict review for all new products. Est. Lift: Low
Option
Option 2 — Vendor
Action
Third-party adviser compliance consultant
Details
Pros: independent review of Form ADV disclosures and conflicts policy. Cons: limited marginal value if already enhanced.
Option
Option 3 — Risk Acceptance
Action
Accept residual compliance management risk
Details
Viable when: undertakings confirmed complete. Approval: General Counsel
F-005 | $50 Billion Asset Threshold — OCC Heightened Standards
HIGHConfidence: Confirmed (threshold crossed); Conditional (outcome of OCC rulemaking)
Regulatory Citation: 12 CFR Part 30, Appendix D; Dodd-Frank §165 (12 U.S.C. 5365); OCC NR 2025-134 (December 23, 2025), proposed amendment raising the threshold from $50 billion to $700 billion
At December 31, 2025 SoFi reported total assets of $50.7 billion, above the current $50 billion threshold at which the OCC's heightened standards guidelines apply to national banks. On December 23, 2025 the OCC proposed raising that threshold to $700 billion. The proposal is not final. Until it is, the current threshold governs.
Data gap / current gap: SoFi Bank's status under the current heightened standards guidelines is not public. The timing and outcome of the OCC rulemaking are not known.
Remediation: Track the OCC rulemaking; assess current obligations under Appendix D with regulatory counsel; document readiness for either outcome.
Owner: Chief Risk Officer; General Counsel
Deadline: OCC rulemaking (timing not known); interim: immediate counsel review
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | Regulatory tracking and threshold readiness | Owner: CRO + Legal; track the rulemaking and maintain readiness materials. Est. Lift: Low |
| Option 2 — Vendor | Engage OCC-specialized bank regulatory counsel | Pros: rulemaking intelligence; Appendix D applicability assessment. Cons: cost. |
| Option 3 — Risk Acceptance | Await regulatory clarity | Viable when: the proposal advances; monitor before committing to a full program build. Approval: CRO |
Option
Option 1 — Internal
Action
Regulatory tracking and threshold readiness
Details
Owner: CRO + Legal; track the rulemaking and maintain readiness materials. Est. Lift: Low
Option
Option 2 — Vendor
Action
Engage OCC-specialized bank regulatory counsel
Details
Pros: rulemaking intelligence; Appendix D applicability assessment. Cons: cost.
Option
Option 3 — Risk Acceptance
Action
Await regulatory clarity
Details
Viable when: the proposal advances; monitor before committing to a full program build. Approval: CRO
F-006 | Technology Platform Concentration Risk — Galileo Client Exit
MEDIUMConfidence: Confirmed
Regulatory Citation: OCC Bulletin 2023-17 (Interagency Guidance on Third-Party Relationships); FFIEC IT Handbook
In 2025 a large Galileo client fully transitioned off the Technology Platform, and total accounts fell from 167.7 million to 128.5 million, a 23% decline, per the FY2025 10-K and the Q4 2025 earnings release. The 10-K states that Galileo and Technisys depend on a small number of clients. This is a confirmed public signal of single-client concentration risk in the B2B infrastructure business.
Data gap / current gap: Client concentration data, exit and termination plan details, and contractual protections are not public.
Remediation: Request client concentration analysis for the Technology Platform; review exit and termination plan documentation; assess diversification strategy.
Owner: Technology Platform business unit head; Chief Risk Officer
Deadline: Immediate
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | Client diversification and concentration monitoring | Owner: Galileo leadership; set concentration thresholds and monitor quarterly. Est. Lift: Medium |
| Option 2 — Vendor | Third-party business continuity review | Pros: independent assessment of resilience to large-client exits. Cons: client data sensitivity. |
| Option 3 — Risk Acceptance | Accept concentration as inherent to the platform model | Viable when: the platform is diversifying. Approval: CEO + Board Risk Committee |
Option
Option 1 — Internal
Action
Client diversification and concentration monitoring
Details
Owner: Galileo leadership; set concentration thresholds and monitor quarterly. Est. Lift: Medium
Option
Option 2 — Vendor
Action
Third-party business continuity review
Details
Pros: independent assessment of resilience to large-client exits. Cons: client data sensitivity.
Option
Option 3 — Risk Acceptance
Action
Accept concentration as inherent to the platform model
Details
Viable when: the platform is diversifying. Approval: CEO + Board Risk Committee
F-007 | SOC 2 Attestation — Scope Not Public
MEDIUMConfidence: Likely (attestation maintained for certain solutions); Conditional (scope)
Regulatory Citation: AICPA Trust Services Criteria; FFIEC IT Handbook; OCC Bulletin 2023-17
The FY2025 10-K states that PCI-DSS, AICPA standards and SOC 2 "apply to or are maintained by certain of our solutions" and that failure to maintain its SOC 2 could breach customer contracts; Item 1C adds that third-party attestations and assessments are conducted periodically. Galileo is the processing infrastructure for the B2B Technology Platform, whose institutional clients typically require SOC 2 Type II reports. Which entities and systems the attestation covers, its type and period, are not public.
Data gap / current gap: SOC 2 scope, report type and coverage of Galileo and SoFi Bank's core processing environment are not confirmable from public sources.
Remediation: Obtain the current SOC 2 report(s) and confirm scope against Galileo and SoFi Bank's critical control environment; scope additional examination if coverage gaps exist.
Owner: CISO; Galileo Head of Compliance
Deadline: 90 days (to confirm scope)
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | Scope confirmation with the existing service auditor | Owner: CISO + Internal Audit. Est. Lift: Medium |
| Option 2 — Vendor | Engage a specialist SOC 2 readiness firm for uncovered systems | Pros: faster gap-to-report timeline. Cons: cost; coordination with the existing auditor. |
| Option 3 — Risk Acceptance | Accept scope gap pending prioritization | Viable when: no contractual SOC 2 requirement is outstanding from B2B clients. Approval: CISO + CRO |
Option
Option 1 — Internal
Action
Scope confirmation with the existing service auditor
Details
Owner: CISO + Internal Audit. Est. Lift: Medium
Option
Option 2 — Vendor
Action
Engage a specialist SOC 2 readiness firm for uncovered systems
Details
Pros: faster gap-to-report timeline. Cons: cost; coordination with the existing auditor.
Option
Option 3 — Risk Acceptance
Action
Accept scope gap pending prioritization
Details
Viable when: no contractual SOC 2 requirement is outstanding from B2B clients. Approval: CISO + CRO
F-008 | ESG Reporting — Content Not Reviewed; Climate Rule Regime Unsettled
LOWConfidence: Confirmed (report exists); Conditional (content and framework alignment)
Regulatory Citation: SoFi FY2025 10-K (ESG report and climate-related commitments); SEC press release 2026-49 (May 29, 2026), proposed rescission of the climate-related disclosure rules
The FY2025 10-K states that SoFi published its third comprehensive ESG report in 2025 and communicates climate-related commitments and governance metrics in it. The report's content and any alignment to a recognized climate framework were not reviewed in this pass. The SEC's climate-related disclosure rules were stayed in April 2024, the Commission ended its defense of them in March 2025, and rescission was proposed on May 29, 2026; no federal climate filing obligation is treated as active.
Data gap / current gap: ESG report content, framework alignment and assurance status are Unresolved from this pass.
Remediation: Review the 2025 ESG report against the disclosure expectations of SoFi's investors and counterparties; track the SEC rescission rulemaking.
Owner: General Counsel; Chief Financial Officer
Deadline: Next ESG report cycle
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | ESG report review and roadmap | Owner: CFO + Legal. Est. Lift: Low |
| Option 2 — Vendor | Engage ESG advisory firm | Pros: framework selection and benchmarking. Cons: cost. |
| Option 3 — Risk Acceptance | Maintain current voluntary reporting | Viable when: no mandatory regime applies. Approval: CFO + General Counsel |
Option
Option 1 — Internal
Action
ESG report review and roadmap
Details
Owner: CFO + Legal. Est. Lift: Low
Option
Option 2 — Vendor
Action
Engage ESG advisory firm
Details
Pros: framework selection and benchmarking. Cons: cost.
Option
Option 3 — Risk Acceptance
Action
Maintain current voluntary reporting
Details
Viable when: no mandatory regime applies. Approval: CFO + General Counsel
F-009 | Crypto / Digital Asset Regulatory Position — SoFi Crypto + SoFiUSD
HIGHConfidence: Confirmed (product launches at SoFi Bank); Conditional (OCC non-objection status)
Regulatory Citation: OCC Conditional Approval No. 1277 (January 18, 2022), condition 3; 12 U.S.C. 1818 (conditions enforceable); GENIUS Act, Pub. L. 119-27 (July 2025); SoFi FY2025 10-K; SoFi releases of November 11 and December 18, 2025
SoFi Bank, N.A. launched SoFi Crypto on November 11, 2025 and SoFiUSD on December 18, 2025. SoFi's releases state that SoFi Crypto products and services are offered by SoFi Bank, N.A. and that SoFiUSD is issued by SoFi Bank, N.A.; the FY2025 10-K states that members buy, sell and hold digital assets through SoFi Bank, that SoFi Bank launched SoFiUSD in December 2025, and that SoFi Crypto is designed to operate within the company's current regulatory framework. Condition 3 of the OCC's 2022 conditional approval provides that, while the Operating Agreement is in effect, the bank "shall not engage in any crypto-asset activities or services ... unless it has received prior written determination of no supervisory objection from the OCC." The condition is therefore not an absolute bar. The 10-K also notes that under the GENIUS Act an insured depository institution such as SoFi Bank cannot itself be a permitted stablecoin issuer, while a qualifying subsidiary can with OCC approval.
Data gap / current gap: Whether SoFi Bank sought and obtained the OCC's prior written determination of no supervisory objection before the 2025 launches, and whether the Operating Agreement remains in effect, is not stated in the 10-K or the launch releases. The regulatory pathway for SoFiUSD once the GENIUS Act takes effect is not public. This is an open verification question, not a finding of non-compliance.
Remediation: Confirm the OCC non-objection status for SoFi Crypto and SoFiUSD and whether the Operating Agreement remains in effect; document the OCC, FinCEN and SEC position for both products and the GENIUS Act pathway for SoFiUSD.
Owner: General Counsel; Chief Risk Officer; SoFi Bank compliance lead for digital assets
Deadline: Immediate (verification of a charter condition)
Strategic Alternatives
| Option | Action | Details |
|---|---|---|
| Option 1 — Internal | OCC condition review | Owner: General Counsel; confirm non-objection status under the Operating Agreement. Est. Lift: Low–Medium |
| Option 2 — Vendor | Engage bank regulatory counsel with digital-asset experience | Pros: OCC guidance and GENIUS Act implementation expertise. Cons: fast-moving landscape; cost. |
| Option 3 — Risk Acceptance | Not viable | Charter conditions are enforceable under 12 U.S.C. 1818. Approval: N/A |
Option
Option 1 — Internal
Action
OCC condition review
Details
Owner: General Counsel; confirm non-objection status under the Operating Agreement. Est. Lift: Low–Medium
Option
Option 2 — Vendor
Action
Engage bank regulatory counsel with digital-asset experience
Details
Pros: OCC guidance and GENIUS Act implementation expertise. Cons: fast-moving landscape; cost.
Option
Option 3 — Risk Acceptance
Action
Not viable
Details
Charter conditions are enforceable under 12 U.S.C. 1818. Approval: N/A
5. Regulatory Obligation Map
Status: ✓ ACTIVE (confirmed obligation). ● LIKELY (strong inference, not fully confirmed). ● N/A (not applicable with rationale).
| Framework | Jurisdiction | Status | Key Obligations | Priority |
|---|---|---|---|---|
| OCC National Bank Supervision | Federal (US) | ✓ ACTIVE | Safety and soundness; capital adequacy; CRA; OCC examination; approvals for branches and acquisitions; heightened standards at the current $50B threshold (OCC proposal to raise it pending) | High |
| Federal Reserve — BHCA / FHC | Federal (US) | ✓ ACTIVE | Bank holding company regulation; financial holding company status (§4(l)); well capitalized and well managed requirements; affiliate transaction limits (§§23A/23B, Regulation W); Volcker Rule (the 10-K states the company and its subsidiaries are subject to it and do not qualify for the $10B exception) | High |
| CFPB Supervision | Federal (US) | ✓ ACTIVE | Supervision and examination from Jan 1, 2024; UDAAP; fair lending (ECOA); TILA; EFTA | High |
| FinCEN / BSA | Federal (US) | ✓ ACTIVE | BSA program; SAR and CTR filing; CDD/KYC; OFAC screening; investment adviser AML rule for SoFi Wealth LLC (effective Jan 1, 2028, under review) | High |
| FDIC Insurance | Federal (US) | ✓ ACTIVE | Deposit insurance assessments ($19.3M FDIC insurance expense for SoFi Bank in 2025); FDIA; secondary supervisory authority | Medium |
| SEC — Public Reporting Company | Federal (US) | ✓ ACTIVE | 10-K, 10-Q, 8-K; proxy (DEF 14A); PCAOB audit; Reg FD; Reg S-K Item 106 cybersecurity disclosure; insider trading restrictions | High |
| SEC — Investment Advisers Act | Federal (US) | ✓ ACTIVE | SoFi Wealth LLC: Form ADV; fiduciary duty; Rule 206(4)-7 compliance program; Rule 204A-1 code of ethics | Medium |
| FINRA | Federal (US) | ✓ ACTIVE | SoFi Securities LLC (CRD 151717): FINRA Rule 3310 (AML program); Regulation S-ID; Exchange Act Rules 17a-3/17a-4 (recordkeeping); net capital; SIPC membership | High |
| FTC Consent Order (Docket C-4673) | Federal (US) | ✓ ACTIVE | Prohibition on unsubstantiated savings claims; in force to Feb 22, 2039; compliance report one year after issuance and on request; ten-year recordkeeping | Medium |
| OCC Conditional Approval #1277 (Jan 2022) | Federal (US) | ✓ ACTIVE (status of Operating Agreement Unresolved) | Crypto-asset activities at SoFi Bank N.A. barred while the Operating Agreement is in effect absent prior written OCC non-objection; capital contribution condition | High |
| GENIUS Act (Pub. L. 119-27) | Federal (US) | ● LIKELY | Payment stablecoin framework effective the earlier of Jan 18, 2027 or 120 days after final rules; insured depository institutions cannot be permitted issuers directly (per SoFi's 10-K summary) | High |
| CCPA / CPRA | California (US) | ✓ ACTIVE | Consumer data rights; privacy notice; opt-out rights; CPPA enforcement (cited in 10-K) | Medium |
| State Supervision | Multi-state (US) | ● LIKELY | The 10-K states the company and its affiliates are subject to supervision and examination by various state regulators | Medium |
| CRA (Community Reinvestment Act) | Federal (US) | ✓ ACTIVE | OCC evaluates SoFi Bank under the CRA; the 2022 approval release names the CRA expressly | Medium |
| EU DORA | EU | ● LIKELY (Conditional) | Technisys S.A. (Luxembourg) may serve DORA-regulated entities; requires confirmation | Low |
| GDPR | EU | ● LIKELY (Conditional) | Per 10-K, applies if services are offered into the EU/UK; entity-level mapping required | Low |
| Basel III capital rules | Federal (US) | ✓ ACTIVE | Capital framework applies via the OCC and Federal Reserve; SoFi Bank well capitalized at Dec 31, 2025 | Medium |
| HIPAA | Federal (US) | ● N/A | Not a healthcare entity or business associate | |
| SFDR / CSRD | EU | ● N/A | No EU-distributed investment products confirmed; no EU parent |
6. Workflow Linkage Map
| Source Workflow | Linked To | Shared Artifact / Rationale | Link |
|---|---|---|---|
| 2.5 KYC Onboarding Audit | 2.2 AML Transaction Monitoring | Customer identity data feeds the monitoring system; a CIP weakness is an AML blind spot | ✓ LINK |
| 2.5 KYC Onboarding Audit | 8.1 Background Check Compliance | Identity verification protocols apply to both customer onboarding and employee screening | ● COND |
| 2.2 AML Transaction Monitoring | 2.3 SAR Draft | Monitoring alerts feed the SAR decision workflow | ✓ LINK |
| 4.1 Policy Library Review | 8.2 Insider Threat Policy Review | The Securities Trading and Section 16 Compliance Policy (Ex-19.1) is part of the policy library | ✓ LINK |
| 9.3 Concentration Risk Assessment | 11.4 Process Resilience & Outsourcing Review | Galileo client concentration is both vendor dependency and outsourced-service concentration | ✓ LINK |
| 1.4 Vendor Risk Assessment | 9.1 Vendor Onboarding Due Diligence | The Third-Party Security Risk Management program covers both | ✓ LINK |
| F-009 Crypto Position | 5.1 Regulatory Change Impact Review | OCC crypto guidance and GENIUS Act implementation must be tracked in horizon scanning | ✓ LINK |
| F-008 ESG Reporting | 5.1 Regulatory Change Impact Review | The SEC climate-rule rescission proceeding is a regulatory change to track | ✓ LINK |
| 7.1 Vulnerability Management | 7.3 Endpoint Security Audit | Vulnerability scan results feed endpoint remediation prioritization | ✓ LINK |
| 4.2 Board Risk Report | 4.5 Audit Committee Prep Pack | Risk and Audit Committees overlap (Freiberg, Meltzer); CISO reports quarterly to the Risk Committee | ● COND |
Source Workflow
2.5 KYC Onboarding Audit
Linked To
2.2 AML Transaction Monitoring
Shared Artifact / Rationale
Customer identity data feeds the monitoring system; a CIP weakness is an AML blind spot
Link
✓ LINK
Source Workflow
2.5 KYC Onboarding Audit
Linked To
8.1 Background Check Compliance
Shared Artifact / Rationale
Identity verification protocols apply to both customer onboarding and employee screening
Link
● COND
Source Workflow
2.2 AML Transaction Monitoring
Linked To
2.3 SAR Draft
Shared Artifact / Rationale
Monitoring alerts feed the SAR decision workflow
Link
✓ LINK
Source Workflow
4.1 Policy Library Review
Linked To
8.2 Insider Threat Policy Review
Shared Artifact / Rationale
The Securities Trading and Section 16 Compliance Policy (Ex-19.1) is part of the policy library
Link
✓ LINK
Source Workflow
9.3 Concentration Risk Assessment
Linked To
11.4 Process Resilience & Outsourcing Review
Shared Artifact / Rationale
Galileo client concentration is both vendor dependency and outsourced-service concentration
Link
✓ LINK
Source Workflow
1.4 Vendor Risk Assessment
Linked To
9.1 Vendor Onboarding Due Diligence
Shared Artifact / Rationale
The Third-Party Security Risk Management program covers both
Link
✓ LINK
Source Workflow
F-009 Crypto Position
Linked To
5.1 Regulatory Change Impact Review
Shared Artifact / Rationale
OCC crypto guidance and GENIUS Act implementation must be tracked in horizon scanning
Link
✓ LINK
Source Workflow
F-008 ESG Reporting
Linked To
5.1 Regulatory Change Impact Review
Shared Artifact / Rationale
The SEC climate-rule rescission proceeding is a regulatory change to track
Link
✓ LINK
Source Workflow
7.1 Vulnerability Management
Linked To
7.3 Endpoint Security Audit
Shared Artifact / Rationale
Vulnerability scan results feed endpoint remediation prioritization
Link
✓ LINK
Source Workflow
4.2 Board Risk Report
Linked To
4.5 Audit Committee Prep Pack
Shared Artifact / Rationale
Risk and Audit Committees overlap (Freiberg, Meltzer); CISO reports quarterly to the Risk Committee
Link
● COND
7. Escalations — Items Requiring Review
E-01 | OCC Conditional Approval vs. SoFi Crypto / SoFiUSD — Non-Objection Status
Reason: Condition 3 of the OCC's January 2022 conditional approval bars crypto-asset activities at SoFi Bank, N.A. while the Operating Agreement is in effect absent the OCC's prior written determination of no supervisory objection. SoFi's own disclosures place SoFi Crypto (November 2025) and SoFiUSD (December 2025) at the bank. Whether non-objection was sought and obtained, and whether the Operating Agreement remains in effect, is not public. This is a verification question that public sources cannot resolve; it is not an allegation of non-compliance.
Who Must Review: General Counsel + Chief Risk Officer + OCC relationship contact
E-02 | CFPB Examination Findings — January 2024 Onwards
Reason: CFPB supervision began January 1, 2024. Examination findings are confidential. The FTC consent order and the FINRA CIP/ITPP action are relevant precedent for examination focus. Findings cannot be confirmed from public sources.
Who Must Review: General Counsel + Chief Compliance Officer + CFPB relationship contact
E-03 | BSA/AML Program Documentation — Post-Charter Quality
Reason: SoFi Bank N.A. was conditionally approved on January 18, 2022 and the bank merger closed in February 2022. A full BSA/AML program is required. The FINRA action (2024, for 2018–2019 conduct) relates to a pre-bank period. Post-charter program quality, including the monitoring system, SAR cadence and CDD compliance, cannot be verified from public sources.
Who Must Review: BSA/AML Compliance Officer + Chief Risk Officer + OCC/FinCEN relationship contact
E-04 | Non-U.S. Operations — Regulatory Obligations
Reason: Technisys S.A. is a Luxembourg société anonyme; the 10-K reports operations in Latin America, Canada, Switzerland and Hong Kong, including a Hong Kong crypto trading launch in 2025. DORA, GDPR and local obligations may attach. Cannot be determined from public sources.
Who Must Review: General Counsel + Technisys compliance lead + local regulatory counsel
8. Next Actions — Prioritized (Effort × Impact)
| Priority | Action | Linked Finding/Workflow | Effort | Impact | Owner |
|---|---|---|---|---|---|
| 1 | Confirm OCC non-objection status for SoFi Crypto/SoFiUSD under the 2022 condition and the GENIUS Act pathway for SoFiUSD | F-009, E-01 | Low | High | General Counsel |
| 2 | Obtain post-2019 CIP/ITPP program documentation and current BSA/AML program assessment | F-001, E-03, 2.5, 2.2 | Medium | High | CRO, BSA Officer |
| 3 | Track the FinCEN adviser AML rule (2028, under review) and design SoFi Wealth LLC's program | F-001, 2.2 | Medium | High | CCO, CRO |
| 4 | CFPB examination preparation: UDAAP self-assessment; FTC consent order compliance review | F-002, F-003, E-02 | High | High | General Counsel, CCO |
| 5 | Confirm SOC 2 scope for Galileo and SoFi Bank's core processing environment | F-007, 1.1 | Medium | Medium | CISO, Internal Audit |
| 6 | OCC $50B heightened standards: assess current Appendix D obligations pending the rulemaking | F-005 | Low | Medium | CRO, General Counsel |
| 7 | Galileo concentration risk: obtain client concentration data; review exit/termination plan | F-006, 9.3, 9.4 | Medium | Medium | Galileo leadership, CRO |
| 8 | Review the 2025 ESG report against investor and counterparty expectations; track the SEC rescission rulemaking | F-008, 10.1, 10.2 | Low | Low | CFO, General Counsel |
| 9 | Non-U.S. regulatory mapping: DORA, GDPR and local obligations for Technisys and the Hong Kong entities | E-04, 3.1, 3.5, 6.1 | Medium | Medium | General Counsel, Technisys compliance lead |
9. Peer Context
SoFi Peer Archetype: High-growth national bank with a fintech platform business
SoFi's closest archetype is a recently chartered national bank that grew through digital channels rather than a branch network, combined with a business-to-business technology platform. The archetype is used only to frame which control areas peers at this scale are generally expected to have documented; no figures for any other company are stated in this profile.
| GRC Category | SoFi (This Profile) | Basis |
|---|---|---|
| Financial Regulation | Defined (3) | Enforcement history and rapid growth; expected to be at or above Defined at this scale |
| Cybersecurity | Defined (3) | SOC 2 scope and Zero Trust posture not public |
| Internal Governance | Defined (3) | Board structure strong; policy library depth not public |
| BSA/AML | Defined (3) | Prior FINRA CIP/ITPP action; post-charter program quality not public |
| ESG / Disclosure | Defined (3) | Voluntary ESG reporting in place; content not reviewed |
| Privacy & Data | Defined (3) | Documented public privacy program |
| Third-Party Risk | Defined (3) | Galileo concentration event is a public signal |
GRC Category
Financial Regulation
SoFi (This Profile)
Defined (3)
Basis
Enforcement history and rapid growth; expected to be at or above Defined at this scale
GRC Category
Cybersecurity
SoFi (This Profile)
Defined (3)
Basis
SOC 2 scope and Zero Trust posture not public
GRC Category
Internal Governance
SoFi (This Profile)
Defined (3)
Basis
Board structure strong; policy library depth not public
GRC Category
BSA/AML
SoFi (This Profile)
Defined (3)
Basis
Prior FINRA CIP/ITPP action; post-charter program quality not public
GRC Category
ESG / Disclosure
SoFi (This Profile)
Defined (3)
Basis
Voluntary ESG reporting in place; content not reviewed
GRC Category
Privacy & Data
SoFi (This Profile)
Defined (3)
Basis
Documented public privacy program
GRC Category
Third-Party Risk
SoFi (This Profile)
Defined (3)
Basis
Galileo concentration event is a public signal
Peer context is directional and based on public evidence about SoFi only. Not an audit.
10. RuleboardAI Engagements
The engagements above are the published engagement types as of September 26, 2026 and are shown for illustration. Current products, prices and turnarounds are on the Products page. Monitoring is not offered. See the Products page.
Verified Assessment — scoped per engagement
Scope: The upgrade from this preliminary profile. Under a signed Letter of Authorization, SoFi would provide the evidence this profile requests: BSA/AML program overview, post-2019 CIP/ITPP documentation, SOC 2 scope, OCC non-objection status for SoFi Crypto and SoFiUSD, and Technology Platform concentration data. RuleboardAI reviews the documents, records management responses, and updates each finding's label against verified evidence. Deliverable: an updated CompanyScope profile with confidence labels revised and escalations E-01 through E-04 addressed.
Ideal for: Closing the data gaps identified in this profile with the client's own evidence.
Custom Diligence — custom scope
Scope: Portfolio-scale diligence for deal teams and lenders: multiple targets or counterparties, custom category and framework scope, turnarounds set to the mandate's timeline, and a named point of contact.
Ideal for: PE deal teams, M&A advisors and lenders assessing several institutions at once.
11. Confidence Legend, Data Gaps & Disclaimers
Confidence Legend
| Label | Meaning |
|---|---|
| Confirmed | Supported by verified or publicly observable evidence directly on point. |
| Likely | Supported by consistent indirect evidence; stated with its inference visible. |
| Conditional | Holds only under stated assumptions or pending specific evidence. |
| Escalate | Requires human judgment or professional advice beyond the report's scope. |
Label
Confirmed
Meaning
Supported by verified or publicly observable evidence directly on point.
Label
Likely
Meaning
Supported by consistent indirect evidence; stated with its inference visible.
Label
Conditional
Meaning
Holds only under stated assumptions or pending specific evidence.
Label
Escalate
Meaning
Requires human judgment or professional advice beyond the report's scope.
Data Gaps
SOC 2 scope, report type and period for Galileo Financial Technologies and SoFi Bank's core processing environment
Cannot confirm from public sources. The 10-K discloses that SOC 2 is maintained for certain solutions; which entities and systems are covered is not public
Post-2019 CIP/ITPP program documentation and current BSA/AML program quality metrics
Cannot confirm from public sources. The FINRA action covered December 2018–April 2019 conduct; post-charter program quality cannot be verified from public sources
CFPB examination findings since January 1, 2024
Cannot confirm from public sources. The CFPB has held supervision and examination authority for approximately 33 months; findings are confidential and are the most material regulator-facing item given UDAAP obligations and the FTC order
OCC non-objection status for SoFi Crypto / SoFiUSD under the 2022 conditional approval, and the status of the Operating Agreement
Cannot confirm from public sources. SoFi's disclosures place both products at SoFi Bank N.A.; whether prior written non-objection was obtained, and whether the Operating Agreement remains in effect, cannot be confirmed from public sources
Content, framework alignment and assurance of the 2025 ESG report
Cannot confirm from public sources. The 10-K confirms the report exists and references climate-related commitments; the report itself was not reviewed in this pass
Non-U.S. regulatory obligations (Technisys S.A., Luxembourg; operations in Latin America, Canada, Switzerland and Hong Kong)
Cannot confirm from public sources. Public disclosures do not confirm or deny DORA, GDPR or local obligations for these operations
Technology Platform client concentration (top clients as a share of segment revenue)
Cannot confirm from public sources. The 2025 large-client exit is confirmed; the current concentration profile, contractual protections and exit plans are not public
Internal whistleblower program documentation
Cannot confirm from public sources. The public-company whistleblower regime applies; internal program structure, channels and non-retaliation policy are not public
BCP/DR test results and exercise cadence for SoFi Bank N.A.
Cannot confirm from public sources. Regular testing is a supervisory expectation; results are not public; at $50.7B in assets operational resilience is a material supervisory focus
Disclaimers
- Public Sources Only. This profile was produced entirely from publicly available sources: SEC EDGAR filings, OCC releases, decisions and institution lists, FINRA disciplinary records, SEC and FTC orders, FinCEN releases, SoFi's own investor releases, and the text of the cited statutes and regulations. No client documentation, internal policies, examination reports or confidential supervisory information was reviewed. This is Gap Mode — Preliminary.
- No Client Engagement. SoFi Technologies, Inc. is not a client of RuleboardAI. This profile is a sample deliverable demonstrating the CompanyScope methodology applied to a public company. No confidential relationship exists.
- Not an Audit, Legal Opinion, or Attestation. Nothing in this document is an audit, legal advice, regulatory opinion or attestation. Findings are preliminary conclusions from public information and are subject to change on review of client documentation.
- Point-in-Time. All data and findings are as of September 26, 2026. Every source URL was re-verified on that date. SoFi's regulatory environment and financial profile change; the profile ages as facts change.
- Accuracy. Reasonable care was taken to cite primary sources, which may themselves contain errors or lag current regulatory status. Material facts should be verified directly with SoFi and its regulators before any business, investment or compliance decision.
- RuleboardAI Methodology. This profile applies RCPS Methodology v1.2 (effective September 28, 2026; the scoring rule is unchanged from v1.1, under which this profile was produced): finding labels Confirmed, Likely, Conditional and Escalate; evidence states including Unresolved; a 1–5 maturity scale whose composite is the mean of the scored categories and takes the name of the nearest whole level. Verified conclusions require a Verified Assessment engagement.
Source Appendix
| Source | Description | URL |
|---|---|---|
| SEC EDGAR — SoFi Technologies (CIK 0001818874) | EDGAR filing index for SoFi. Verified 2026-09-26 | View source |
| SoFi Form 10-K FY2025 (filed February 17, 2026) | Annual report for the year ended December 31, 2025; primary source for financial, regulatory, cybersecurity (Item 1C), crypto, stablecoin and ESG-report statements. Verified 2026-09-26 | View source |
| SoFi DEF 14A 2026 Proxy Statement (April 30, 2026) | Director and officer roster, ages, committee composition, chairs and 2025 meeting counts. Verified 2026-09-26 | View source |
| SoFi Q4 2025 Earnings Release (Form 8-K exhibit, January 30, 2026) | Members 13.7M, products 20.2M, Technology Platform accounts 128.5M vs 167.7M, loans at fair value $36.4B, adjusted EBITDA, 2026 guidance. Verified 2026-09-26 | View source |
| OCC Conditional Approval #1277 — SoFi Bank, N.A. (January 18, 2022) | Decision letter; conditions 1–3 including the crypto-asset condition with the prior written no-supervisory-objection carve-out. Verified 2026-09-26 at the resolving path | View source |
| OCC News Release 2022-4 (January 18, 2022) | Press release on the conditional approval; names the Operating Agreement, capital conditions, crypto-asset condition and the CRA. Verified 2026-09-26 | View source |
| OCC National Banks Active list (as of August 31, 2026) | Confirms SoFi Bank, National Association, charter no. 20862, Cottonwood Heights, UT, active. Verified 2026-09-26 | View source |
| OCC News Release 2025-134 (December 23, 2025) | Proposal to raise the heightened-standards asset threshold from $50 billion to $700 billion; proposed, not final. Verified 2026-09-26 | View source |
| OCC Bulletin 2023-17 — Interagency Guidance on Third-Party Relationships | Current third-party risk management guidance (replaces OCC 2013-29). Verified 2026-09-26 | View source |
| FINRA AWC No. 2019062705801 — SoFi Securities LLC (May 2, 2024) | Letter of Acceptance, Waiver and Consent: censure and $1.1M fine; CIP and ITPP findings; conduct December 2018–April 2019. Verified 2026-09-26 | View source |
| SEC Investment Advisers Act Release No. 5826 — SoFi Wealth LLC (August 19, 2021) | Order instituting settled proceedings: ~20,000 accounts, SFY/SFYX, tax consequences, $300,000 penalty, undertakings. Verified 2026-09-26 | View source |
| SEC adviser registry (IAPD) — firm search "SoFi" | SoFi Wealth LLC registration active (801-78185); SoFi Capital Advisors LLC registration inactive. Verified 2026-09-26 | View source |
| FTC Decision and Order — Docket No. C-4673, In re Social Finance, Inc. and SoFi Lending Corp. (February 2019) | Order text: savings-claim substantiation, compliance reporting, recordkeeping, termination on February 22, 2039. Verified 2026-09-26 | View source |
| FTC press release — FTC Approves Final Order with SoFi (February 2019) | Summary of the complaint allegations (conduct since April 2016) and the final order. Verified 2026-09-26 | View source |
| SoFi press release — SoFi Bank launches crypto trading (November 11, 2025) | States that SoFi Crypto products and services are offered by SoFi Bank, N.A. Read in a browser on 2026-09-26; the page refuses automated requests | View source |
| SoFi press release — SoFiUSD stablecoin (December 18, 2025) | States that SoFiUSD is issued by SoFi Bank, N.A. and fully reserved. Read in a browser on 2026-09-26; the page refuses automated requests | View source |
| Tidal Trust I — SoFi Next 500 ETF (SFYX) prospectus supplement (February 2, 2026) | Liquidation of SFYX; Social Finance, Inc. named as sponsor. Verified 2026-09-26 | View source |
| Tidal Trust I — post-effective amendment (June 26, 2026) | SoFi Select 500 ETF (SFY) and two other SoFi-branded ETFs remain registered; Tidal Investments LLC adviser; SoFi sponsor. Verified 2026-09-26 | View source |
| FinCEN — final rule postponing the investment adviser AML rule to January 1, 2028 (December 31, 2025) | Effective date moved from January 1, 2026; rule under review. Verified 2026-09-26 | View source |
| SEC press release 2026-49 — proposed rescission of climate-related disclosure rules (May 29, 2026) | Rules stayed April 4, 2024; defense ended March 27, 2025; rescission proposed. Verified 2026-09-26 | View source |
| OCC Bulletin 2019-47 — stress testing rule amendments | Company-run stress test threshold raised to $250 billion (12 CFR 46). Verified 2026-09-26 | View source |
| SoFi Leadership Team (sofi.com) | Officer roster; secondary to the DEF 14A. Verified 2026-09-26 | View source |
| 12 CFR Part 30, Appendix D — OCC heightened standards | Rule text | View source |
| 12 CFR Part 46 — OCC stress testing | Rule text | View source |
| 12 CFR 21.21 — BSA compliance program (national banks) | Rule text | View source |
| 31 CFR 1020.210 — AML program requirements for banks | Rule text | View source |
| 31 CFR 1020.320 — Reports by banks of suspicious transactions | Rule text | View source |
| 31 CFR 1010.230 — Beneficial ownership (CDD) | Rule text | View source |
| 31 CFR 1023.220 — Broker-dealer customer identification program | Rule text | View source |
| 31 CFR Part 1032 — Investment advisers (AML) | Rule text | View source |
| 17 CFR 275.206(4)-7 — Adviser compliance procedures | Rule text | View source |
| 17 CFR 275.204A-1 — Adviser codes of ethics | Rule text | View source |
| 17 CFR 240.17a-3 — Broker-dealer records | Rule text | View source |
| 17 CFR 240.17a-4 — Broker-dealer record preservation | Rule text | View source |
| 17 CFR 229.106 — Regulation S-K Item 106 (cybersecurity) | Rule text | View source |
| 17 CFR 248.201 — Regulation S-ID identity theft red flags | Rule text | View source |
| 12 CFR Part 223 — Regulation W (§§23A/23B) | Rule text | View source |
| 12 CFR Part 44 — OCC Volcker rule | Rule text | View source |
| 12 CFR Part 25 — OCC Community Reinvestment Act rule | Rule text | View source |
| 12 U.S.C. 5515 — CFPB supervision of very large banks | Statute text | View source |
| 12 U.S.C. 5531 — UDAAP | Statute text | View source |
| 12 U.S.C. 5365 — Enhanced supervision and prudential standards | Statute text | View source |
| 12 U.S.C. 1843 — BHCA §4 (financial holding companies) | Statute text | View source |
| 12 U.S.C. 1851 — Volcker Rule | Statute text | View source |
| 12 U.S.C. 1818 — Enforcement (conditions imposed in writing) | Statute text | View source |
| 12 U.S.C. 2901 — Community Reinvestment Act | Statute text | View source |
| 31 U.S.C. 5318 — BSA compliance programs | Statute text | View source |
| 15 U.S.C. 45 — FTC Act §5 | Statute text | View source |
| 15 U.S.C. 80b-6 — Advisers Act §206 | Statute text | View source |
| 15 U.S.C. 78u-6 — Securities whistleblower incentives and protection | Statute text | View source |
| GENIUS Act — Public Law 119-27 | Statute text (govinfo) | View source |
| FINRA Rule 3310 — Anti-Money Laundering Compliance Program | Rule text | View source |
| 31 CFR 1020.220 — Bank customer identification program | Rule text | View source |
| 17 CFR Part 243 — Regulation FD | Rule text | View source |
| 17 CFR 240.15c3-1 — Broker-dealer net capital | Rule text | View source |
| 31 CFR Part 501 — OFAC reporting, procedures and penalties | Rule text | View source |
| 15 U.S.C. 78ccc — Securities Investor Protection Corporation | Statute text | View source |
| 12 CFR Part 1002 — Regulation B (ECOA) | Rule text | View source |
| 12 CFR Part 1005 — Regulation E (EFTA) | Rule text | View source |
| 12 CFR Part 1026 — Regulation Z (TILA) | Rule text | View source |
| NIST Cybersecurity Framework 2.0 | Framework text | View source |
| NIST SP 800-207 — Zero Trust Architecture | Framework text | View source |
| FFIEC BSA/AML Examination Manual | Manual home. Refuses automated requests (403); loaded in a browser 2026-09-26 | View source |
| FFIEC IT Examination Handbook InfoBase | Handbook home. Refuses automated requests (403); loaded in a browser 2026-09-26 | View source |
| CFPB Supervision and Examination Manual | Manual home | View source |
| AICPA — SOC 2 | Trust Services Criteria overview | View source |
Source
SEC EDGAR — SoFi Technologies (CIK 0001818874)
Description
EDGAR filing index for SoFi. Verified 2026-09-26
URL
Source
SoFi Form 10-K FY2025 (filed February 17, 2026)
Description
Annual report for the year ended December 31, 2025; primary source for financial, regulatory, cybersecurity (Item 1C), crypto, stablecoin and ESG-report statements. Verified 2026-09-26
URL
Source
SoFi DEF 14A 2026 Proxy Statement (April 30, 2026)
Description
Director and officer roster, ages, committee composition, chairs and 2025 meeting counts. Verified 2026-09-26
URL
Source
SoFi Q4 2025 Earnings Release (Form 8-K exhibit, January 30, 2026)
Description
Members 13.7M, products 20.2M, Technology Platform accounts 128.5M vs 167.7M, loans at fair value $36.4B, adjusted EBITDA, 2026 guidance. Verified 2026-09-26
URL
Source
OCC Conditional Approval #1277 — SoFi Bank, N.A. (January 18, 2022)
Description
Decision letter; conditions 1–3 including the crypto-asset condition with the prior written no-supervisory-objection carve-out. Verified 2026-09-26 at the resolving path
URL
Source
OCC News Release 2022-4 (January 18, 2022)
Description
Press release on the conditional approval; names the Operating Agreement, capital conditions, crypto-asset condition and the CRA. Verified 2026-09-26
URL
Source
OCC National Banks Active list (as of August 31, 2026)
Description
Confirms SoFi Bank, National Association, charter no. 20862, Cottonwood Heights, UT, active. Verified 2026-09-26
URL
Source
OCC News Release 2025-134 (December 23, 2025)
Description
Proposal to raise the heightened-standards asset threshold from $50 billion to $700 billion; proposed, not final. Verified 2026-09-26
URL
Source
OCC Bulletin 2023-17 — Interagency Guidance on Third-Party Relationships
Description
Current third-party risk management guidance (replaces OCC 2013-29). Verified 2026-09-26
URL
Source
FINRA AWC No. 2019062705801 — SoFi Securities LLC (May 2, 2024)
Description
Letter of Acceptance, Waiver and Consent: censure and $1.1M fine; CIP and ITPP findings; conduct December 2018–April 2019. Verified 2026-09-26
URL
Source
SEC Investment Advisers Act Release No. 5826 — SoFi Wealth LLC (August 19, 2021)
Description
Order instituting settled proceedings: ~20,000 accounts, SFY/SFYX, tax consequences, $300,000 penalty, undertakings. Verified 2026-09-26
URL
Source
SEC adviser registry (IAPD) — firm search "SoFi"
Description
SoFi Wealth LLC registration active (801-78185); SoFi Capital Advisors LLC registration inactive. Verified 2026-09-26
URL
Source
FTC Decision and Order — Docket No. C-4673, In re Social Finance, Inc. and SoFi Lending Corp. (February 2019)
Description
Order text: savings-claim substantiation, compliance reporting, recordkeeping, termination on February 22, 2039. Verified 2026-09-26
URL
Source
FTC press release — FTC Approves Final Order with SoFi (February 2019)
Description
Summary of the complaint allegations (conduct since April 2016) and the final order. Verified 2026-09-26
URL
Source
SoFi press release — SoFi Bank launches crypto trading (November 11, 2025)
Description
States that SoFi Crypto products and services are offered by SoFi Bank, N.A. Read in a browser on 2026-09-26; the page refuses automated requests
URL
Source
SoFi press release — SoFiUSD stablecoin (December 18, 2025)
Description
States that SoFiUSD is issued by SoFi Bank, N.A. and fully reserved. Read in a browser on 2026-09-26; the page refuses automated requests
URL
Source
Tidal Trust I — SoFi Next 500 ETF (SFYX) prospectus supplement (February 2, 2026)
Description
Liquidation of SFYX; Social Finance, Inc. named as sponsor. Verified 2026-09-26
URL
Source
Tidal Trust I — post-effective amendment (June 26, 2026)
Description
SoFi Select 500 ETF (SFY) and two other SoFi-branded ETFs remain registered; Tidal Investments LLC adviser; SoFi sponsor. Verified 2026-09-26
URL
Source
FinCEN — final rule postponing the investment adviser AML rule to January 1, 2028 (December 31, 2025)
Description
Effective date moved from January 1, 2026; rule under review. Verified 2026-09-26
URL
Source
SEC press release 2026-49 — proposed rescission of climate-related disclosure rules (May 29, 2026)
Description
Rules stayed April 4, 2024; defense ended March 27, 2025; rescission proposed. Verified 2026-09-26
URL
Source
OCC Bulletin 2019-47 — stress testing rule amendments
Description
Company-run stress test threshold raised to $250 billion (12 CFR 46). Verified 2026-09-26
URL
Source
SoFi Leadership Team (sofi.com)
Description
Officer roster; secondary to the DEF 14A. Verified 2026-09-26
URL
Source
31 CFR 1020.320 — Reports by banks of suspicious transactions
Description
Rule text
URL
Source
31 CFR 1023.220 — Broker-dealer customer identification program
Description
Rule text
URL
Source
12 U.S.C. 5365 — Enhanced supervision and prudential standards
Description
Statute text
URL
Source
12 U.S.C. 1818 — Enforcement (conditions imposed in writing)
Description
Statute text
URL
Source
15 U.S.C. 78u-6 — Securities whistleblower incentives and protection
Description
Statute text
URL
Source
15 U.S.C. 78ccc — Securities Investor Protection Corporation
Description
Statute text
URL
Source
FFIEC BSA/AML Examination Manual
Description
Manual home. Refuses automated requests (403); loaded in a browser 2026-09-26
URL
Source
FFIEC IT Examination Handbook InfoBase
Description
Handbook home. Refuses automated requests (403); loaded in a browser 2026-09-26
URL
Powered by RuleboardAI | Generated 09-26-2026 | Illustrative — SoFi Technologies (SAMPLE) — CompanyScope v1 2026 · RCPS Methodology v1.2 | Public Sources Only
RuleboardAI | ruleboardai.com | Ashwin Tatikola
SAMPLE DOCUMENT — ILLUSTRATIVE USE ONLY
This profile was produced entirely from public sources as a sample deliverable for the RuleboardAI marketing website. No client engagement exists between RuleboardAI and SoFi Technologies, Inc. No client documentation was reviewed. All data is sourced from public filings and regulatory records as cited below.
Not an audit, legal opinion, or attestation. Built from public sources only.
Want this for your company?
What a purchase covers. This sample shows the full report structure across every category. A CompanyScope profile ($500 one-time) covers one category you choose, in the same structure.