SOLO Network Launches FinCEN-Observed Bank Reliance Pilot to Advance Reusable Customer Verification Across U.S. Financial Institutions
The SOLO Network has announced the launch of a FinCEN-observed Bank Reliance Pilot, developed in coordination with the U.S. Department of the Treasury, the Financial Crimes Enforcement Network (FinCEN), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC). The initiative represents a significant milestone in the modernization of customer verification by introducing what the organization describes as the first scalable framework for enabling trusted customer verification to be reused across multiple financial institutions.
The pilot seeks to address one of the banking industry’s longest-standing operational challenges: the repeated verification of the same customers every time they establish a relationship with a new bank, fintech, or financial services provider. By creating a standardized method for representing, auditing, and evaluating completed verification work, the SOLO Network aims to reduce unnecessary duplication while preserving each institution’s independent compliance responsibilities.
The initiative also marks the first coordinated engagement involving the U.S. Treasury, FinCEN, the OCC, and the FDIC focused on operationalizing bank reliance at scale, highlighting growing interest in improving efficiency across customer due diligence and Know Your Customer (KYC) processes.
Addressing a Persistent Industry Challenge
Financial institutions have traditionally invested substantial time and resources verifying customer identities, reviewing documentation, assessing compliance requirements, and conducting anti-money laundering (AML) checks.
However, these verification efforts are frequently repeated whenever customers open accounts with different institutions—even if another regulated organization has recently completed an equivalent verification process.
According to SOLO, the issue has never been that customer verification was absent.
Instead, the primary challenge has been the lack of interoperability between institutions.
Banks and fintech companies generally lack a standardized mechanism for understanding:
- What verification work has already been completed.
- What documentation was reviewed.
- Which regulatory standards were applied.
- Whether prior verification satisfies their own compliance requirements.
As a result, institutions often repeat identical verification procedures rather than relying on previously completed work.
The SOLO Network seeks to eliminate this inefficiency without compromising regulatory oversight or institutional independence.
Modernizing the Concept of Bank Reliance
The pilot builds upon the long-established regulatory concept of bank reliance, under which one financial institution may rely on certain compliance work performed by another institution under appropriate circumstances.
Although bank reliance has existed within banking regulations for years, practical implementation across multiple organizations has remained limited due to operational complexity and the absence of common technical standards.
SOLO aims to bridge that gap by providing infrastructure that makes independently performed verification interoperable across institutions.
Rather than requiring banks to adopt identical verification procedures, the platform focuses on standardizing how completed verification is documented and communicated.
This distinction enables institutions to maintain their existing internal compliance frameworks while benefiting from trusted verification already performed elsewhere.
Standardizing Verification Artifacts
A central feature of the SOLO Network is the creation of standardized verification artifacts.
These artifacts serve as comprehensive, auditable records documenting:
- Verification activities performed.
- Evidence reviewed.
- Identity documents examined.
- Compliance standards applied.
- Risk assessment processes.
- Supporting audit information.
Instead of simply sharing customer information, participating institutions generate structured records describing how verification was completed.
Receiving institutions can independently evaluate these artifacts and determine whether they satisfy their own legal, regulatory, and risk management requirements.
This approach preserves institutional autonomy while reducing redundant work.
Maintaining Independent Compliance Decisions
Importantly, the SOLO Network does not require financial institutions to outsource customer verification decisions.
Each participating bank or fintech continues making its own independent determinations regarding customer acceptance, risk management, and regulatory compliance.
The platform merely enables institutions to review standardized evidence documenting verification already completed by another trusted participant.
If an institution determines that the verification satisfies its internal standards, it may rely on that work rather than restarting the process from the beginning.
If additional verification is required, the institution remains free to perform supplemental reviews.
This model allows flexibility while promoting operational efficiency.
Reducing Friction for Consumers
Repeated identity verification has long been a source of frustration for consumers and businesses.
Opening accounts at multiple financial institutions often requires customers to repeatedly submit:
- Government-issued identification.
- Business formation documents.
- Tax information.
- Proof of address.
- Ownership records.
- Beneficial ownership information.
- Compliance questionnaires.
Although institutions perform these reviews independently, much of the information requested remains identical.
The SOLO Network aims to reduce this duplication by allowing customers to authorize participating institutions to evaluate trusted verification already completed elsewhere.
Instead of beginning every relationship from scratch, customers can benefit from portable verification that follows them throughout the financial ecosystem.
Comparison to TSA PreCheck
SOLO compares its model to the Transportation Security Administration’s TSA PreCheck program.
Travelers enrolled in TSA PreCheck undergo trusted screening once and subsequently receive expedited security processing at participating airports.
Similarly, SOLO envisions a financial system where trusted verification travels with consumers across participating institutions.
Customers would no longer repeatedly complete identical onboarding procedures each time they establish new financial relationships.
At the same time, every participating institution would retain full authority over its own compliance decisions.
The analogy illustrates how reusable trust can improve efficiency without weakening security.
Collaboration Across Federal Agencies
One of the most notable aspects of the pilot is the coordinated involvement of multiple U.S. regulatory agencies.
The initiative includes engagement with:
- The U.S. Department of the Treasury.
- Financial Crimes Enforcement Network (FinCEN).
- Office of the Comptroller of the Currency (OCC).
- Federal Deposit Insurance Corporation (FDIC).
According to SOLO, this represents the first coordinated effort involving all four organizations focused on operationalizing scalable bank reliance.
While each agency maintains its own regulatory responsibilities, the pilot provides an opportunity to explore how standardized verification artifacts may support existing compliance frameworks while reducing unnecessary operational duplication.
Encouraging Industry Collaboration
Another objective of the SOLO Network is to encourage greater collaboration among banks and fintech companies.
Historically, institutions have had limited incentives to share verification work already performed.
Several obstacles contributed to this situation:
- Lack of standardized documentation.
- Limited interoperability.
- Inconsistent audit practices.
- Regulatory uncertainty.
- Operational complexity.
- Limited economic incentives.
SOLO addresses these barriers by creating a common framework through which trusted institutions can exchange auditable verification records without requiring standardized operational processes.
This approach transforms customer verification into a collaborative ecosystem rather than an isolated institutional activity.
CEO Highlights Need for Interoperability
Georgina Merhom, Founder and Chief Executive Officer of SOLO, emphasized that financial institutions already rely on one another’s work in numerous areas of financial services.
However, customer verification has historically lacked a consistent framework for documenting, evaluating, and auditing completed work across organizations.
According to Merhom, the industry’s objective should not be centralized verification performed by a single provider.
Instead, any trusted institution should be capable of issuing verification that another institution can independently evaluate.
She explained that customers repeatedly begin verification processes from the beginning—not because verification has never occurred, but because institutions have lacked a shared trust framework capable of making completed verification portable.
SOLO seeks to establish that common framework while allowing organizations to preserve their individual operating models.
Rapid Industry Adoption
Despite being founded only recently, the SOLO Network has experienced significant early adoption.
Within its first year of operation, the network reports onboarding leading sponsor banks and their fintech partners.
Collectively, participating organizations represent more than 100 million consumer and small business profiles, demonstrating substantial industry interest in reusable verification capabilities.
This early participation provides an important foundation for broader network effects, as the value of reusable verification increases with the number of participating institutions.
Consumer Protection Remains Central
As a consumer reporting agency, SOLO states that transparency, auditability, and consumer protection have been incorporated into the network’s design from the outset.
The organization emphasizes that reusable verification must operate within existing legal and regulatory frameworks while protecting customer rights.
Customers remain responsible for authorizing participating institutions to evaluate previously completed verification.
The network also provides audit trails documenting:
- Verification activities.
- Supporting evidence.
- Standards applied.
- Institutional evaluations.
- Authorization records.
These capabilities are intended to improve accountability while strengthening trust between financial institutions, regulators, and consumers.
Benefits for Financial Institutions
For banks and fintech companies, reusable verification has the potential to generate significant operational benefits.
Potential advantages include:
- Reduced onboarding costs.
- Faster customer acquisition.
- Lower compliance duplication.
- Improved operational efficiency.
- Enhanced audit capabilities.
- Stronger collaboration between institutions.
- More consistent documentation.
- Improved customer experience.
Institutions can also redirect compliance resources toward higher-risk activities rather than repeatedly reviewing customers who have already undergone comprehensive verification elsewhere.
Benefits for Consumers and Businesses
Consumers and businesses also stand to benefit from a more streamlined onboarding experience.
Rather than repeatedly gathering and submitting identical documentation to multiple financial institutions, customers could authorize participating organizations to evaluate existing trusted verification.
Potential benefits include:
- Faster account opening.
- Reduced paperwork.
- Fewer duplicate identity checks.
- Improved customer convenience.
- Greater transparency.
- More consistent onboarding experiences.
Business customers, which often face particularly complex compliance requirements involving ownership structures and beneficial ownership documentation, may experience especially meaningful efficiency improvements.
Preserving Regulatory Standards
Importantly, SOLO emphasizes that reusable verification is not intended to weaken regulatory standards.
Each institution continues maintaining full responsibility for compliance with:
- Bank Secrecy Act requirements.
- Anti-money laundering regulations.
- Customer Identification Program obligations.
- Know Your Customer requirements.
- Internal risk management policies.
Reusable verification simply provides standardized evidence that institutions may evaluate when making independent compliance decisions.
This preserves accountability while reducing unnecessary duplication.
Building a More Connected Financial Ecosystem
The SOLO Network reflects broader industry efforts to modernize financial infrastructure through interoperability rather than centralization.
Instead of replacing existing compliance systems, the platform enables institutions to continue using their preferred verification methodologies while sharing standardized evidence describing completed work.
This approach supports innovation without requiring wholesale operational change.
As more institutions join the network, reusable verification could become an increasingly valuable component of digital banking, sponsor banking, embedded finance, and fintech partnerships.
The launch of the FinCEN-observed Bank Reliance Pilot marks an important step toward reimagining customer verification within the financial services industry. By standardizing how verification work is documented, evidenced, audited, and evaluated, the SOLO Network seeks to transform identity verification from a repetitive institutional process into a portable, reusable trust framework.
Supported through coordination with the U.S. Department of the Treasury, FinCEN, the OCC, and the FDIC, the initiative demonstrates how regulatory collaboration and technological innovation can work together to improve efficiency while preserving rigorous compliance standards. If broadly adopted, the SOLO Network’s model has the potential to reduce operational costs, accelerate customer onboarding, enhance transparency, and create a more connected financial ecosystem in which trusted verification can move securely across institutions without compromising regulatory oversight or institutional independence.
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