Roadmap
Roadmap
Compliance
THEN SCALE
Pay-in-4 with bank-aligned compliance and transparent terms. Funding from approved sources—including crypto via partners—where permitted by law.
Last updated: September 13, 2025
Availability varies by program, partner, and jurisdiction. Crypto funding is offered via approved partners where permitted by law.
Phase 1: Bank Partner Program
compliance Gate:
signed bank loi + compliance review
Target: Q1 2026 (pilot eligibility review)
Subject to approvals
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Data room: entity docs, policies skeleton, architecture diagram, risk assessment, projected volumes, use‑case deck.
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Goal: 3 discovery calls → 1–2 qualified paths with rough timelines.
Phase 0: Reset & Signal Trust
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Rewrite homepage/FAQ with compliance-first copy; add “Not a bank/partner issued” footer; add Apple/Google Pay trademarks.
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Hide placeholder Shop; publish Compliance & Licenses page; publish Roadmap page with gates.
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Create “Proof Hub” (treasury/multi-sig links when ready, change‑log for Terms/Privacy).
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Build Bank Pitch One‑Pager + 2‑page Product Memo.
Identify/engage partner bank (Member FDIC) for BNPL/credit issuance. Document underwriting model, fair‑lending posture, and program governance.
Phase 3: MVP Scope & Build
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MVP Features:
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Account creation + KYC
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Funding source linking (approved sources only)
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Instant virtual card creation once approved by partner
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Pay‑in‑4 schedule generation; ledger; reminders; dunning
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Merchant acceptance methods: hosted checkout link, QR/invoice pay, simple JS button
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Admin console: risk flags, manual review, refunds/chargebacks, dispute notes
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Tech: Modular services (auth, ledger, risk, notifications). Tokenization readiness (Apple/Google Pay when approved).
Phase 2: Compliance Stack
compliance Gate
Vendor selection + Policy Sign-off
Target: Concurrent with Phase 1
Subject to approvals
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KYC/AML vendor shortlist; sanctions screening; device/risk signals.
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Draft: CIP, EDD, sanctions, record‑keeping, privacy, UDAAP/TILA disclosures, complaints.
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Set up sandbox integrations and test scripts.
Implement CIP/KYC, AML transaction monitoring, OFAC sanctions screening, fraud controls, and recordkeeping. Build adverse media and PEP screening where appropriate.
Finalize pricing, schedules, late/NSF fee policies, hardship programs, dispute/chargeback handling, and complaint management.
compliance Gate:
Legal sign-off on Truth-in-Lending/BNPL disclosures
Target: Pre-pilot
Subject to approvals
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Credit/risk policy (limits, eligibility, state rules); device/behavioral signals.
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Fraud rules: velocity, BIN/geo, synthetic detection, mule patterns.
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Collections policies (soft → hard), disclosures, call scripts.
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Monitoring dashboards: approvals, loss ladder, repayments, support tickets.
Phase 4: Risk & Underwriting
Controlled rollout with selected merchants and users. Measure loss rates, repayment behaviors, and operational readiness before broader availability.
compliance Gate:
State/jurisdiction availability confirmed
Target: After steps 1-4
Subject to approvals
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Target 3 verticals: Home services (HVAC), Automotive (repair/dent), Local e‑com.
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5–10 pilot merchants with LOIs; integrate via invoice/QR or hosted link first.
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Consumer messaging: “Limited pilot — by invitation, subject to approval.”
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Weekly pilot review with partner bank/program manager.
Broader release contingent on partner approvals and performance thresholds. Publish changelogs and program metrics for transparency.
compliance Gate:
Operational audit + compliance attestation
Target: Post-pilot; partner sign-off
Subject to approvals
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T&Cs final, state availability matrix, fee schedule per partner.
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App/landing onboarding polish; support playbooks; incident drills.
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Marketing compliance review; affiliate policy; brand guide.
Phase 5: Pilot Merchant Program
Phase 6: Public Availability
Phase 7: Scale
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Expand states/segments; add 2nd processor or issuer as redundancy.
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Optimize approvals with alternative data; reduce CAC via merchant co‑marketing.
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Quarterly compliance audit cadence; SOC2 path if required by partners.