For a long time, enterprise payments involved a pretty familiar trade-off. Banks offered security, safeguards, and regulatory comfort, but moving money through them could be slow and inflexible.
Fintech platforms made it easier to move fast and adapt to new use cases, but they often did so in ways that shifted more risk and responsibility back onto the business. Trying to combine the two usually meant piecing systems together and hoping nothing broke.
That balance doesn’t work anymore. There’s more regulatory scrutiny, lower tolerance for payment risk, and questions about who controls funds and how decisions are enforced are harder to brush aside.
At the same time, employees, customers, and partners expect money to move quickly, and they expect experiences that fit the situation, not generic processes.
Rather than forcing speed and safeguarding into a single system, more enterprises are adopting a two-stack model to address this challenge.
Banks continue to do what they’re best at, holding and protecting funds and providing regulatory oversight. Fintech platforms focus on delivering configurable logic, faster iteration, and modern payment experiences.
In this blog, we look at why this shift is happening, how the two-stack model works in practice, and what enterprises should consider when evaluating a payments partner.
Why Enterprises Shouldn’t Have to Choose Between Trust and Speed
Enterprises are being pulled in two directions at the same time. On one side, there’s growing pressure to prove that payments are well-controlled, auditable, and defensible.
On the other side, there’s a clear expectation that money should move faster and adapt to real-world needs. The challenge is that neither side can be ignored anymore.
Why Can’t Enterprises Compromise on Trust?
Trust in the financial sector is hard won and easily lost.
High-profile failures across banking and fintech have shown how quickly things can unravel when controls, oversight, or fund custody aren’t solid.
As a result, regulators are paying closer attention, and enterprises are under pressure to show that money is being handled carefully.
What makes this more challenging is how payment programs now operate. Several factors make strong controls and clear ownership essential:
- Payment operations are more fragmented: Global programs, multiple payout methods, and distributed teams make it difficult to maintain consistent controls
- Problems surface faster and are harder to contain: When money moves quickly and at scale, errors, fraud, or misuse become visible sooner and leave less room for quiet fixes after the fact.
- Regulatory scrutiny is more detailed and hands-on: Auditors want to understand exactly where funds are held, who can initiate transactions, and how approvals and limits are applied in daily operations.
Why Can’t Enterprises Slow Down to Stay Safe?
Slowing everything down isn’t a realistic option either. Expectations around payments have changed, and they’re not shifting back. Employees, customers, vendors, and beneficiaries are not going to be willing to give up on the speed and reliability they demand in moving money.
Across industries, real-time and near-real-time payouts are part of normal operations. This shows up in areas like:
- Payroll and earned wage access, where workers expect faster access to money they’ve already earned.
- Claims and reimbursements, where delays quickly translate into frustration and complaints.
- Vendor and supplier payments, where timing affects cash flow and relationships.
- Incentives and relief programs, where speed is often tied directly to participation and impact.
Enter the Two-Stack Model
This tension between trust and speed may not be new, but the underlying infrastructure has finally caught up.
Real-time payment rails and modern banking integrations have made it easier for banks to support faster money movement without sacrificing oversight, while more mature fintech platforms can layer logic, controls, and user experiences on top of bank-held funds without breaking governance.
The two-stack model has emerged as a practical way to separate responsibilities that were never meant to sit in the same place:
- Banks remain responsible for holding and safeguarding funds, enforcing fiduciary controls, and providing the regulatory foundation enterprises rely on.
- Fintech platforms focus on configuration and execution, translating business rules into programmable payment logic that can be built, adjusted, and scaled quickly.
Stack #1: The Bank Layer - Ownership, Safeguarding, and Accountability
In a two-stack model, the bank layer is responsible for the money itself through:
- Fund safeguarding that fintechs can’t replicate: Funds are held in regulated, bank-controlled accounts rather than by a platform or program manager. Money isn’t co-mingled or used for working capital, and ownership is clearly defined at all times.
- Providing Immutable control and audit-ready reporting: Transactions beyond basic deposits are initiated and validated at the bank level, supported by immutable ledgering and real-time reconciliation. This gives finance, procurement, and risk teams records they can rely on.
- Providing Compliance as a structural advantage: Ongoing requirements around AML, KYC, and KYB, PCI, liquidity rules, and regulatory oversight sit with a regulated bank, allowing enterprises to gain legal defensibility and risk insulation that would be difficult to manage independently.
The bank layer provides stability and durability and ensures that everything built on top of it can scale without introducing unacceptable risk.
Stack #2: The Fintech Layer - Control, Configuration, and Execution
If the bank layer provides stability, the fintech layer turns business intent into working payment programs without changing how funds are held or safeguarded. It offers:
- Programmable payment logic built for real-world use cases: Fintech platforms give enterprises fine-grained control over how money can be used, who can use it, and under what conditions by designing payment behavior that reflects how programs actually operate, including:
- Spending and merchant controls
- Eligibility rules and funding logic
- Velocity limits and transaction thresholds
- Multi-step approvals and role-based permissions
- One configurable engine, with many different programs: The same fintech layer can support payroll, incentives, vendor payouts, spend cards, or relief programs without spinning up new processors or bespoke builds. Enterprises configure the logic once and adapt it as needs evolve, rather than rebuilding for every new use case.
- Speed to market without structural risk: This layer is what allows teams to launch faster, iterate more often, and respond to change without reopening banking, custody, or compliance decisions. New programs can go live in weeks instead of months, while the underlying foundation stays stable.
What Enterprises Gain From a True Two-Stack Model
When the bank and fintech layers are designed to work together, enterprises gain structural advantages that support speed, scale, and long-term competitiveness, such as:
- Faster launches without long build cycles: Enterprises can bring payment programs live in months rather than years, without building and maintaining infrastructure in-house.
- Bank-grade protection teams can rely on: Procurement, compliance, and risk teams gain confidence from clear fund custody, enforceable controls, and structures that stand up under audit and regulatory review.
- Flexibility to support multiple use cases on one platform: The same system can power payroll, incentives, vendor payments, spend cards, and relief programs without separate processors or custom builds.
- Real-time visibility with configurable controls: Enterprises can see how funds move, apply granular rules, and adjust workflows without sacrificing oversight.
- A simpler, more unified operating model: Fewer vendors reduce integration risk, audits are more straightforward, and reporting is consistent across programs.
Real-World Proof: Where the Two-Stack Model Shows Its Value
This approach is already being used in situations where payments need to move quickly, but accountability still matters.
This approach is already being used in situations where payments need to move quickly, but accountability still matters.
- Insurance payouts. After an accident or major loss, people often need access to funds immediately. Faster payouts reduce stress at the exact moment it matters most, while insurers retain the controls and reporting they need.
- Payroll and earned wage access. Employees increasingly expect quicker access to wages they’ve already earned, especially contractors and gig workers, without compromising payroll governance.
- Wealth management spend programs. Firms can offer controlled access to funds through spend cards, account tools, or targeted disbursements, with limits and workflows tailored to different client needs.
- Disaster relief and emergency disbursements. Fast distribution paired with clear tracking and reporting helps organizations demonstrate exactly how money was allocated and used.
How Berkeley Fits Into a Two-Stack Payments Model
Berkeley provides the configurable fintech layer that allows enterprises to design, control, and scale payment programs on top of bank-secured funds.
Berkeley supports this in a few key ways:
- Configurable payment logic without custom builds: Enterprises can define rules around eligibility, limits, approvals, and usage, and adjust those rules as programs evolve, without rebuilding infrastructure or reopening banking decisions.
- One platform for multiple payment programs: Payroll-related payouts, incentives, vendor payments, spend cards, and relief programs can all be supported through the same system, reducing operational complexity and duplication.
- Real-time visibility and control: Teams gain clear insight into how funds move, with granular controls and workflows that support oversight without slowing execution.
- API-first integration into existing systems: Payment programs can plug into existing finance, payroll, or operational tools, allowing payments to work as part of broader business processes rather than standalone systems.
By sitting between enterprise use cases and bank infrastructure, Berkeley helps organizations bring modern payment experiences to life while keeping fund control, compliance, and accountability where they belong.
The Future Isn’t “Bank vs. Fintech” - It’s Both
Enterprises shouldn’t have to choose between safeguarding and speed. Payment programs need to move quickly, adapt easily, and still meet the expectations of regulators, auditors, and internal risk teams.
The two-stack approach reflects this shift. Banks continue to provide fund custody, fiduciary controls, and regulatory oversight. Fintech platforms deliver the configurability, logic, and tools needed to build modern payment experiences. Together, they create a model that supports scale, flexibility, and long-term durability.
If you’re looking to modernize payments without compromising on trust or compliance, Berkeley can help you assess whether a two-stack model is the right fit.
Contact us to learn more.
