Launching and operating a bank requires meeting extensive legal and regulatory obligations that govern licensing, capital, governance, customer protection, prudential risk management, and ongoing supervision. In the business plan, founders should clearly identify the target jurisdictions, the intended license type (e.g., commercial bank, digital bank, community bank, deposit-taking institution), and the supervisory authorities that will oversee the bank.

Licensing and chartering
A bank generally cannot accept deposits or market itself as a bank without an approved license/charter. The business plan should outline the licensing pathway, including pre-application engagement, application submission, and approval milestones. Typical licensing requirements include:
- Fit-and-proper assessments for shareholders, board members, and senior management
- Demonstrated source of funds and ownership transparency (including beneficial ownership disclosures)
- Initial and ongoing capital requirements, along with a credible capital plan
- A viable business model and financial projections supported by prudent assumptions
- Operational readiness (policies, systems, staffing, outsourcing arrangements) prior to opening

Capital, liquidity, and prudential requirements
Bank regulators typically impose minimum capital thresholds and risk-based capital requirements, along with liquidity and funding standards. Your business plan should specify how the bank will comply from day one and as it scales, including:
- Capital composition and buffers (what qualifies as core capital versus supplementary capital)
- Liquidity management approach (liquid asset holdings, contingency funding plan)
- Stress testing practices and triggers for management actions
- Policies for large exposures, concentration limits, and related-party exposures

Governance, internal controls, and risk management
Strong governance is a licensing and ongoing supervision priority. The plan should describe the governance structure and control environment, including:
- Board composition, independence, committees (audit, risk, remuneration) and their mandates
- Three lines of defense model (business, risk/compliance, internal audit) and reporting lines
- Enterprise Risk Management framework covering credit, market, liquidity, operational, conduct, and model risk
- Internal audit scope, frequency, and independence; external audit appointment and timelines

Anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance
Banks are subject to strict AML/CTF regimes and sanctions obligations. The business plan should be explicit about the compliance program and how it will be operationalized:
- Customer due diligence/KYC onboarding standards, beneficial ownership verification, and ongoing monitoring
- Risk-based approach: customer risk scoring, enhanced due diligence for higher-risk customers
- Transaction monitoring, alert investigation workflows, and escalation rules
- Suspicious activity reporting processes and recordkeeping retention policies
- Sanctions screening (customers and transactions), name-matching governance, and escalation/true-hit handling
- Appointment of responsible officers (e.g., AML compliance officer) and training plan

Consumer protection, product governance, and fair treatment
Banking is heavily regulated for disclosures, sales practices, pricing transparency, and complaints handling. The plan should address:
- Product approval process and target-market definition; controls to prevent mis-selling
- Standard customer disclosures (fees, interest, terms, risks) and plain-language documentation
- Complaints management, response SLAs, root-cause analysis, and remediation approach
- Collections and arrears management standards, including customer hardship programs where applicable

Data protection, privacy, and cybersecurity
Banks handle sensitive personal and financial data and are typically subject to privacy laws and sector cybersecurity expectations. Include:
- Data governance: data classification, retention, access controls, and audit trails
- Privacy compliance: lawful basis for processing, consent management where required, cross-border transfer controls
- Cybersecurity program: vulnerability management, penetration testing, incident response, and security monitoring
- Third-party risk management for fintech vendors, cloud providers, and outsourced service partners

Payment systems, deposit insurance, and financial infrastructure
Participation in payment rails and protection of depositors can require additional approvals and ongoing rules compliance. In the plan, specify:
- Intended payment services (cards, ACH/SEPA equivalents, wire transfers, instant payments) and required memberships
- Settlement, reconciliation, and dispute management processes
- Deposit protection scheme participation (if applicable) and how coverage will be communicated to customers

Financial reporting, regulatory reporting, and audits
Ongoing reporting is a significant operational workload. The business plan should show readiness for:
- Regulatory returns (capital, liquidity, asset quality, large exposures, related-party transactions)
- Financial statements prepared under the relevant accounting standards and audit requirements
- Management information systems that produce accurate, timely, and reconciled reporting
- Recordkeeping requirements and document retention schedules

Market conduct, marketing restrictions, and use of the term “bank”
Many jurisdictions restrict advertising, deposit solicitation, and the use of bank-related terminology. The plan should include controls for:
- Review and approval of marketing materials by compliance/legal
- Disclosures for rates, fees, and promotional terms
- Restrictions on claims about safety, guarantees, or regulatory status

Employment, executive compensation, and key person requirements
Bank regulators may scrutinize hiring, fitness and propriety, and incentive structures. Address:
- Background checks and certification requirements for regulated roles
- Compensation policies aligned with prudent risk-taking and clawback provisions where applicable
- Succession planning for key control functions (CRO, CFO, compliance, internal audit)

Cross-border operations and foreign ownership
If the bank will operate in multiple countries or serve non-resident customers, the plan should describe:
- Passporting/branching or subsidiary strategy and required approvals
- Cross-border data transfer compliance and customer onboarding restrictions
- Tax reporting obligations that may arise from serving international customers

Implementation plan and compliance resourcing
Conclude this section with a practical roadmap and budget for compliance delivery. Founders should include:
- A regulatory engagement plan (who owns regulator communications, cadence, and documentation control)
- A compliance staffing plan (in-house vs. external advisors) and training schedule
- A policy library list to be finalized prior to launch (AML/CTF, credit policy, conduct risk, outsourcing, incident response, complaints, model risk, etc.)
- A timeline showing when core systems (KYC, transaction monitoring, core banking, reporting) will be implemented and validated

This section should clearly demonstrate that compliance is not an afterthought: it is embedded in the business model, operating design, and financial plan, with accountable owners, tested controls, and sufficient funding to meet supervisory expectations.

Financing a bank requires a mix of regulatory capital, long-term funding, and liquidity resources. In a business plan, distinguish clearly between: (a) capital that counts toward regulatory requirements, (b) funding used to build the operating platform and cover early losses, and (c) balance-sheet funding used to originate and hold assets. Lenders and investors will evaluate your path to authorization, the resilience of your capital plan under stress, and the credibility of your governance and risk framework.

1) Founders’ capital and pre-launch equity
Early-stage equity funds feasibility work, licensing/authorization preparation, hiring of key executives, vendor selection, and initial systems build. This capital often comes from founders, strategic angels, or a small syndicate aligned with the long timeline and regulatory scrutiny. In the plan, specify the intended use of funds (legal/regulatory, compliance staffing, technology, premises, insurance, audit) and the runway to reach key milestones (submission of application, conditional approval, readiness testing, launch).

2) Institutional equity (private placements)
Banks commonly raise equity from institutional investors through private placements. Investors will expect a detailed capitalization table, governance rights, and a clear route to liquidity (e.g., later rounds, strategic sale, or public listing where appropriate). Address how investor protections will coexist with regulatory expectations for fit-and-proper owners, control thresholds, related-party rules, and limitations on complex ownership structures.

3) Strategic investors and partnerships
Strategic investors (fintechs, payment processors, insurers, retailers, or regional financial groups) may provide capital alongside commercial agreements (distribution, co-branding, technology, or access to customer segments). This can accelerate deposit gathering and product adoption, but the plan should anticipate potential conflicts: exclusivity clauses, data ownership, outsourcing concentration risk, and supervisory scrutiny of third-party dependencies. Describe how you will maintain independence of risk decisions and meet arm’s-length requirements.

4) Regulatory capital instruments (where permitted)
Depending on jurisdiction and license type, eligible capital can include common equity and, in some cases, additional capital instruments (e.g., certain preferred shares or subordinated debt that meets regulatory criteria). Your plan should:
- Identify which instruments you intend to use and why
- Outline key terms you will target (maturity, subordination, loss absorbency features, dividend/coupon constraints)
- Show how these instruments support capital ratios and buffers without introducing refinancing risk

5) Subordinated debt and other loss-absorbing funding
Subordinated debt can support balance-sheet growth and, in some frameworks, contributes to capital buffers. For a new bank, pricing and investor appetite depend heavily on governance credibility, underwriting discipline, and the stability of funding sources. Include a staged approach: raise after demonstrating operational readiness and early portfolio performance, not as a substitute for adequate equity.

6) Deposits as a primary funding source (post-launch)
Customer deposits are central to bank funding. Your plan should separate deposit strategy by segment and product and link it to liquidity management and interest rate risk:
- Retail deposits (current accounts, savings, term deposits): typically stickier, but require strong onboarding, service, and trust-building
- SME deposits: can scale with business banking relationships but may be more rate-sensitive
- Brokered/wholesale deposits (if allowed): can grow quickly but may be less stable and draw closer supervisory focus
Define deposit pricing governance, concentration limits, expected mix over time, and contingency actions if deposit inflows underperform.

7) Wholesale funding and interbank borrowing
Wholesale funding (secured/unsecured) can support liquidity and asset growth but is generally more sensitive to market conditions and confidence. In the plan, state permitted instruments, counterparties, collateral policy, haircuts, and limits. Demonstrate that wholesale funding is a complement to deposits, not the foundation of the model, especially in early years.

8) Central bank facilities and eligible collateral frameworks
Where applicable, access to central bank operations can be an important liquidity backstop. The plan should describe operational readiness (account setup, eligible collateral, reporting capability) and how these facilities fit within the liquidity contingency framework. Avoid presenting central bank access as a routine funding source; position it as part of risk management and stress preparedness.

9) Securitization and loan sales (later-stage balance-sheet management)
As portfolios mature, securitization or loan sales can free capital and manage concentration, duration, and liquidity. If included, describe governance for asset eligibility, representations and warranties, servicing arrangements, and how you will avoid excessive reliance on originate-to-distribute incentives. Link this option to track record and data quality milestones.

10) Vendor financing and implementation financing
Core banking, card processing, AML systems, and digital onboarding platforms are major early costs. Some vendors offer deferred payments or implementation financing. This can reduce initial cash burn, but it may create hidden leverage and long-term fixed commitments. Disclose these arrangements, their covenants, termination clauses, and any security interests, and ensure they align with outsourcing and operational resilience requirements.

11) Government or development programs (where applicable)
In some markets, programs support lending to priority sectors through guarantees, funding lines, or risk-sharing. If you plan to use them, show operational capability to comply with eligibility rules, reporting, and audit requirements. Clarify the economics (fees, caps, coverage) and avoid building the core model on a program that may be temporary or policy-dependent.

How to present the financing plan in your business plan
Include a clear, staged capital and funding roadmap tied to milestones and risk gates:
- Phase 1 (pre-authorization): equity to fund setup, governance build-out, and regulatory engagement
- Phase 2 (authorization to launch): incremental equity to complete technology, hiring, controls testing, and operational readiness
- Phase 3 (early operations): deposits ramp-up; conservative asset growth; maintain higher liquidity and capital buffers
- Phase 4 (scale): diversified funding mix; potential subordinated debt; optional securitization/loan sales

What investors and regulators will scrutinize
Address these points explicitly to strengthen credibility:
- Capital adequacy and buffers under base and stressed scenarios (credit losses, deposit outflows, margin compression)
- Quality of capital (loss absorbency, permanence) versus short-dated or covenant-heavy funding
- Liquidity management (liquidity buffer composition, access to contingent sources, concentration limits)
- Interest rate risk and deposit beta assumptions used in projections
- Governance: board composition, independent risk/compliance, internal audit plan, and decision rights
- Related-party funding and conflicts of interest controls
- Operational resilience and third-party risk, especially where funding depends on partners or platforms

Deliverables to include as appendices
To make the section actionable, attach:
- Capitalization table and funding timeline by instrument
- Sources and uses schedule for each round/phase
- Pro forma regulatory capital and liquidity metrics (with assumptions stated clearly)
- Liquidity contingency funding plan summary (triggers, actions, communication protocol)
- Term-sheet placeholders for planned instruments (high-level only, no fabricated pricing)
- Governance documents outline (risk appetite statement, ALCO charter, funding policy, concentration limits)

The marketing and sales strategy for the bank is designed to build trust, acquire profitable customers, grow primary banking relationships (checking/current account + direct deposit/payroll), and expand revenue through responsible lending and fee-based services. The approach combines brand positioning, localized demand generation, digital acquisition, branch/relationship-led sales, and partner channels, supported by a measurable funnel and strict compliance controls.

Target Segments and Positioning
Marketing will be organized around clearly defined segments with tailored value propositions, messaging, and channel mixes:
1) Retail consumers: simple everyday banking, transparent fees, fast account opening, strong mobile app, and responsive support.
2) Mass affluent and professionals: relationship banking, preferential rates, credit solutions, and wealth/financial planning introductions where applicable.
3) Small and medium businesses (SMEs): operating accounts, payments, cash management, merchant services, lines of credit, and treasury support.
4) Community and niche segments (e.g., local associations, industry clusters): specialized account bundles and dedicated relationship coverage.
Positioning will emphasize safety, reliability, service quality, speed of onboarding, and clarity of pricing. Product claims will be evidence-based and reviewed for regulatory compliance.

Go-to-Market Channels
Customer acquisition will use a balanced channel portfolio to reduce dependency on any single source and to match segment behavior:
Digital: SEO and local search, paid search, paid social, app store optimization (if applicable), retargeting, email nurture, and website conversion optimization.
Branch and in-person: community presence, financial education events, business networking, and appointment-based consultations for higher-value products.
Partner channels: payroll providers, accounting firms, business associations, real estate and auto ecosystems (where permitted), fintech partners, and employer relationships.
Referral programs: structured incentives that comply with regulations and focus on relationship depth rather than one-off openings.
Direct outreach for SMEs: relationship manager prospecting, calling programs, and targeted outreach to priority industries.

Brand, Trust, and Reputation Strategy
Banking purchases are trust-based; the brand strategy will prioritize credibility and transparency:
Clear articulation of deposit protection/insurance status and security practices in customer-friendly language.
Consistent service standards (response times, complaint handling, dispute resolution) with visible escalation paths.
Public reviews and reputation management with prompt, compliant responses and operational fixes to recurring issues.
Content that demonstrates expertise (financial literacy, cash-flow management, fraud prevention) without making unrealistic promises.

Product Packaging and Offer Design
Offers will be packaged to encourage primary relationship behavior and reduce churn:
Everyday banking bundles: checking/current account + savings + debit card + digital tools.
SME bundles: business account + merchant services + invoicing/payments + optional credit line eligibility pathway.
Qualification-based offers: rate promotions or fee waivers tied to direct deposit, average balance, or multi-product usage.
Onboarding checklists and “first 30 days” journeys to drive activation (bill pay setup, salary deposit, card usage, alerts, and savings goals).

Pricing and Promotions
Pricing will be competitive and transparent, with a focus on lifetime value rather than aggressive short-term incentives. Promotions will be time-bound and targeted, with clear eligibility rules and disclosures. For lending products, marketing will avoid “instant approval” implications unless supported by underwriting processes, and all APR/rate disclosures will follow applicable laws and internal compliance review.

Sales Model and Process
The bank will run two complementary sales motions:
1) Self-serve/digital-led for standard accounts: fast onboarding, identity verification, and guided product selection.
2) Relationship-led for complex needs (SME, mortgages, wealth referrals): appointment-based sales with needs assessment and documented suitability/affordability checks.
Core sales process steps will include: lead capture & qualification, needs discovery, product recommendation, compliance checks (KYC/AML and affordability where relevant), application submission, underwriting/approval (for credit), onboarding, and post-sale activation.

Lead Generation and Funnel Management
Lead sources will be tracked by segment and intent (information-seeking vs ready-to-open). The funnel will be managed with defined handoffs and service levels:
Marketing-qualified lead (MQL): meets segment criteria and engagement threshold.
Sales-qualified lead (SQL): validated need, eligibility, and intent; routed to branch/relationship manager as appropriate.
Conversion steps: account opening completed, funding achieved, activation milestones met (direct deposit/payroll, bill pay, card usage).
Ongoing nurture will be automated via email/SMS (where permitted) and in-app messaging, with personalization based on behavior and product eligibility.

Cross-Sell and Relationship Deepening
Growth will prioritize responsible cross-sell based on customer needs and risk appetite:
Lifecycle triggers: new job/direct deposit setup, savings goal creation, large balance movements, business formation, equipment purchase intent.
Credit readiness programs: education and pre-qualification paths that do not guarantee approval.
SME upsell: payments acceptance, cash management tools, and credit products aligned with cash-flow profiles.
Retention programs: annual relationship reviews, proactive fee/rate transparency, and service recovery outreach following issues.

Community and Local Market Strategy (if operating branches)
Local visibility will be built through practical initiatives: partnerships with local employers, sponsorship of business events, financial literacy workshops, and collaboration with chambers of commerce and industry associations. Branch teams will maintain a prospecting cadence and a calendar of community touchpoints linked to measurable pipeline targets.

Partnership Strategy
Partnerships will be evaluated on customer fit, economics, operational effort, compliance risk, and data-sharing feasibility. Typical partnership structures include co-marketing, embedded referrals, or integrated onboarding flows. All partner agreements will define lead ownership, service levels, complaint handling, and responsibilities for disclosures and consent.

Digital Experience and Conversion Optimization
The bank’s website and mobile experience will be treated as primary sales assets:
Clear product pages with fee tables, eligibility requirements, and required documents.
Streamlined application flows with progress indicators and save-and-resume capability.
Secure document upload and transparent application status updates.
A/B testing of messaging, calls-to-action, and onboarding steps to improve completion rates while maintaining compliance.

Customer Service as a Sales Lever
High-quality service will support acquisition and retention. Service teams will be trained to identify needs and refer customers to appropriate products without pressure selling. Scripts and prompts will focus on problem resolution first, then optional next steps (e.g., setting up alerts, overdraft options, or fraud protection tools).

Compliance and Risk Controls in Marketing and Sales
All marketing materials, product disclosures, and sales scripts will follow a documented approval workflow involving compliance and legal review. Key controls include:
Truth-in-advertising standards and standardized disclosures for rates, fees, and credit terms.
KYC/AML and sanctions screening processes embedded into onboarding.
Fair lending and non-discrimination policies reflected in targeting, underwriting communications, and staff training.
Data privacy, consent management, and secure handling of personal information across channels.

Key Metrics and Reporting
Performance will be monitored through a dashboard reviewed weekly and monthly. Core metrics include:
Acquisition: cost per lead, cost per account, approval rates (where applicable), and channel conversion rates.
Activation: funding rate, direct deposit/payroll setup rate, first-30-day engagement, and digital adoption.
Relationship depth: products per customer, primary account ratio, deposit growth, and retention/churn.
SME performance: pipeline value, win rate, time-to-close, and utilization of cash management services.
Quality and risk: complaint volume and resolution time, fraud rates, early delinquency indicators, and account closure reasons.
Targets will be set based on internal capacity, expected ramp time, and risk appetite rather than unsupported market claims.

12-Month Execution Roadmap
Months 1–3: finalize positioning, segment offers, launch compliant marketing asset library, implement CRM and tracking, optimize onboarding flow, start local SEO and partner outreach.
Months 4–6: scale paid acquisition, launch referral program, begin community events, implement lifecycle nurture journeys, formalize SME prospecting cadence.
Months 7–9: introduce additional bundles and cross-sell triggers, expand partnerships, refine underwriting-to-marketing feedback loop, improve conversion via testing.
Months 10–12: deepen relationship programs, expand into adjacent segments/geographies (if planned), tighten unit economics, and standardize best-performing playbooks across teams.

The Operations and Logistics section describes how the bank will run day-to-day, deliver services reliably, meet regulatory obligations, and manage the flow of transactions, data, and cash (where applicable). This part should show that the bank can operate safely at scale, with clear ownership, controls, and contingency plans.

Operating Model and Service Delivery
Define the service channels and how they interact:
Branch operations (if any): account opening, teller services, cash handling, customer service, local business banking.
Digital channels: mobile app, online banking, chat/secure messaging, card controls, payments.
Contact center: phone support, complaints handling, fraud reports, lost card handling, service requests.
Relationship management: business/SME onboarding, credit support, treasury/cash management support.
Back office: payments operations, reconciliations, dispute management, loan servicing, document management.

Explain how customers move between channels without friction (e.g., digital onboarding supported by contact center; branch-assisted digital enrollment). Clarify which products are “straight-through processed” versus those requiring manual review (e.g., higher-risk customers, complex lending, exceptions).

Core Banking and Systems Architecture
Describe the system components that enable operations and controls:
Core banking system (accounts, ledger, interest, fees, statements).
Payments processing (ACH/SEPA/FPS/wires depending on market), bill pay, real-time payments integration if applicable.
Card issuing and processing (debit/credit), tokenization, card disputes/chargebacks.
Digital banking platform (web/app), authentication, customer notifications.
CRM and case management (service tickets, complaints, workflow).
AML/KYC screening and transaction monitoring tools.
Credit origination and underwriting tools (scorecards, rules, decisioning) and loan servicing platform.
Data warehouse/BI, regulatory reporting, audit logs, retention.

State hosting approach (cloud/on-prem/hybrid), key integrations, and how you will manage vendor dependencies (SLAs, monitoring, escalation paths). Include how you will ensure segregation of duties, least-privilege access, and logging across all platforms.

Customer Onboarding and Account Opening (KYC/EDD)
Outline the end-to-end onboarding process and operational checkpoints:
Application capture (digital/branch/relationship manager) and identity verification.
Customer due diligence: sanctions/PEP screening, adverse media checks if used, risk scoring.
Enhanced due diligence triggers and approval process for higher-risk customers.
Document collection, validation, and storage (with retention policy).
Account approval/decline decisioning and customer communication.
Initial funding controls and fraud checks (e.g., first deposit/transfer verification).
Ongoing due diligence refresh cycles based on risk tiers.

Define responsible teams (front-line, compliance, operations) and service-level targets (e.g., standard cases vs exceptions). Include a plan for reducing manual work over time through automation while maintaining control quality.

Transaction Operations and Reconciliations
Describe how the bank will process and control daily flows:
Inbound/outbound payments handling, cut-off times, exceptions and repair queues.
Posting rules to the general ledger and sub-ledgers; end-of-day processing controls.
Reconciliation routines (bank accounts, suspense accounts, card settlement, payment networks).
Return items, recalls, and investigations (with documented timelines and ownership).
Fees, interest accruals, statement generation, and customer notices.

Specify how exceptions are tracked (case management), how breaks are investigated and resolved, and how aging items are escalated. Include maker-checker controls and evidence requirements for audit.

Lending Operations (if offering loans)
Explain the operational pipeline from application to servicing:
Origination: application intake, document collection, verification, underwriting, approvals.
Collateral and lien/perfection steps where relevant, valuation processes, insurance tracking.
Closing and funding controls, disbursement methods, and post-closing checks.
Servicing: payment processing, escrow handling (if applicable), modifications, hardship programs.
Collections: early-stage delinquency workflows, cures, escalations, charge-off processes.
Portfolio monitoring: covenant tracking, risk rating reviews, concentration monitoring.

Clarify credit committee structure, approval authorities, and how credit exceptions are documented and monitored. Include how lending operations coordinate with compliance (fair lending, disclosures, adverse action notices where applicable).

Cash and Branch Logistics (if operating branches or cash services)
If the bank will handle physical cash, include controls and logistics:
Cash forecasting and replenishment schedules; vault and drawer limits.
Armored carrier relationships and service-level requirements.
Dual control procedures, cash counts, surprise audits, and variance management.
ATM operations (if applicable): cash loading, maintenance, dispute handling.
Physical security measures and incident reporting.

If the bank is digital-only, explicitly state how cash-related customer needs will be addressed (e.g., partner ATM network, cash deposit partnerships, or limited cash services), and what controls cover those third-party arrangements.

Compliance Operations Embedded in Daily Work
Describe how compliance is operationalized, not just overseen:
AML transaction monitoring alert handling, investigation steps, escalation and filing decisions.
Sanctions screening operations for payments and customer updates.
Fraud operations: detection, case management, customer verification, recovery efforts.
Complaints management: intake, categorization, root-cause analysis, regulator-ready documentation.
Privacy and data rights handling (requests, breach response procedures).

Include a clear RACI (who is Responsible, Accountable, Consulted, Informed) for key compliance-driven processes and how decisions are documented for audit and regulators.

People, Roles, and Coverage
Define the org structure needed to operate safely:
Operations leadership (payments, deposit operations, lending ops).
Risk and compliance (AML, fraud, operational risk, internal controls).
Customer support/contact center management and quality assurance.
IT operations and security (monitoring, incident response, access management).
Finance operations (GL, reconciliations, reporting).
Vendor management and procurement.

State hours of operation for critical support functions and on-call coverage for incidents (payments outages, security events). Describe training programs for front-line and operations staff, including recurring training and certification/attestation where required.

Third-Party and Vendor Management
List which functions are outsourced or partner-dependent (core banking, KYC, card processor, cloud hosting, call center, collections, document storage). Describe the vendor lifecycle:
Due diligence (financial health, security posture, compliance, audit reports).
Contracting (SLAs, data ownership, exit clauses, subcontractor controls).
Ongoing monitoring (performance KPIs, incidents, audits, change management).
Business continuity testing with vendors and joint incident exercises.
Exit and migration plans to reduce lock-in risk.

Business Continuity, Disaster Recovery, and Resilience
Describe how the bank will maintain service during disruptions:
BCP scope (payments, digital banking, contact center, branch operations, critical vendors).
DR strategy (backup frequency, recovery objectives, data replication, environment separation).
Incident management process (triage, communications, customer/regulator notifications).
Operational runbooks for manual fallback procedures (e.g., payment exception handling).
Regular testing cadence and lessons-learned process.

Security and Access Logistics
Summarize the operational security controls that protect systems and customers:
Identity and access management (MFA, privileged access, periodic access reviews).
Change management and release controls for customer-facing systems.
Security monitoring, vulnerability management, patching processes.
Device management and endpoint protection for staff systems.
Data governance: classification, encryption, retention, and secure disposal.

Facilities and Physical Operations
If operating offices/branches, explain site selection logic, staffing, physical security, document handling, and record retention. For digital-first banks, cover secure office practices and how remote work is controlled (equipment issuance, secure connectivity, call recording policies, and supervision).

Key Operational Metrics and Reporting Cadence
Define how operations will be measured and improved. Include a practical set of KPIs and who reviews them:
Onboarding: time to open, exception rate, abandonment rate, rework rate.
Payments: processing times, exception volumes, reconciliation breaks, return rates.
Fraud/AML: alert volumes, time to disposition, confirmed fraud rate trends, backlog aging.
Customer service: first-contact resolution, response times, complaint volume and themes.
Lending: time to decision, time to fund, delinquency buckets, cure rates.

Specify reporting cadence (daily ops dashboards, weekly risk/controls review, monthly vendor review, quarterly audit/compliance reviews) and how corrective actions are tracked to completion.

Implementation Timeline and Operational Readiness
Provide a staged launch plan with readiness gates, such as:
Systems configuration and integrations complete; end-to-end testing signed off.
Policies and procedures approved; training completed and recorded.
Vendor contracts live; SLAs and escalation paths validated.
Operational control testing (reconciliations, access controls, monitoring) completed.
Pilot launch with limited customers/products; monitored rollout to full launch.

Conclude with what must be true for the bank to scale (automation roadmap, hiring plan, system capacity planning, and control maturity improvements) while maintaining compliance and customer experience.

The Human Resources & Management section explains how the bank will be governed, staffed, and controlled to meet regulatory expectations while delivering safe, consistent service. This section should demonstrate clear accountability, segregation of duties, and the ability to attract experienced leaders across risk, compliance, operations, technology, and customer-facing functions.

Organizational structure
Describe the legal and operating structure (e.g., holding company and bank subsidiary, branches, digital channels, shared services). Provide a simple org chart narrative that shows reporting lines and independence of control functions. A typical structure includes:
Board of Directors (with committees)
Chief Executive Officer (CEO)
Independent control functions: Chief Risk Officer (CRO), Chief Compliance Officer (CCO)/BSA-AML Officer, Internal Audit (reports functionally to the Board/Audit Committee)
Business lines: Retail/SME Banking, Commercial Banking, Treasury, Wealth/Private Banking (if applicable)
Operations & Technology: Banking operations, payments, IT/security, vendor management
Finance: CFO, financial control, regulatory reporting, FP&A

Board governance and committees
Explain the Board’s role in oversight of strategy, risk appetite, capital/liquidity, and senior management performance. Identify key committees and what each oversees. Common committees include:
Audit Committee: financial reporting oversight, external auditor, Internal Audit plan/results
Risk Committee: risk appetite, credit concentration limits, stress testing, operational risk, model risk (if applicable)
Compliance/Conduct Committee (or combined Risk & Compliance): regulatory readiness, consumer protection, complaints trends, ethics
Compensation Committee: executive pay aligned to risk outcomes; incentive controls and deferrals where appropriate
Nominating/Governance Committee: board composition, independence, training, succession planning

Executive leadership roles (and what regulators expect to see)
Define each senior role with responsibilities and decision rights. Avoid title-only descriptions; specify how they interact and how conflicts are managed.

CEO: accountable for overall performance; ensures culture, governance, and execution of approved strategy.
CFO: financial control, budgeting, capital planning, liquidity reporting, ALCO support, regulatory reporting coordination.
CRO: independent oversight of credit, market, liquidity, operational, and model risk; owns risk framework, risk appetite monitoring, and escalation protocols.
CCO / BSA-AML Officer: compliance program, regulatory change management, monitoring/testing, suspicious activity reporting processes, sanctions screening governance.
Chief Credit Officer / Head of Credit: underwriting standards, credit policy, portfolio monitoring, workout/special assets (as needed), credit committee operations.
Chief Operating Officer (COO): end-to-end operations, process controls, service levels, business continuity, third-party oversight.
Chief Information Security Officer (CISO) / Head of IT Security: cybersecurity program, incident response, access controls, security vendor oversight.
Head of Treasury / ALM: liquidity management, funding strategy, interest rate risk management, investment portfolio limits, ALCO reporting.
Head of Retail/Commercial Banking: sales management, relationship management, performance and conduct standards, frontline controls.

Segregation of duties and control environment
Show how the bank prevents conflicts and reduces operational risk through separation between origination, approval, booking, funding, and monitoring. Document practical examples such as:
Loan officers originate; independent credit approves within delegated authority; operations books and funds; credit administration perfects collateral; risk monitors portfolio; collections/workout is independent from origination.
Payments initiation, approval, and release are separated; dual control for high-risk transactions; privileged access is limited and reviewed.
Frontline units own first-line controls; Risk/Compliance provide second-line oversight; Internal Audit provides third-line independent assurance.

Staffing plan aligned to product scope and regulatory requirements
Present a phased hiring plan tied to milestones (licensing/charter readiness, launch, branch openings, new product rollouts). Specify which roles must be in place before launch (often: CRO, CCO/BSA-AML, Internal Audit coverage, financial controller, core operations leads, information security leadership). Include how staffing scales with account volumes, loan growth, and customer support demand. Describe use of outsourced support where appropriate (e.g., outsourced Internal Audit, specialized compliance testing, penetration testing), and how the bank will oversee vendors.

Recruitment standards and background screening
Explain hiring criteria for regulated roles and customer-facing staff. Include:
Minimum experience requirements for executives and key control functions
Pre-employment checks (identity, employment/education, criminal where permitted, credit checks where appropriate, conflicts of interest declarations)
Fit-and-proper assessments for senior managers and board members (as applicable)
Ongoing licensing/registration and continuing education requirements (where applicable)

Training and competence management
Describe mandatory training programs and how completion is tracked. In banking, typical training includes:
BSA/AML and sanctions awareness
Consumer protection and fair lending/anti-discrimination obligations
Information security, privacy, and secure handling of customer data
Operational controls (dual control, cash handling, payments approvals)
Fraud awareness and escalation procedures
Code of conduct, conflicts of interest, and whistleblowing channels
Role-specific training for credit underwriting, collateral documentation, and collections

Performance management and incentives
Set out how the bank will evaluate performance without encouraging excessive risk-taking. Include principles such as: balanced scorecards (growth, profitability, risk, customer outcomes), quality metrics (delinquencies, complaint rates, audit findings), and clawback/adjustment provisions for material control breaches. Specify who approves incentive plans (typically the Board/Compensation Committee) and how compliance/risk sign-off is embedded.

Culture, ethics, and conduct risk
Explain the values and expected behaviors, and how leadership will reinforce them. Practical mechanisms include: a documented code of ethics, speak-up policies, independent investigation processes, and consequences for policy breaches. Describe how the bank monitors conduct risk through customer complaints, call monitoring (where used), sales quality reviews, and root-cause analysis of incidents.

Succession planning and key-person risk
Identify critical roles (CEO, CRO, CCO/BSA-AML, Treasury/ALM, Head of IT Security, Head of Credit) and outline succession coverage (deputy roles, interim arrangements, documented runbooks). Explain how knowledge is retained through procedure documentation, cross-training, and controlled access to key systems and vendor relationships.

Decision-making forums and management committees
List the internal committees that drive discipline and documentation. Common examples:
ALCO (Asset-Liability Committee): liquidity, funding, interest rate risk, pricing governance
Credit Committee: approval governance, exceptions, portfolio limits, watchlist actions
Operational Risk Committee: incident management, KRIs, control testing results, business continuity readiness
Compliance Committee: regulatory change, monitoring results, consumer issues, remediation tracking
Information Security Committee: threat landscape, vulnerability management, incident response preparedness

Internal Audit approach
State whether Internal Audit is in-house or co-sourced and how independence is maintained (functional reporting to the Audit Committee). Summarize the risk-based audit plan coverage: lending, deposits, payments, AML program, cybersecurity, third-party risk, financial reporting controls, and branch operations (if applicable). Describe issue tracking, remediation ownership, and timelines.

What to include in the business plan appendices
To make this section actionable, attach or reference:
Management biographies highlighting relevant banking experience and prior regulatory interactions
Role descriptions for key positions (CEO, CFO, CRO, CCO/BSA-AML, Head of Credit, Treasurer, CISO, Head of Operations)
A hiring timeline by quarter tied to operational milestones
Committee charters and sample reporting packs (risk dashboard, ALCO report outline, compliance monitoring plan outline)
Policies roadmap (credit policy, AML program, information security, vendor management, complaints handling, business continuity)