Private Banking Business Plan Template

Where Private Banking Sits in 2026

Private banking is no longer the quiet corner of wealth management it was twenty years ago. PwC's 2025 Global Asset & Wealth Management Report projects total industry assets under management will rise from $139 trillion in 2024 to $200 trillion by 2030, a 6.2% compound annual growth rate (PwC, 2025). Private markets alone — credit, equity, infrastructure, real estate — are forecast to deliver more than half of total industry revenue by the end of the decade, which redraws the product shelf for any founder writing a business plan today.

The pure private banking revenue pool is smaller than the AUM headline suggests. The Business Research Company sizes the global private banking market at roughly $673.9 billion by 2029 at a 7.4% CAGR (The Business Research Company, 2025). In the United States, IBISWorld puts private banking services revenue at $114.7 billion in 2025 with a five-year CAGR of 7.3% (IBISWorld, 2025). Asia keeps redrawing the league table — the top ten houses in Asia crossed $2.5 trillion in regional AUM last year and total Asia private banking AUM passed $4 trillion for the first time, with JPMorgan entering the Asia top three (Asian Private Banker, 2025).

At the very top, the gap between leaders and challengers is widening. UBS group invested assets exceeded $7 trillion in 2025, up roughly 15% year-on-year, with the Global Wealth Management division alone in the $4.5–5 trillion range. Bank of America's wealth division sits near $4.8 trillion, JPMorgan around $4.6 trillion, Goldman Sachs around $3.6 trillion (Easy Global Banking, 2025). For a new entrant the takeaway is simple: do not try to compete with UBS on platform breadth. Win on a defined niche — a profession, an asset class, a geography, a tax situation — that the global houses cannot serve profitably below their own minimums.

Two macro trends matter for the plan you are writing. First, the next-gen wealth transfer — Cerulli has the figure near $84 trillion moving between generations across North America by 2045 — means relationships built with founder clients in their 60s and 70s will need to be re-earned with daughters, sons and beneficiaries in their 30s and 40s. Plans that bake in next-gen onboarding, digital reporting and impact mandates win. Second, fee compression on vanilla equity allocations is real, while fees on alternatives, lending and tax structuring have held. A credible 2026 plan over-weights advice that competitors find hard to commoditise.

A third dynamic is worth flagging in the industry section of any plan: the rise of the independent RIA channel as a competitor to traditional bank-owned wealth divisions. Cerulli, Echelon Partners and DeVoe & Company all track persistent advisor migration out of wirehouses and bank wealth divisions into independent RIAs. The independent channel has captured a steadily growing share of net new HNW assets each year for over a decade. For founders, that means recruiting senior advisors from a wirehouse or a bank-owned private wealth division is genuinely viable in 2026 — but compensation must reflect the deferred-comp and forgivable-loan packages they would otherwise be writing off when they leave. Build that into the financial plan as a Year-1 cash item, not a goodwill amortisation.

Finally, regulators on both sides of the Atlantic have stepped up scrutiny of conflicts and fee disclosures since 2022. The SEC's Marketing Rule, Reg BI for retail accounts, and the FCA's Consumer Duty all require firms to evidence not just that fees are disclosed, but that they represent fair value to the client. That diligence belongs in the operations and compliance sections of the plan, not as boilerplate.

Questions Founders Ask Before Filing

The same questions surface every week from founders we work with. Short answers below; the rest of the page goes deeper.

Capital, Setup & Funding the Build

Almost every founder we meet starts the conversation with the same number — and it is almost always wrong, because the question they should be asking is which of three structures they are actually building. The cost of opening a registered investment advisor in Boston that manages $250M of HNW money is nothing like the cost of obtaining an OCC charter. We separate them out below.

Path A — Boutique Wealth Advisory / RIA

This is the realistic path for the vast majority of plans we write. A two-partner team leaves a wirehouse, registers with the SEC (or with their state regulator below the $110M AUM threshold), files a Form ADV and opens custody at Schwab Advisor Services, Fidelity Wealthscape or Pershing X. Setup cost lands in the $250,000–$1.2M (£200K–£900K) range, including 12 months of working capital before AUM-based revenue catches up to fixed cost. Compliance counsel for a single-state RIA registration starts at around $8,000 (LPL, 2024). Founders moving portable books often raise nothing externally beyond their own capital plus a single LP family office cheque.

Path B — National Trust Company or State-Chartered Trust Bank

A useful middle layer once a wealth practice approaches $750M–$1B in AUM and clients want lending against portfolios, custody under the firm's own name and trust services (revocable, irrevocable, dynasty). South Dakota, New Hampshire, Nevada and Tennessee all run business-friendly trust company regimes with capital expectations in the $2M–$5M range, plus another $1M–$3M in working capital and tech.

Path C — Full Chartered Private Bank

A federal OCC charter or a state non-member bank charter with FDIC insurance. Initial capital expectations from federal and state regulators sit in the $15M–$25M range for a US private bank, with $5M–$10M of additional setup spending on legal, technology, premises and pre-revenue payroll (OCC Charters & Licensing). FINMA expects CHF 10M paid-up minimum with CHF 20M typical for a niche private bank in Switzerland, plus CHF 500K–CHF 2M just in legal and advisory fees for the application itself (FINMA, 2026).

Where the Money Goes (Path A — RIA build, illustrative $850K)

• Compliance counsel, Form ADV, IPS, AML programme: $30K–$80K (£24K–£64K)
• RIA platform & tech stack — Black Diamond / Addepar / Orion / RightCapital: $40K–$140K Year 1 (£32K–£112K)
• CRM (Salesforce Financial Services Cloud or Wealthbox) + e-signature + document vault: $20K–$60K (£16K–£48K)
• Custodian onboarding (Schwab Advisor Services / Fidelity / Pershing X): $10K–$30K (£8K–£24K)
• Cybersecurity, MDR, SOC2 readiness (HNW data is a target): $30K–$120K (£24K–£96K)
• Brand, website, photography, client-facing collateral: $25K–$90K (£20K–£72K)
• Office (1,500–2,500 sqft client-facing) + furniture + AV: $50K–$220K (£40K–£176K)
• Professional indemnity / E&O insurance: $25K–$80K Year 1 (£20K–£64K)
• Working capital — 12 months of partner draws and ops payroll: $200K–$500K (£160K–£400K)

Funding Routes

Most boutique private banking founders self-fund the early build — partner equity from prior wirehouse deferred compensation, supplemented by a single anchor client or family office writing a credit facility against expected AUM. Bank lending against an RIA practice is now well understood; firms like Live Oak Bank (FL), Oak Street Funding and PPC Loan write SBA and conventional loans up to $5M against forecasted AUM cash flow. SBA 7(a) is available up to $5M with terms to 25 years and is increasingly used by RIAs taking out a retiring founder. In the UK, Tier 1 private banks raising bank capital go via institutional rounds; smaller IFAs and wealth managers use Iress, Praemium, Hoxton Capital and similar to leverage growth.

A useful intermediate option for founders unwilling to take outside equity: an RIA aggregator partnership. Hightower, Mariner Wealth Advisors, Mercer Advisors and Captrust will each write a sub-acquisition cheque or a partnership investment against a forecast AUM book. The cheque comes with platform support — back-office, compliance, technology, M&A pipeline — but at the cost of equity dilution and brand subordination. For founders whose primary goal is independence, this trade is rarely worth it; for founders whose primary goal is scaling fast and exiting in seven to ten years, it can compress the journey by half.

For Path C builds, capital usually comes from a small group of high-net-worth founder shareholders plus, increasingly, a strategic minority investor — often a non-bank financial holding company or a family office aligned with the founders' niche. The OCC and the PRA both pay close attention to the source of capital and the long-term commitment of qualified shareholders, so layered SPV structures that obscure beneficial ownership tend to fail the fit-and-proper review. Plan to disclose ultimate ownership and lock-up commitments transparently in the application from the start.

Three Routes Into the Industry, Side by Side

The table below is the single most important diagram in any private banking plan. Get the chosen structure wrong and the regulator will reject the application before the merits are read.

Most of the founders we speak to land on Path A and add Path B (a New Hampshire or South Dakota trust company) within three to five years once AUM crosses $750M. Path C is genuinely rare — fewer than ten new US bank charters were granted in many recent years. Be sure that path is necessary before you commit to a $20M capital raise plus an 18-month application calendar.

Fees, AUM Economics & Margin

Private banking revenue is built from four streams that recur year after year. A credible plan separates them cleanly so a lender or LP can see what is contractual, what is performance-linked, and what is one-off.

The Four Revenue Streams

• AUM-based management fee — typically 60–120 basis points annually. Discretionary mandates in Switzerland sit in the 0.60%–1.20% range; US RIAs running held-away portfolios commonly land at 75–100 bps for the first $5M, stepping down at $10M and again at $25M.
• Planning & advice retainers — flat fees of $5,000–$50,000 per household per year for tax planning, estate work, business-sale support and concentrated-stock strategies. These stabilise cash flow when markets pull back AUM fees.
• Net interest margin — only available to chartered banks and trust companies. Lombard loans against portfolios at SOFR + 75–200 bps; mortgage and structured credit at competitive rates. NIM can be 25–35% of revenue in a mature private bank.
• Performance fees on alternatives — typically 10–20% above an agreed hurdle, available where the firm runs its own private credit or equity sleeves. Be conservative in projections; this is the most volatile line.

A Worked Example — $250M RIA at 18 Months

Two senior advisors with portable books reach $250 million in AUM eighteen months after launch. Blended fee schedule averages 85 bps. Revenue model:

That margin moves with AUM concentration. A book where the top three relationships make up more than 35% of AUM is fragile; lenders and acquirers discount it heavily. A diversified book of 80–120 households at $1M–$5M average size is what buyers actually pay 7–9× EBITDA for in the US RIA M&A market. Build the plan to that benchmark.

How Fees Compare Across the Top Houses

Goldman Sachs Private Wealth Management starts at a $10M minimum and earns its fee through alternatives access, bespoke credit and concentrated-stock work; Morgan Stanley Private Wealth Management opens at around $5M and competes on syndicate access; UBS Wealth Management runs deeper minimums in Asia and the Middle East than in the US. A boutique cannot match that platform breadth — but it can compete on advisor-to-client ratio (1:25 is realistic at a boutique vs. 1:150 at a wirehouse) and on response times that still beat any global house's middle office.

Julius Baer, Pictet and Lombard Odier — the Geneva and Zurich houses — operate on slightly different mathematics. Their cost-income ratios are typically managed in the 65–75% range, with the difference made up through transactional revenue (FX, structured products) layered on the AUM fee. A founder modelling a Swiss-domiciled or DIFC-domiciled boutique should benchmark against those cost-income ratios rather than the US RIA EBITDA-margin frame; the language a regulator and a Tier-1 acquirer expect is different.

Coutts in the UK and Brown Brothers Harriman in the US sit in a useful middle zone for benchmarking — long-established but smaller than the UBS/JPM/GS triumvirate, with published service standards and minimums that a new entrant can read directly from their public materials. When the plan needs a competitor matrix, those two houses give the cleanest reference points outside the very top tier.

Licensing: OCC, PRA, FINMA & Beyond

Regulatory diligence is the single most under-budgeted line in early-stage private banking plans. Below is the working set we use with clients.

United States

• OCC charter (Path C) — pre-filing meeting required; full application; capital expectation $15M–$25M; FDIC deposit insurance approval runs in parallel; 12–24 months from first meeting to opening (Federal Reserve, 2024).
• State trust company charter (Path B) — apply with the relevant state banking commissioner. South Dakota Division of Banking and the New Hampshire Banking Department both publish clear application checklists. Capital floors $2M–$5M; review 6–12 months.
• SEC RIA registration via Form ADV (Path A, >$110M AUM) — file electronically through IARD; 45-day review window; ongoing Form ADV Part 2 brochure delivery and annual amendment.
• State securities registration (Path A, <$110M AUM) — register via NASAA in the founder's home state plus any state with five or more clients.
• FINRA exam stack — Series 65 (uniform investment adviser) or Series 66 if the advisor also holds Series 7. CFP Board certification is a near-universal credibility marker for HNW work.
• BSA/AML programme + designated AML officer — written policy, customer identification programme, OFAC screening, suspicious activity reporting through FinCEN. Budget $80K–$200K Year 1.
• State investment adviser representative (IAR) registration for each licensed advisor in each client state.

United Kingdom

• PRA & FCA bank authorisation (Path C) — the New Bank Start-up Unit at the Bank of England runs founders through a pre-application phase, then mobilisation, then full authorisation. Mobilisation lets the firm hold a restricted licence while completing build-out. Typical 12–18 months end-to-end (Bank of England, New Bank Authorisation).
• FCA permission for Discretionary Investment Management or Advising and Arranging — the practical Path A in the UK. Application runs 6–12 months; capital is risk-weighted under MIFIDPRU. Founders also bring in PII at FCA-prescribed minimums.
• Senior Managers & Certification Regime (SM&CR) — every senior manager must be approved with a defined Statement of Responsibilities; a Senior Manager Function (SMF) map must be filed.
• HMRC registration for Money Laundering Regulations supervision if not supervised by the FCA.
• ICO registration for data protection — annual fee £40–£2,900 depending on size.
• Companies House incorporation and PSC register filings.

Switzerland — FINMA Banking Licence

• Paid-up capital of at least CHF 10 million, with FINMA expecting CHF 20 million for a niche private bank.
• Three-to-five-year business plan demonstrating capital adequacy, liquidity and risk diversification at all times under stress.
• Fit-and-proper test for board, executive committee and qualified shareholders (10%+ stakes).
• Substance in Switzerland — head office in CH, sufficient employees on payroll, on-site compliance and risk officers before opening.
• External audit appointment — only FINMA-approved audit firms (Big Four, BDO, Mazars, etc.).
• Application cost — CHF 500,000–CHF 2,000,000 in legal and advisory fees alone, on top of capital.

Other Useful Jurisdictions

• Singapore (MAS) — Capital Markets Services Licence for fund management. Accredited-investor-only model: S$1M paid-up, no AUM cap on accredited clients. Approval window 4–6 months.
• UAE — DIFC (DFSA) or ADGM (FSRA) — Category 3C or 3A licence depending on activity. Base capital from US$500K to US$2M; office in the financial free zone is mandatory; approval 4–9 months.
• Liechtenstein (FMA) — alternative to Switzerland with EEA passporting; minimum capital CHF 10M for banks, similar fit-and-proper expectations.
• Cayman Islands — CIMA — Class B restricted banking licence used historically for offshore private banking; far less favoured post-CRS and FATCA.

Six Mistakes That Sink Applications

These are the failure modes we see most often in plans that arrive on our desk for triage.

1. Confusing the structure. Founders write a beautiful plan for a chartered private bank when the regulator they will actually face is the SEC for an RIA, or the FCA for a Discretionary Investment Manager. A plan written for the wrong regulator wastes six months. Pick the structure first; write the plan for it.
2. Hiring the MLRO last. Both the FCA and the OCC expect the Money Laundering Reporting Officer / BSA Officer named, vetted and signed up before the application is filed. Trying to add this hire at week 30 of an 18-month application stalls the file.
3. Treating KYC as one-off onboarding. Modern AML expectations are continuous — Know Your Transactions, ongoing source-of-wealth refresh, beneficial-ownership re-validation. Static PDF onboarding files are no longer acceptable; budget for transaction monitoring software (ComplyAdvantage, Featurespace, Quantexa).
4. Building self-clearing custody too early. Pershing X, Schwab Advisor Services and Fidelity Wealthscape exist for a reason. Below $1B AUM, building a self-clearing tech stack burns capital that should fund advisor hires.
5. Pricing on AUM alone in the first 18 months. AUM revenue lags onboarding cost. A $5,000–$15,000 planning retainer per household creates positive cash flow during onboarding and signals commitment to advice rather than asset gathering.
6. Underspending on cybersecurity. An HNW client data breach is firm-ending. Plans we approve include MDR (managed detection & response) from launch, SOC2 within 12 months, plus tabletop incident-response drills twice a year. This is not a corner to cut to make the spreadsheet work.
7. Modelling AUM growth as a straight line. Real onboarding is bumpy: a single $30M household lands, then nothing for ten weeks, then three $4M relationships in a fortnight. Plans that show a straight 6%-monthly AUM ramp tell a sophisticated reviewer the founder has not actually onboarded clients. Show a cohort-based ramp with realistic gaps and a sensitivity table for slow quarters.
8. Forgetting the trust-and-estate referral path. HNW clients usually arrive with an existing trust attorney and accountant. Plans that do not budget for centre-of-influence cultivation in Year 1 — joint webinars, fee-share referral agreements, intentional content for those COIs — undershoot net new asset targets in Year 2 because the inbound pipeline never gets primed.

We have also seen good plans get rejected for less obvious reasons: an over-confident discounted cash flow that bakes in 15% AUM CAGR through a recession; a Year-1 hiring plan that violates the SEC supervised-person rules; a marketing budget that violates the FCA financial promotion rules on testimonials and past performance. The plan needs to read as if a fiduciary wrote it for a fiduciary reviewer.

Sample Plan Preview

Below is an extract from an actual private wealth advisory plan our team produced — names changed, financials representative.

What's in the Template

Every Avvale private banking template ships with the sections a regulator, a lender, or a sophisticated LP expects to see. The free download covers the narrative; the paid tiers add the numbers.

• Executive Summary — written for the reader who has 90 seconds: structure, AUM target, capital ask and the founders' edge.
• Firm & Legal Structure — entity choice (LLC, S-Corp, LP), state of registration, ownership, regulator path, key person clauses.
• Industry Analysis — market size, segment growth, fee compression dynamics, the next-gen wealth transfer narrative.
• Target Client Profile — written by household archetype (executives mid-liquidity event, professional partners, multi-generational families, family-office prospects), with source-of-wealth, asset complexity and stickiness for each.
• Service Offering & Fee Schedule — discretionary vs. non-discretionary, planning retainer structure, alternatives access, lending arrangements.
• Competitive Positioning — boutique vs. wirehouse, vs. RIA aggregator, vs. multi-family office.
• Operations & Tech Stack — custodian, portfolio accounting, planning software, CRM, communications, cybersecurity, document vault.
• Compliance & Risk — written supervisory procedures, code of ethics, AML/BSA, business continuity, cyber, vendor risk.
• Marketing & Business Development — referral architecture, COI mapping, intentional content, events, conditional digital presence.
• Management Team & Advisory Board — bios, fiduciary track record, regulatory history, planned hires.
• Financial Plan — 5-year P&L, balance sheet, cash flow, AUM model with rolling cohorts, sensitivity to net inflows and market beta.

The optional Financial Forecast add-on (included in our $300/£250 and $1,000/£800 packages) provides a 5-year Excel model with rolling AUM cohorts, net new asset assumptions, fee tiering, partner draw schedules and a break-even chart that lenders accept without rework. Ask us for the private-banking-specific extension if you are pursuing Path B or Path C — it includes a regulatory-capital and liquidity-coverage sheet built to OCC and PRA reviewer expectations.

For wider context, browse our full library of free business plan templates, or look at the related plans for wealth management, financial advisor and family office structures.

Frequently Asked Questions