Library / Regulated business decisions

The decisions that change a regulatory position

Institutions do not get into difficulty by misreading a rule. They get into difficulty by taking a decision without seeing what it would change.

This library sets out the decisions US financial institutions most often need to simulate — what moves, what the alternatives are, and what should be established before commitment.

Simulate a decision

Product decisions

Product

Adding stablecoin settlement to a US payments business

Can we settle in stablecoins without changing what we are?

What can change in a US payments company's regulatory position when stablecoin settlement is introduced, and how the options compare.

Launching a customer wallet

Does giving customers a balance change what we are doing?

How introducing a customer-facing wallet can change a US institution's regulatory position, and which design choices matter most.

Holding customer balances

Should we hold funds ourselves, or keep them somewhere else?

What changes when a US institution begins holding customer funds, and how alternative structures compare.

Launching embedded accounts or cards on a platform

What does the platform become when it offers accounts?

How adding accounts or cards to a platform business can change what the platform is doing in regulatory terms.

Market decisions

Market

Entering a new US state

What does this state change that the last one did not?

How adding a US state can change licensing, supervision and operating requirements while the federal position stays the same.

Serving a new customer segment

Does a different customer make this a different business?

How a change in who the customer is — consumer, small business, regulated entity — can change an institution's regulatory position.

Operating model decisions

Operating model

Changing the custody model

Who should control the assets, and where should they sit?

How a change in who controls assets, and where, can move an institution's regulatory position and operating requirements.

Approving a new bank programme

What would this programme change about the bank?

What an approval committee should be able to see about how a proposed programme would change the bank's own regulatory position.

Scaling an existing programme

Is our approved position still valid at this volume?

Why the same programme at ten times the volume is a different regulatory decision, and what to re-test before scaling.

Structure decisions

Structure

Choosing a US entry structure

Which structure gives us the market with the smallest delta?

How entry structure shapes everything that follows for an institution entering the United States, and how the main routes compare.

Partnering versus holding your own permissions

Do we rent the permission or own it?

How the choice between operating through a licensed partner and holding permissions directly changes a US institution's regulatory position.

Changing partner bank or programme structure

What moves with the partner, and what stays with us?

What can move when a programme changes sponsor bank or restructures: permitted activity, oversight expectations and dependencies.

Common questions

Questions this page answers

What is a regulated business decision?

A product, market, operating-model, partnership or structural decision that can change an institution's regulatory position.

What does the decision library contain?

For each decision: the question management is actually asking, what tends to move in the institution's regulatory position, the alternative ways to reach the same commercial objective, and what should be established before committing.

Does the library tell me whether a decision is permitted?

No. It frames the decision and the consequences worth testing. Whether a specific configuration is permitted for a specific institution is what a simulation is for.

Simulation labWhat is a Regulatory Delta?Discuss a decision