Reglator

Decision / Operating model

Approving a new bank programme

What would this programme change about the bank?

Committees are asked to approve programmes on the basis of the partner's plan. The question they actually have to answer is what the programme would change about the bank.

Simulation produces that view, with alternatives, so approve, restructure and decline can be compared on the same basis.

Regulatory delta

What this decision tends to move

The delta is the difference between the institution's position today and its position if this decision were executed.

Activity
What the bank would be doing.
Permissions
Whether it fits existing authority.
Governance
What oversight the programme requires.
Concentration
How the programme changes exposure.
Judgement
Where supervisory expectation decides.

Design space

Ways to reach the same commercial objective

Two configurations that achieve the same outcome frequently produce materially different regulatory deltas. Comparing them is how the decision is made.

Option 01

Approve as proposed

Full delta accepted.

Option 02

Approve with structural conditions

Delta reduced deliberately.

Option 03

Decline or defer

Delta avoided, opportunity cost taken.

Before committing

What management should establish first

  • What changes about the bank, in plain terms
  • Which conditions would reduce the delta most
  • What would need re-testing after launch

Common questions

Questions this page answers

Does this replace the bank's own risk assessment?

No. It supplies comparable options and a record of what was tested, earlier in the process.