Decision / Structure
Changing partner bank or programme structure
What moves with the partner, and what stays with us?
A partner change is often treated as procurement. In practice permitted activity, oversight expectations and operating requirements can all move with the partner.
Simulation makes the differences between two structures visible before the migration is committed.
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.
- Permitted activity
- What the programme is allowed to do.
- Oversight
- What the partner will expect to see.
- Controls
- What the programme must operate differently.
- State exposure
- Which states the structure covers.
- Continuity
- What breaks during migration.
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
Single new partner
Simple, concentrated.
Option 02
Dual partner structure
Resilience, duplicated obligations.
Option 03
Restructure with the existing partner
Smaller delta, less choice.
Before committing
What management should establish first
- What the new structure changes about permitted activity
- What migration requires operationally
- How the programme evidences the change
Common questions
Questions this page answers
Why does a partner change carry regulatory consequence at all?
Because much of a programme's position is derived from the partner's permissions and expectations, not only from its own.
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