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Financial Services → Infrastructure for Bank Charters
How to get a bank charter? It starts with your infrastructure
Getting a bank charter feels like a capital story. Raise enough money. Hire experienced leadership. Build the right board. Submit the application.
But regulators don’t approve balance sheets. They approve institutions, and institutions run on infrastructure.
If you want to understand how to get a bank charter today, you have to start with the systems, controls, and environments that will support that charter on day one.
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What regulators really evaluate in a bank charter application
When organizations think about the OCC or FDIC approval process, they often focus on capital adequacy and executive experience. Those matter. But they only tell part of the story.
Regulators evaluate:
- Capital strength and funding model
- Management capability and governance
- Risk management framework
- BSA/AML and consumer compliance programs
- Operational resilience and technology controls
Operational risk is inseparable from technology risk. If your systems fail, customers feel it. If your data leaks, regulators respond. If your infrastructure collapses under load, that becomes a safety and soundness issue.
Your infrastructure is part of your charter narrative whether you acknowledge it or not.
Why infrastructure is now a charter-level issue
Banking used to run on branches and batch processing. Today it runs on APIs, digital onboarding flows, fraud engines, analytics platforms, and customer-facing applications.
Regulators understand this shift. They now examine technology architecture as part of the institution’s overall stability.
Technology is part of your safety and soundness profile
Examiners look at:
- Core systems and how they integrate with digital layers
- Customer-facing applications and uptime history
- API exposure and third-party connectivity
- Incident response procedures
An outage is no longer just a technical inconvenience. It can trigger consumer complaints, reputational damage, and regulatory scrutiny. If your institution is digital-first, your infrastructure is your bank.
Data protection is a regulatory expectation, not a feature
Charter applicants must demonstrate alignment with frameworks such as:
- FFIEC guidance
- GLBA safeguards requirements
- NIST-based cybersecurity controls
Regulators expect to see:
- Encryption at rest and in transit
- Role-based access controls
- Centralized logging and audit trails
- Documented key management practices
- Data classification policies
You cannot “add compliance later.” Your data controls must exist before approval.
Business continuity must be proven, not promised
Examiners don’t accept theoretical resilience. They want evidence that your systems can survive cyberattacks, outages, and regional disruptions.
Disaster recovery plans must include:
- Defined RTO and RPO targets
- Geographic redundancy
- Failover procedures
- Regular testing and documented results
The infrastructure checklist behind every successful charter
Organizations that move smoothly through the bank charter process treat infrastructure as a structured discipline, not an IT afterthought.
At a minimum, regulators expect:
- A documented cybersecurity framework aligned to FFIEC or NIST
- A formal vendor risk management program
- SOC reporting and third-party audit documentation
- Incident response plans with defined escalation paths
- Change management controls
- Board-level oversight of IT risk
- Independent penetration testing and vulnerability assessments
Non-core but mission-critical systems must meet bank-level standards
Many of the systems most critical to growth don’t belong inside your core platform:
- Public websites and digital experience layers
- Account opening front ends
- Middleware and integration services
- Fraud analytics platforms
- Regulatory reporting environments
- Data warehouses and analytics engines
These systems drive trust, revenue, and compliance. They are non-core, but they are not optional.
Infrastructure supporting these workloads must be:
- Isolated from shared, generalized environments
- Performance-stable under load
- Audit-ready and examiner-visible
- Governed by documented controls
How to design infrastructure with the charter in mind
The most successful charter applicants design infrastructure deliberately, with regulatory expectations mapped from the beginning.
Start with regulatory mapping
Tie every system to:
- Applicable regulatory requirements
- Data classification standards
- Control frameworks
If you cannot map a system to a control, you cannot defend it during an exam.
Define ownership boundaries clearly
Document:
- What resides inside the core platform
- What runs in isolated infrastructure
- Who owns monitoring, patching, and incident response
- How escalation flows to executive leadership
Clear responsibility models reduce operational confusion and examiner concern.
Choose infrastructure built for regulated workloads
Not all hosting environments support regulated financial workloads. Infrastructure supporting a charter-ready institution must provide:
- Isolation and segmentation
- Predictable performance
- Documented audit readiness
- Transparent logging and monitoring
- Defined accountability
Why infrastructure is the foundation, not the afterthought
Capital gets you in the conversation. Governance earns trust. Infrastructure proves operational maturity.
If regulators don’t believe your systems can support secure growth, they will question the institution itself. That means, “How do we get a bank charter?” is not only a financial or legal question: it’s an infrastructure question.
Bank charter FAQs
Getting started with your bank charter infrastructure strategy
A bank charter signals stability, trust, and regulatory accountability. Infrastructure underpins every one of those promises.
Start with a formal infrastructure gap assessment aligned to FFIEC and OCC expectations before submitting your application. Map controls, document ownership, and test resilience.
If you need to upgrade your infrastructure, Liquid Web can help. Our financial services hosting solutions are built to support non-core but mission-critical workloads in regulated environments.
Specialty Cloud delivers isolated environments, predictable performance, audit readiness, and clear responsibility models that complement your core banking platform and support growth without increasing risk.
Click through below or start a chat now with a financial services hosting expert to learn more.
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Kamila Thompson is Senior Director of Growth at Liquid Web, with over 15 years of experience driving strategy in highly regulated financial services environments. She spent more than a decade at TransUnion, where she operated under strict regulatory and data privacy requirements. Kamila specializes in building scalable growth engines that balance compliance, analytics, and measurable business impact.