The Mission

Incorporate the holding company structure. Register with FinCEN as a Money Services Business. Engage regulatory counsel. This is paperwork — do it right, because everything downstream depends on it.

Identify and negotiate a sponsor bank relationship. This takes longer than most fintechs expect — and longer still for a bank that serves the customers we do. The bank that says yes needs to understand our mission, our compliance posture, and our risk controls before we go live.

Simultaneously: build the BSA/AML program, KYC/KYB stack, and transaction monitoring infrastructure. These are operational before the first account opens.

A note on state licensing: under a proper sponsor bank structure, state Money Transmitter Licenses are generally not required — the bank's charter covers money transmission. We pursue MTLs only for specific product functions that fall outside our sponsor bank's coverage, not as a blanket parallel licensing strategy.

Limited rollout with sponsor bank live. We onboard a controlled cohort of creators and legal businesses, stress-test our compliance and operations under real conditions, and fix what breaks before we scale.

Expand onboarding across our target verticals. Grow the customer base. Raise a Series A — not just to fund operations, but to demonstrate to future regulators that Free Bank has durable capital backing.

We also begin correspondent banking discussions here. ACH, wire, and card network relationships take time to establish, and some counterparties will have the same instincts as the banks we're replacing. Building these relationships early, while the sponsor bank provides a buffer, is how we avoid surprises later.

We file for a Wyoming Special Purpose Depository Institution (SPDI) charter — a path Wyoming created specifically for fintech and financial infrastructure companies. An SPDI allows us to hold our own deposits and provide payment services under our own charter, without the Bank Holding Company Act overhead of a full commercial bank.

Critically, the SPDI moves faster than an ILC. It gets Free Bank out of sponsor bank dependency for deposit-taking years before a full bank charter is in hand. If you're a creator banking with us, your deposits are ours — not routed through a third party — well before the full buildout is complete. Kraken Bank went this route. So do we.

In parallel: we build the core banking systems, deposit operations, and regulatory reporting infrastructure required for a full charter. We hire the team — Chief Compliance Officer, Chief Risk Officer, operations staff with prior charter experience. We raise a Series B.

Wyoming SPDI approved and operational. Free Bank holds its own deposits under its own charter. This is a genuine independence milestone — not the finish line, but no longer dependent on a third party for our core function. Our sponsor bank relationship narrows to any remaining product functions the SPDI doesn't yet cover.

We begin formal pre-filing dialogue with the FDIC and Utah Department of Financial Institutions ahead of our Industrial Loan Company application. These meetings shape the application — we expect feedback, and we revise accordingly.

We also engage proactively with legislators. ILC applications attract political attention. We go in knowing that.

We submit the Industrial Loan Company charter application to Utah DFI and the FDIC. The ILC structure is right for Free Bank: it allows a commercial parent to own a federally recognized bank without becoming a bank holding company subject to Federal Reserve oversight — preserving our operational flexibility while giving us the full charter we need.

This begins a formal review process that typically takes 18–36 months. We do not publish a target approval date because we will not manufacture one.

We respond to FDIC information requests, continue operating and growing under the SPDI, and continue our advocacy work. A bank that exists to fight debanking doesn't go quiet during its own regulatory review.

Conditional approval received. We complete the capital contributions, systems audits, and examination readiness work required before full activation.

Full charter activation. Free Bank is a federally recognized bank. Full product suite. No third parties whose interests can override our commitments to customers.

All legacy sponsor relationships wound down. Free Bank operates on fully independent infrastructure.