What It Costs to Start a Payment Bank with Fed Access

Establishing a payment bank with direct access to Federal Reserve rails is a significant undertaking that requires capital, compliance infrastructure, and regulatory credibility. Below is a breakdown of estimated costs and typical timelines involved in forming such an institution, whether through a Nevada-based payment charter, trust charter, ILC, or other eligible entity.

1. Regulatory Strategy & Application Preparation

  • Legal & Consulting Fees: $200,000–$400,000+ (includes feasibility analysis, entity structuring, and application drafting)

  • Application Retainers: ~$200,000 fixed, plus ongoing advisory ($20,000/month typical)

  • Accounting & Financial Modeling: $25,000–$75,000

  • Timeline: 3–6 months for application preparation

2. Licensing & Regulatory Filing

  • Filing Fees (State + Fed): $10,000–$75,000 depending on jurisdiction

  • Background Checks, Fingerprinting, Disclosures: $2,500–$5,000

  • Outside Legal Review: $50,000–$150,000

  • Timeline: 6–18 months for charter review, FDIC application, or FRB routing approval (varies by state and model)

3. Capitalization & Reserves

  • Initial Capital Requirements: Typically $5M–$25M depending on business model and jurisdiction (FDIC-insured institutions must meet Tier 1 capital thresholds)

  • Liquidity Requirements: Must maintain adequate reserves and demonstrate business continuity and solvency under stress scenarios

4. Compliance & Operational Setup

  • CMS Buildout (BSA/AML, UDAAP, etc.): $100,000–$250,000

  • Software & Infrastructure (core, ledger, KYC tools): $200,000–$500,000+

  • Staffing & Training (compliance, ops, exec): $500,000+/yr for minimal operating team

  • Insurance (E&O, D&O, cyber): $25,000–$75,000/year

5. Branding, GTM & Launch

  • Beta Launch via Sponsor Bank: Appliant Advisors helps clients establish sponsor bank partnerships that allow them to begin processing limited transactions and piloting their product while their charter or direct Fed access is still under review.

  • Marketing Compliance Review & Launch Planning: $25,000–$100,000

  • Website, Comms, Investor Materials: $10,000–$50,000

  • Customer Support, Onboarding, CX Systems: $50,000–$150,000

  • Timeline: 3–9 months after license is issued before full market launch

Estimated All-In Cost to Launch a Payment Bank:


$6 million to $30+ million, depending on capital strategy, licensing path, and market ambition.

Estimated Total Timeline:
18 to 30 months from regulatory strategy to market launch

Note: These costs are directional and vary significantly based on your licensing pathway (Nevada, ILC, Trust, etc.), sponsor partnerships, and federal engagement (e.g. FDIC insurance, FRB account access).

Appliant Advisors helps clients not only reduce the cost of missteps, but structure operations and teams that regulators trust—and markets embrace.