Faisal KhanAnswered Oct 19, 2026I would start by making the banking requirement clear. Explain what the business does, who owns it, where it operates, and what each account will be used for. An operating account and an FBO account for client funds serve different purposes, so describe both requirements separately.
For an initial banking review, I generally ask for:
- Certificate of incorporation and relevant state filings.
- Operating agreement or bylaws.
- EIN confirmation letter.
- Ownership structure and beneficial-owner information.
- Relevant licensing, registration, or agent-status documentation, clearly distinguishing applications from approvals.
- A business plan and realistic transaction forecasts.
- The banking partner’s completed application forms.
The forecast should explain expected monthly volume, transaction sizes, payment corridors, and the nature of incoming and outgoing payments. Give the bank enough information to understand how the account will actually operate.
Banks assess MSB relationships according to their risks. Depending on that assessment, they may also review the AML program, independent testing, operating procedures, and agent arrangements. FinCEN’s interagency MSB banking guidance explains this risk-based approach.
Once the profile is clear, the next step is matching it with a bank that supports the required account structure, payment rails, and corridors. Ask about setup charges, minimum balances, and ongoing fees. Documentation requirements and timelines vary by institution; a complete application helps the review but does not guarantee approval.