A specialty · De novo banks

Serving the de novo bank.

How we help a new bank govern risk, security, and AI from day one, through the charter, the pre-opening exam, and the de novo period that follows.

The charter changes the bar

Capable is not the same as bank-ready.

Examiners hold a new bank to a mature standard from day one, however capable the parent. Closing that gap is the work.

What the examiner expects

A named information security officer

A written security program and policy library

Vendor management and board reporting in force

Continuity and incident response, tested

What a charter adds

Your first examination under bank supervision

Bank-grade GLBA and FFIEC program expectations

Board-level information security governance

A named ISO accountable to the board

Where we fit

One partner across every phase.

No rebuild and no re-procurement as you move from charter to steady state. The same accountable partner the whole way.

01

Organizing

Charter and planning

Business plan and risk inputs for the charter and regulatory applications. The framework is chosen early.

02

Pre-Opening

Build the bank

Stand up infrastructure, the security program, the vendor stack, and the policy library the pre-opening exam expects.

03

De Novo Period

First three years

Carry the program through heightened supervision. vCISO coverage, board reporting, testing, and exam support.

04

Maturity

Steady state

Scale the program with the balance sheet, with the same partner and no rebuild.

What we bring

For a charter, the advisory and AI carry the work.

Risk advisory

A named virtual CISO

An accountable security officer and a full GLBA and FFIEC aligned program. Examiner ready before you open. The program →

Managed technology

Banking IT, run daily

We run banking IT and security operations every day. That operational fluency is what makes the advice credible. Managed IT →

AI advisory

Governance from day one

AI governance built in at the greenfield, not retrofitted later. The easiest place to get this right. AI Advisory →

What stands behind the advice

We know what examiners want now, not last year.

We sit in examinations across the country every month. A new bank gets the benefit of what examiners are focused on now.

$6B+

Client banks nationwide, from the low hundreds of millions to over $6 billion in assets.

OCC · FDIC · FRB

Experience across all three federal banking regulators.

Monthly

In audit and examination cycles, every month of the year.

How we engage

Predictable by design.

Pricing is a conversation we have once we have scoped your charter, not a number on a slide.

Flat fee

Not by the hour

A scoped advisory fee, with anything out of scope priced up front. You budget once and know the number.

Scalable

Scope grows with the bank

Start with what the charter requires. Expand as supervision and the bank mature. No rebuild.

Single

One accountable partner

Risk, governance, and AI under one engagement and one point of contact. The seams are our problem, not yours.

Thinking about a charter? Talk to us early.

The earlier we are in the room, the cleaner the build. We will tell you what the examiner will expect before you open.

Common questions

Straight answers, before the first call.

Examiners hold a new bank to a mature standard from day one, however capable the parent. A named information security officer, a written security program and policy library, vendor management and board reporting, and tested continuity and incident response all need to be in force before the pre-opening exam.

Four: Organizing (charter and planning), Pre-Opening (building infrastructure, the security program, the vendor stack, and the policy library), the De Novo Period (the first three years under heightened supervision), and Maturity (steady state, scaling the program with the balance sheet).

No. ImageQuest is the same accountable partner across every phase, from charter to steady state, so there is no rebuild and no re-procurement as the bank grows.

A named virtual CISO and a full GLBA and FFIEC aligned risk advisory program, banking IT and security operations run daily, and AI governance built in from the greenfield rather than retrofitted later.

We sit in examinations across the country every month, with client banks nationwide from the low hundreds of millions to over $6 billion in assets, and experience across the OCC, FDIC, and FRB.