De novo institutions, charter conversions, fiduciary-power applications, reorganizations, and new activities can involve compliance work alongside legal, financial, capital, governance, and operational workstreams.

InnReg can support the compliance portions of these projects while coordinating with the institution's counsel, accountants, management, and other advisers. We do not treat compliance documentation as separate from the operating model the institution will need to maintain after approval.

Support can include:

• Regulatory and compliance analysis of proposed activities

• Compliance governance and organizational design

• Compliance program and policy documentation

• Business and control descriptions

• BSA/AML and consumer-compliance readiness

• Coordination of compliance-related regulatory responses

• Implementation and pre-launch readiness planning

For national-bank applicants limited to trust-company operations, the OCC's chartering framework expressly addresses national trust-bank charters and was updated in 2026 to clarify the authority of such banks to conduct trust-company operations and related activities.

An institution's compliance framework should reflect its actual products, customers, branches or channels, fiduciary activities, systems, staff, control functions, and regulatory obligations.

InnReg develops new compliance programs and helps established institutions update policies, procedures, and controls that no longer reflect the business or current regulatory expectations. The engagement can address an institution-wide program or a defined business line or regulatory area.

Representative areas of support include:

• Compliance and BSA/AML risk assessments

• Policies, procedures, and control frameworks

• Deposit and payment compliance

• Lending and fair-lending procedures

• Trust, fiduciary, and custody procedures within scope

• Privacy and information-security policies

• Complaint, escalation, and remediation processes

• Training and compliance calendars

• Management and board reporting workflows

• Implementation and operational-readiness support

Compliance programs need continuing administration after they are built. Regulatory changes need to be evaluated, policies updated, customer issues reviewed, required filings and reviews completed, findings remediated, and management kept informed of material compliance matters.

InnReg can work as an extension of an established compliance department and administer agreed recurring workstreams. The operating model identifies what InnReg performs, what requires institutional review or approval, and which responsibilities remain with designated officers, management, the board, internal audit, or other control functions.

Ongoing support can include:

• Compliance-calendar management

• Policy and procedure maintenance

• Regulatory-change monitoring

• BSA/AML operational support

• Consumer-compliance reviews

• Complaint and issue management

• Compliance training coordination

• Regulatory reporting support within scope

• Findings and corrective-action tracking

• Management and committee reporting support

Banks and trust institutions often already have defined governance structures and designated compliance personnel. Outside support therefore needs to complement those structures rather than blur regulatory accountability.

InnReg can supplement an internal Chief Compliance Officer, BSA compliance officer, or broader compliance department and can provide interim or fractional compliance leadership where appropriate to the institution, role, governance framework, and supervisory expectations.

Support can include:

• Additional senior compliance capacity

• Program administration and work planning

• Support for the CCO or BSA compliance officer

• Board and management reporting preparation

• Regulatory-change and new-activity coordination

• Oversight of agreed remediation initiatives

• Coordination across compliance, operations, risk, legal, and other functions

• Interim support during personnel transitions

The BSA compliance officer is specifically designated by the institution's board and is responsible for coordinating and monitoring day-to-day BSA compliance. The board remains ultimately responsible for the bank's BSA/AML compliance and for providing the officer with appropriate authority, independence, and resources.

An institution needs evidence that its compliance controls are appropriately designed and operating as intended. Testing can identify weaknesses before an examination, validate remediation, or satisfy independent-review requirements where the engagement meets the applicable independence standard.

InnReg can perform targeted compliance reviews and support examinations conducted by the OCC, Federal Reserve, FDIC, NCUA, state banking or trust regulators, and other applicable authorities.

Testing and examination support can include:

• BSA/AML independent testing where independence requirements are satisfied

• Consumer-compliance testing

• Deposit and payment sample reviews

• Lending and fair-lending control testing

• Trust or fiduciary control reviews within scope

• Policy implementation and evidence testing

• Regulatory examination readiness

• Document-request and response coordination

• Findings analysis and corrective-action planning

• Remediation validation and follow-up testing

BSA/AML independent testing may be conducted by qualified bank personnel or an outside party, but the tester should not be involved in the functions being tested or in other BSA activities that create a conflict or compromise independence. There is no fixed regulatory frequency for BSA/AML independent testing; frequency should be commensurate with the institution's risk profile and risk-management strategy.

A bank's existing compliance framework may need to change when it introduces a new deposit product, payment capability, lending program, fiduciary service, custody offering, customer segment, delivery channel, technology, or other material activity.

InnReg can assess those changes before implementation or evaluate an existing compliance program where management wants an independent view of identified or potential gaps.

Assessments can address:

• New product and activity implications

• Applicable consumer and BSA/AML requirements

• Customer journeys and operational workflows

• Fiduciary or custody considerations

• Governance and control responsibilities

• Required changes to policies and procedures

• Regulatory notification or approval considerations

• Gaps between documented controls and actual practices

• Examination or internal-audit findings

• Prioritized remediation and implementation plans