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FinTech → Chartered Bank Roadmap

Transitioning ThinkMakes from a banking infrastructure "renter" to a full charter "landlord" — capturing Net Interest Margin, full interchange, and institutional valuation multiples.

Current

FinTech / Partner Bank

→

Target

OCC / ILC Charter

→

Exit

1.5–2.5x Book Value

Two Paths to Charter Ownership

De Novo Path

Build from Scratch (Varo Model)

3–5 Years

$20M–$50M Tier 1

✅ Pros

• Full control from day one

• No legacy liabilities

• OCC national charter

⚠️ Cons

• Longest timeline

• Highest capital requirement

• Extensive regulatory review

Acquisition Path

Buy to Play (SoFi Model)

12–18 Months

Varies (purchase price)

✅ Pros

• Fastest route to charter

• Existing FDIC insurance

• Established customer base

⚠️ Cons

• Requires cash to buy out owners

• Inherits legacy systems

• Due diligence complexity

⚡

The "Ramos 2028" Power Play: ILC Charter (Utah)

Recommended

An Industrial Loan Company (ILC) Charter allows a non-financial parent company (like ThinkMakes, a tech/political org) to own a full bank — without the same Bank Holding Company restrictions applied to commercial banks.

Why ILC?

Offers full banking services. Parent company (ThinkMakes) does not need to divest from other business lines. Available in Utah, Nevada, California.

Notable ILC Holders

Toyota Financial, BMW Bank, Square (Block), Nelnet — all non-bank parents owning FDIC-insured banks via ILC charter.

How You Get Paid as a Bank Owner

Net Interest Margin (NIM)

15–25% spread

vs. splitting with partner bank today

Take user deposits at 0.05% and lend at 15–25% via credit cards or business loans. Keep the entire spread.

Full Interchange Capture

1.5–2% per swipe

vs. partial share as a FinTech

Keep the full interchange fee on every card swipe instead of sharing 50–80% with Stride or Evolve.

Asset Appreciation (Exit)

1.5–2.5x Book Value

institutional acquisition premium

Chartered banks trade at multiples of Book Value. Your valuation jumps from "software app" to "regulated utility."

Immediate Steps (Before the $20M Charter)

Switch to Direct Deposit Model

Now

Negotiate higher revenue share with your partner bank based on deposit volume you bring in.

Lending Participation

Now

Help your partner underwrite loans to your 37+ projects and take a referral or servicing fee.

ILC Charter Research

6 Months

File for an Industrial Loan Company charter in Utah — allows a non-financial parent company to own a bank.

Raise Tier 1 Capital

1–2 Years

Begin capital raise targeting $20M through platform investors and the ThinkMakes Innovation Exchange.

Capital Requirements Snapshot

Path	Min Capital	Timeline	Regulator
De Novo (OCC)	$20M–$50M	3–5 years	OCC
Acquisition	Varies	12–18 months	OCC / Fed
ILC (Utah)	$10M–$20M	18–36 months	UDFI / FDIC