Obtaining a regulatory passport for a neobank
Initially, the process was stalled due to formal deficiencies. We took over communication with the office, which allowed for a smooth passage of the procedure in 97 days instead of the planned 200.
The VeloDigital project was stuck at the stage of verifying capital requirements. We changed the strategy of communication with the regulator, which allowed the neobank to enter the market much ahead of schedule.
The challenge
The client had been waiting for an administrative decision since August 2023. The office sent successive requests to supplement documentation, and each of them froze the process for at least 31 days. The VeloDigital team spent 146 hours preparing responses that were rejected due to ambiguities in the interpretation of fintech regulations. The costs of maintaining technical readiness of personnel were 14,300 PLN per day, and the lack of a passport prevented acquiring the first of the planned 12,400 test users.
Our approach
We started with an audit of 24 documents previously sent to the office. We appointed a two-person team: Marek Zarychta and Agnieszka Woźniak analyzed every remark of the supervisor. We resigned from sending more general letters. Instead, we organized three technical working meetings at the office at Plac Powstańców Warszawy. Fintech is our specialty, so we talked to officials in the language of specifics and system architecture, not marketing promises. We act quickly and precisely, so we consulted every change in documents with the client's lawyers within 4 hours of receiving remarks.
The solution
We developed a new, 84-page package of technical and operational documentation. It contained precise answers to 17 key doubts regarding the safety of client funds. We implemented a new risk reporting protocol that met the requirements of the office without the need to rebuild the bank's entire IT system. Facts matter, not promises, so we showed real system stress tests on a sample of 5,280 simulated transactions per second.
Results
Thanks to a change in approach and direct involvement in talks with officials, the procedure ended with a decision in less than four months. The client avoided another round of bridge financing and was able to launch the application in the planned market window.
Timeline
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January 2024Audit of existing correspondence and identification of 17 formal blocks.
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February 2024Submission of the corrected package of 84 pages of technical documentation.
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March 2024Clarification session with the department of payment systems supervision.
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April 2024Receiving a regulatory passport and official operational launch.
"Suprasorte knew exactly where the problem lay in our papers. Instead of writing generalities, they went to the office with hard data. This saved us several months of nerves and real money."