Here's a confession: I haven't written a meaningful line of code in weeks. I've been reading OCC memos, CFPB enforcement actions, and BSA/AML guidelines instead. My mom thinks I'm joking when I describe my workdays. I'm not. This is what building a neobank looks like before the neobank exists. It's less about the product and more about understanding every possible way the government can shut you down.
And they can shut you down in ways you wouldn't expect. The CFPB recently decided that overdraft fees are actually credit products. That sounds technical and boring until you realize it means the rules that banks have operated under for fifty years just changed. Revenue models that worked last year might not work next year. I've watched well-funded companies get caught flat-footed by exactly this kind of thing, and I'd rather be paranoid now than surprised later.
The paranoia isn't free. Compliance infrastructure will eat 10-15% of your operating budget, and a CCO (which you absolutely need) costs $250K before you've made a penny. When I first saw those numbers I genuinely wondered if I was in over my head. But I've come around to thinking of it differently. Every dollar you spend on compliance is a dollar your future competitor will have to spend too, except they'll be spending it in a panic after a regulator comes knocking, and you'll already have the systems in place.
This is partly why we run two projects in parallel. Dentplicity is a data platform. Its regulatory footprint is light, which lets us build relationships and trust with dental practices without the full compliance burden of a bank. CLIN is the neobank, and it needs an entirely different level of infrastructure. By keeping them separate, I can move fast where it's safe and be meticulously slow where it matters. The lessons from one feed directly into the other.
I used to think of compliance spending as a tax. Now I think of it as a competitive advantage that compounds. The companies that build credibility with partners, regulators, and customers early don't have to scramble for it later. It's not a cost. It's a head start that compounds.
Data sources: Cross River Bank 2025 Newsletters, consumerfinance.gov, various industry analyses on compliance costs.