Appendix IV - Business Plan Trust Business

Summary

This is a prescribed form (Appendix IV) that applicants for a trust business licence in Bermuda must complete as part of their application under section 11(6)(a) of the Trusts (Regulation of Trust Business) Act 2001. It sets out the required content of the business plan that must accompany a trust business application, covering the first three years of proposed operations.

• Business overview: Aims and objectives, and the nature and scale of expected business and its sources
• Group structure: A chart showing the applicant's relationship to its parent, subsidiaries and affiliates, if applicable
• Financials: Revenue projections including balance sheet and profit and loss for each year, with the assumptions underlying the projections, plus capital structure and financing arrangements
• Systems and controls: Proposed internal audit and compliance arrangements, including risk management, financial accounting, internal controls and physical security
• Staffing: Management structure, mind and management, organisational structure, staff experience and qualifications, and training plans including any AML training by the compliance officer or money laundering reporting officer
• Client assets and premises: Arrangements for segregating clients' assets, and details of premises, fixed assets and equipment
• Outsourcing and delegation: Details of outsourcing or insourcing arrangements and any proposed delegation of responsibilities, including names, addresses and functions of the persons or entities involved

The listed items are described as non-exhaustive minimum requirements, meaning applicants may need to provide additional information depending on their specific proposed business.

Key obligations

• An applicant for a trust business licence must submit a business plan covering the first three years of operation as part of its application under section 11(6)(a) of the Trusts (Regulation of Trust Business) Act 2001
• The business plan must address aims and objectives, nature and scale of business, group structure chart, revenue projections with underlying assumptions, capital structure and financing arrangements, internal audit/compliance and risk management systems, staffing and management structure and training, client asset segregation arrangements, premises and fixed assets, internal controls and physical security, outsourcing/insourcing arrangements, and any delegation of responsibilities with names, addresses and functions of delegates

Applies to

Applicant for a trust business licence, trust companies