Finance model of the project is well prepared, however, based on opportunistic assumption and take into account only part of the business. There is an unrealistic estimation of future profits. It is impossible to become profitable organization within 1 year. Despite the fact, that bank is going to have cost-effective branchless structure. The project team has introduced own capital requirements, which is substantially higher, than regulators requirements. Leverage ratio also is higher, than Basel’s requirements. This significantly decreases risks of the bank and the whole platform. Higher reserves should lead to smaller profits. As a result, in terms of profit, FSB has disadvantage compared to usual banks. Moreover, most part of bank’s assets would be in cash, cash equivalents and CB deposits. This part of bank’s assets could not generate any return at all in current reality. Project founders declare, that main goal is creating the platform for fintech developers, however, in finance model they do not include income from the platform at all. Three main income flows is interest, commission and trading income. Moreover, commission income constitutes more than 70% of total income, compared to 40-50% for usual banks. Most of commission income comes from clearance procedure for cryptocurrencies. There is no information about assumed commission rates. At that moment, commissions seem extremely high. It is not clear, why consumers should pay substantially more for banking services and switch to Forty Seven Bank. As a result, most part of bank’s income depends on rates and competition on cryptocurrencies exchange and clearance market. At this moment, there is no monetization plan for API for fintech developers and white label bank. Trading portfolio assets will rise from 5% of total assets in 2019 up to 26% in 2022. The team has unrealistically high expected income from trading (20%). Such level of expected return assumed too high risks for the bank. As it is said in the business model, the main source of capital will be current consumers account. However, there are substantial restrictions on managing consumer’s current accounts. Capital is cheap nowadays, especially in interbank deals. At the one side, it is a great news, it declines the cost of attracting capital. But on the other hand, it is terrible news, because of the fact, that it is extremely hard to generate an income on own assets nowadays. There is absolutely no information about income or costs from exchange and derivatives trading, rating agency business and ICO due-diligence, nothing about service for developers and income from developing the complicated ecosystem of developers.