Tracing its heritage to 1787 (that's a year, not a time), Raphaels Bank is one of the oldest independent banks in the UK. The bank says "today, we operate as a dynamic, niche savings and lending bank." It also operates "our own ATM Estate" and says it's a "well-established payment services provider." That, it is hard to escape concluding, is that this venerable institution is capitalising on its size and ability to operate in areas more usually associated with secondary institutiond and fintech companies. But for such a tiny business, it comes to the attention of regulators more than is healthy.