Are you setting up an "internet bank" within an existing bank, essentially a "trading as" name just for the internet or just setting up internet banking? If so, you should review all of the FFIEC guidance, as well as the old OCC booklet, make sure you are meeting current expectations.
You can also contact your regulator for guidance.
If you are setting up a totally internet bank, chartered as such, you need to start with our regulator. I am guessing you are doing the first, because you wouldn't be this far with a newly chartered internet bank without this knowledge.