From the original research pack. This draft has not received a complete claim-by-claim review. Fees, product terms, statistics and legal status may have changed. Its preparation date is not a publication date. Use the linked original sources.

For most of the last decade, fintechs avoided becoming banks. Renting a partner bank's charter was faster and cheaper. In 2025 and 2026 that calculation flipped: payments companies, crypto firms, business-banking apps, and even a rent-payment startup lined up for charters, and U.S. regulators started saying yes, and occasionally no. Here is what is driving the rush, what the different licenses allow, and why "approved" rarely means "open for business" on day one.

Key takeaways

  • A bank charter lets a company take deposits, access payment systems, and lend without depending on a sponsor bank, at the cost of heavy capital, supervision, and compliance requirements.
  • The OCC reported receiving dozens of new bank applications in an 18-month span, and trade press described 2026 as a charter boom [1][2][3].
  • Notable 2026 decisions include OCC conditional approvals for Nu (January), Mercury (April), Upstart (July 23), and Revolut (September 3); conditional approval for Coinbase's trust bank; final approval for Circle's trust bank (July 10); and denials for Wise (July) and bunq (August) [4][5][6][8][16][17].
  • "Conditional approval" is a milestone, not a launch: companies still must raise capital, meet conditions, and often obtain FDIC deposit insurance before opening.
  • Charter types differ a lot. A national trust bank, an industrial loan company, and a full-service national bank allow very different activities.

What a bank charter actually is

A bank charter is a government license to operate as a bank. In the U.S., companies can get one from the federal government, through the Office of the Comptroller of the Currency (OCC), or from a state banking regulator. A bank that takes insured deposits also needs deposit insurance from the Federal Deposit Insurance Corporation (FDIC), and a company that owns a bank typically becomes a bank holding company supervised by the Federal Reserve, unless the charter type is exempt.

A de novo bank is simply a brand-new bank, as opposed to one formed by buying an existing institution.

Why fintechs want their own charter

1. Escaping sponsor-bank dependence

Most U.S. fintech accounts and cards run on a partner bank's charter. After the 2022–2024 wave of enforcement actions against those banks, many fintechs saw their launches delayed or programs forced to migrate when a partner bank was restricted Related field note. A charter removes that single point of failure.

2. Keeping more of the economics

With a partner bank, revenue from deposits, cards, and loans is shared. A chartered bank keeps its net interest income (the spread between what it earns on loans and securities and what it pays on deposits) and funds loans with its own deposits rather than more expensive wholesale funding. Related field note

3. Direct access to payment rails

Banks can connect more directly to systems like the Federal Reserve's payment services. Non-banks generally must go through a bank. For payments and stablecoin businesses, that access is strategic. Related field note

4. Regulatory legitimacy and a friendlier window

Trade press and law firms have described federal regulators in 2025–2026 as more open to new charters, including for digital-asset firms. The OCC also finalized amendments to its chartering rule in 2026 affirming that national trust banks can engage in certain non-fiduciary activities [9][10][11]. Many applicants appear to be moving while that window is open.

5. Crypto and stablecoin rules

The GENIUS Act created a federal framework for payment stablecoins, and several crypto firms have pursued national trust bank charters to custody assets and support stablecoin activity under federal supervision. Related field note

Charter types compared

Charter type Chartering authority Can take insured deposits? Typical fintech use Notes
National bank OCC Yes, with FDIC insurance Full-service consumer or business banking (e.g., Nu's and Mercury's applications [4][5]) Parent typically becomes a bank holding company under Fed supervision
National trust bank OCC Generally no (fiduciary/custody focus) Crypto custody, stablecoin reserves, asset servicing [8][11] OCC's 2026 final rule addressed non-fiduciary activities [10]
State-chartered bank State regulator (+ FDIC or Fed) Yes Regional or niche banking Also subject to state rules
Industrial loan company (ILC) State (often Utah) + FDIC Yes Lending and deposits for commercial parents (e.g., Flex's application [12]) Parent company may avoid bank holding company status; controversial with bank trade groups
Acquiring an existing bank Change-of-control approvals Yes Faster path for some fintechs Inherits the target bank's history and systems

Explore the payment path

The 2025–2026 charter wave: who applied and what happened

Status labels below reflect reporting we could find as of September 17, 2026. Applications move quickly, so check the OCC's corporate applications search and the FDIC's application notices for current status.

Consumer and business banking

  • Nu (Nubank): The Brazil-based digital bank announced on January 27, 2026 that it received OCC conditional approval to establish a U.S. national bank [4][13].
  • Mercury: The business-banking fintech received OCC conditional approval for a national bank charter in April 2026 [5][8][14].
  • Upstart: The AI lending company received preliminary conditional approval for a fully digital national bank on July 23, 2026. PYMNTS reported elevated conditions, including a 12% minimum Tier 1 leverage ratio and 15% total risk-based capital ratio for three years; its FDIC insurance and Federal Reserve holding company applications were still pending as of early August 2026 [6][8].
  • Revolut: The UK-based fintech announced on September 3, 2026 that it received OCC conditional approval to form a U.S. national bank, the proposed Revolut Bank US. The company said it still needs approvals from the FDIC and the Federal Reserve, plus final OCC approval, and is targeting a 2027 launch [17].
  • Wise (denied): PYMNTS reported that the OCC denied Wise's national trust bank application in July 2026, citing compliance and management shortcomings, particularly anti-money-laundering controls, and noting a July 2025 multistate consent order against Wise US [6].
  • bunq (denied): The OCC denied bunq's national bank application in August 2026, according to PYMNTS, citing concerns including capital documentation, credit loss assumptions based on European data, and management's familiarity with U.S. banking law [6].
  • Other national banks: Davis Wright Tremaine listed conditional approvals for VALT Bank (March 2026) and Augustus National Bank (May 8, 2026), which received FDIC deposit insurance approval on August 4, 2026 [8]. OpenReserve also received preliminary conditional approval, per a trade report [15].

Digital-asset and payments firms

  • A group of crypto and payments companies applied for OCC national trust bank charters in a short span. FinTech Weekly described "eleven companies" in "eighty-three days" [7].
  • Circle: received final OCC approval for its national trust bank on July 10, 2026, according to Davis Wright Tremaine [8].
  • BitGo, Fidelity Digital Assets, and Paxos: received conditional approvals for national trust bank charters in December 2025, with final approval pending as of August 5, 2026 [8].
  • Coinbase: received OCC conditional approval for a national trust charter in early April 2026 [16].
  • Pending (as of August 5, 2026): Bridge National Trust Bank (Stripe's stablecoin unit), Laser Digital National Trust Bank (Nomura), and Morgan Stanley Digital Trust [8].

Industrial loan companies

  • Flex, a rent-payment fintech, applied to the FDIC and Utah for an ILC charter, per Banking Dive [12].

The overall numbers

PYMNTS reported that the OCC received 40 new bank applications in 18 months [3]. Banking Dive and American Banker have covered the surge as an "explosion" of charter applications [1][2]. (We did not find a single official count covering all regulators; treat figures as OCC-only unless stated.)

What "conditional approval" means

A conditional approval is the regulator saying: you can open a bank if you meet these conditions. Typical conditions include:

  • Raising a specified amount of capital
  • Getting FDIC deposit insurance (for deposit-taking banks) and Federal Reserve approval for the holding company
  • Hiring the proposed management team and adopting a business plan the regulator reviewed
  • Passing a pre-opening examination
  • Opening within a set time period, or the approval lapses

Some fintechs have historically received conditional approvals and never opened. Readers should distinguish applied, conditionally approved, final approval, opened, withdrawn, and denied. Explore the payment path

The trade-offs fintechs accept

A charter is not free money. Banks face:

  • Capital requirements that tie up equity that could otherwise fund growth
  • Examinations by regulators on a regular cycle, plus Community Reinvestment Act obligations for many charter types
  • Activity limits, since banks can't engage in some businesses fintechs could do freely
  • Compliance scale: the anti-money-laundering, consumer protection, and risk management burden moves fully in-house
  • Slower product iteration, since new products may need regulatory review

Earlier fintech banks show both paths. Some used a charter to build lending and deposit businesses; others struggled to reach profitability under bank capital rules. (Company-specific outcomes should be checked against their filings.)

Who pushes back

Bank trade groups have long opposed ILCs owned by commercial companies and have raised concerns about national trust banks doing bank-like activities without full bank regulation. Some state regulators have also challenged federal fintech charters in the past. These debates affect which charter types remain viable, so watch for litigation and rule changes.

What it means for consumers

If your fintech app becomes a bank, your deposits may be held directly by that bank rather than through a partner, which can simplify FDIC insurance questions: coverage then applies to the bank itself, up to legal limits. But a new bank is also a young institution. Check the bank's name on the FDIC's BankFind tool, and remember that if you also hold money at the same bank through another app, balances may count toward the same insurance limit. Related field note Related field note

FAQ

What is the difference between a fintech and a bank? A bank holds a charter and is directly supervised; it can take deposits in its own name. Most fintechs are technology companies that offer bank products through a licensed partner bank.

Why would a fintech want a national trust bank charter instead of a full bank charter? A trust charter focuses on custody and fiduciary activities, which suits crypto custody and stablecoin reserve management, and typically does not involve taking insured deposits.

Does conditional approval mean the bank is open? No. The company must meet conditions, such as raising capital and obtaining deposit insurance, before opening.

Did regulators deny any fintech charters in 2026? Yes. PYMNTS reported that the OCC denied Wise's national trust bank application in July 2026 and bunq's national bank application in August 2026 [6]. Check OCC records for the official decisions.

Is my money safer if my fintech becomes a bank? It can simplify deposit insurance, since funds sit directly at an insured bank, but safety also depends on the bank's management, capital, and your total balances there.

Sources

  1. American Banker, "Fintechs asking for, and receiving, bank charters in 2026," https://www.americanbanker.com/news/fintechs-asking-for-and-receiving-bank-charters-in-2026 (2026; accessed 2026-09-17)
  2. Banking Dive, "Inside the explosion of banking charter applications," https://www.bankingdive.com/news/inside-the-explosion-of-banking-charter-applications/810250/ (2026; accessed 2026-09-17)
  3. PYMNTS, "OCC Receives 40 New Bank Applications in 18 Months," https://www.pymnts.com/legal/bank-regulation/2026/occ-receives-40-new-bank-applications-in-18-months/ (2026; accessed 2026-09-17)
  4. Business Wire (Nu Holdings), "Nu Secures Approval to Establish US National Bank," https://www.businesswire.com/news/home/20260127041655/en/Nu-Secures-Approval-to-Establish-US-National-Bank (January 27, 2026; accessed 2026-09-17)
  5. Banking Dive, "Mercury nabs conditional OCC charter," https://www.bankingdive.com/news/mercury-nabs-conditional-occ-charter/818674/ (2026; accessed 2026-09-17)
  6. PYMNTS, "What the OCC's Wise and Bunq Denials Mean for FinTech Bank Charters," https://www.pymnts.com/legal/bank-regulation/2026/occ-makes-us-bank-readiness-the-price-of-a-fintech-charter/ (August 2026; accessed 2026-09-17)
  7. FinTech Weekly, "Eleven Companies, Eighty-Three Days: The Race for a Federal Crypto Banking License," https://www.fintechweekly.com/news/occ-national-trust-bank-charter-crypto-fintech-2026 (2026; accessed 2026-09-17)
  8. Davis Wright Tremaine, "OCC's Recent Charter Approvals Signal Momentum for Digital-Asset Bank Charters," https://www.dwt.com/blogs/financial-services-law-advisor/2026/08/occ-signals-digital-asset-charter-momentum (August 5, 2026; accessed 2026-09-17)
  9. PYMNTS, "OCC Clarifies Charter Rule and Extends National Path for FinTechs," https://www.pymnts.com/bank-regulation/2026/occ-clarifies-charter-rule-and-extends-national-path-for-fintechs/ (2026; accessed 2026-09-17)
  10. OCC, "National Bank Chartering: Final Rule," Bulletin 2026-4, https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-4.html (2026; accessed 2026-09-17)
  11. Stinson LLP, "OCC Finalizes Amendments to National Bank Chartering Rule to Affirm the Authority of National Trust Banks to Engage in Non-Fiduciary Activities," https://www.stinson.com/newsroom-publications-occ-finalizes-amendments-to-national-bank-chartering-rule-to-affirm-the-authority-of-national-trust-banks-to-engage-in-non-fiduciary-activities (2026; accessed 2026-09-17)
  12. Banking Dive, "Rent fintech Flex applies for ILC charter," https://www.bankingdive.com/news/flex-rent-fintech-fdic-utah-charter-industrial-loan-company-ilc-application/826375/ (2026; accessed 2026-09-17)
  13. Banking Dive, "Nubank gets conditional OCC approval for charter," https://www.bankingdive.com/news/nubank-gets-conditional-occ-approval-charter/810981/ (January 2026; accessed 2026-09-17)
  14. FinTech Futures, "Mercury lands conditional approval for US national bank charter," https://www.fintechfutures.com/regulatory-actions/mercury-lands-conditional-approval-for-us-national-bank-charter (2026; accessed 2026-09-17)
  15. Global Fintech Series, "OCC Grants OpenReserve Preliminary Conditional Approval to Charter a National Bank," https://globalfintechseries.com/banking/occ-grants-openreserve-preliminary-conditional-approval-to-charter-a-national-bank/ (2026; accessed 2026-09-17)
  16. CoinDesk, "Coinbase wins initial bank regulator nod for trust charter, boosting custody push," https://www.coindesk.com/policy/2026/04/02/coinbase-wins-initial-occ-nod-for-trust-charter-boosting-sustody-push (April 2, 2026; accessed 2026-09-17)
  17. Revolut, "Revolut Receives Conditional Approval from U.S. Office of the Comptroller of the Currency to Form a National Bank," https://www.revolut.com/news/revolut_receives_conditional_approval_from_u_s_office_of_the_comptroller_of_the_currency_to_form_a_national_bank/ (September 3, 2026; accessed 2026-09-17)

Last updated September 17, 2026. This article is for educational purposes only and is not financial, legal, tax, or investment advice. Charter application statuses change frequently; verify current status with the OCC, FDIC, Federal Reserve, and state regulators, and confirm terms directly with any provider.

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