Fintech, the OCC, and the Race for National Bank Charters

Something significant is happening at the Office of the Comptroller of the Currency. Over a period of roughly three months, from December 2025 through early March 2026, the OCC has conditionally approved national bank charters for more than nine fintech and digital asset companies, with nearly a dozen more applications in queue. These are not fringe players. Circle, Paxos, BitGo, Fidelity Digital Assets, Ripple, Bridge (a Stripe subsidiary), Crypto.com, Nu, and Protego are among those that have received conditional approvals. Revolut, Payoneer, Morgan Stanley Digital Trust, Coinbase, Zerohash, and others are pending.

This is not a regulatory footnote. It is a structural shift in how the U.S. banking system is organized  and what it means to be a bank.

For financial institutions and fintech observers, this moment deserves serious attention. In this first installment of a two-part series, I examine why fintechs are pursuing OCC national bank charters in numbers not seen since the de novo era, what the application process entails, and what the recent wave of approvals reveals about where the regulatory environment is heading.

Why Now? What caused the surge This wave was not accidental. Multiple factors in 2025 made the OCC charter pathway appealing.

The passage of the GENIUS Act in 2025 provided the clearest federal framework to date for stablecoin issuance and digital asset activity within regulated institutions. Where fintechs previously operated in a patchwork of state money transmitter licenses and informal guidance, the GENIUS Act created a pathway for federally supervised stablecoin operations. National bank charters, particularly national trust charters with OCC approval to conduct related non-fiduciary activities, became the natural vehicle for companies seeking to operate under that framework at scale.

The OCC released interpretive letters, specifically 1184, 1185, 1186, and 1188 clarifying that national banks may engage in digital asset activities such as custody, staking, and riskless principal cryptocurrency transactions. The February 27, 2026 final rule, effective in a few weeks, April 1, explicitly authorized national trust banks to engage in activities related to trust operations, removing uncertainty that had previously deterred some applicants.

This has led to a regulatory landscape that is clearer and more comprehensible than at any previous stage of the digital asset era. Fintechs that had been waiting for regulatory clarity are no longer waiting.

A National Bank Charter offers significant advantages beyond stablecoin authorization. For fintech companies dealing with the complexities of state-by-state licensing requirements, federal preemption provides substantial benefits. By obtaining a national bank charter, organizations eliminate the necessity for money transmitter licenses across all fifty states, benefit from consistent OCC supervision rather than varying state-level oversight, and gain access to essential federal payments infrastructure, including Fedwire and ACH, which are integral components of the U.S. financial system.

The current wave of applications breaks primarily into two charter types: the national trust bank charter and the full national bank charter. Understanding the distinction matters.

National Trust Bank Charter

The national trust charter is a limited-purpose charter focused on fiduciary activities, asset custody, trust management, escrow and, as clarified by the rule, related non-fiduciary activities. It does not permit accepting insured deposits or engaging in general commercial lending. That limitation is precisely what makes it attractive to digital asset and payments fintechs: they gain national status, federal preemption, and OCC supervision without triggering the full complement of FDIC requirements, CRA obligations, or Bank Holding Company Act implications.

Capital requirements for trust charters are set on a case-by-case basis and scaled for the applicant’s risk profile. Among the recent approvals, minimum tier 1 capital ranged from $6.05 million for Paxos which was a conversion from an existing state charter to $45 million for Bridge, reflecting the scale and complexity of its stablecoin infrastructure. The OCC consistently requires that at least 50 percent of minimum capital be held in eligible liquid assets i.e. unencumbered cash, short-term deposits at insured institutions, or U.S. government obligations with quarterly assessments for the first three years of operation.

Full National Bank Charter

The full national bank charter is broader. It permits deposit-taking (with FDIC insurance), commercial lending, credit card issuance, and the full range of permissible national bank activities. The compliance architecture is commensurately heavier: Basel III capital requirements, CRA obligations, CFPB supervision for consumer-facing activities, and coordination with the FDIC and Federal Reserve for larger institutions. Capital thresholds are higher, often $50 million or more for de novo applicants, and the application timeline and interagency coordination requirements add both complexity and duration.

Among the current applicants, full national bank charters are being pursued by a smaller set of companies, Revolut, Mercury, and Nu  that are positioning for comprehensive banking operations, including direct deposits and lending. Nu received conditional approval in January 2026 and must capitalize within twelve months. Revolut filed in early March 2026 with a $500 million commitment to its U.S. expansion, including direct lending and credit cards. These are not fintech experiments; they are serious bets on regulated banking infrastructure.

To apply for a charter, fintech companies follow a process managed by the OCC under 12 CFR Part 5. Although the procedure is consistent for all charter types, it has been adjusted to suit the unique, nontraditional models often used by fintech applicants. The application goes through four main steps: prefiling, filing, review, and decision, after which there is an organizational phase before final approval is granted.

The prefiling phase is where applications succeed or fail before they are ever formally submitted. Applicants are encouraged and effectively required to engage the OCC’s Office of Innovation early. Multiple meetings with OCC licensing and supervisory staff allow the agency to identify potential issues, and the applicant to refine its business model, capital plan, and governance structure before committing to a formal filing. For fintechs, this phase is particularly important because the OCC has limited precedent for some of the operational models being proposed, and staff need time to develop familiarity with activities like stablecoin reserve management or crypto custody at scale.

The formal application must include a detailed business plan covering proposed activities, financial projections under normal and stressed scenarios, governance structure, risk management framework, and internal controls.

The review phase is the most intensive. The OCC evaluates the application against statutory criteria, with particular emphasis on the qualifications of organizers and management, the viability of the business plan, capital and liquidity adequacy, and the applicant’s commitment to financial inclusion. Fintechs are expected to demonstrate experience in regulated financial services, not just technology, and to include robust third-party risk management and contingency strategies. For digital asset fintechs, the review pays close attention to custody safeguards, blockchain fee management, and outsourcing compliance.

Decisions result in either preliminary conditional approval or denial. Conditional approvals impose specific, enforceable requirements such as minimum capital, no material changes to the approved business plan, specified governance milestones before final approval and commencement of operations. The organization phase typically requires capital raising, completion of governance and compliance infrastructure, and satisfaction of all conditions.

The full process, from initial prefiling engagement through conditional approval, typically runs from 120 to 180 days for well-prepared applications, though the organization phase and path to final approval can extend the total timeline to six to eighteen months. Legal and consulting costs frequently exceed $1 million, and in complex cases can run significantly higher.

Recent Approvals and Pending Applications

The following tables summarize the current state of OCC fintech charter activity as of early March 2026.

Conditional Approvals (2025–2026)