FinTechs Are Shopping for Very Different Charters

The latest wave of bank charter activity is producing institutions that may share a federal regulator while bearing little resemblance to one another.

Revolut wants a national bank that could take insured deposits, offer credit cards and make loans. Circle has received final approval for a national trust bank built around digital-asset custody and USDC reserve management. Block has applied for a national trust bank that expressly wouldn’t take deposits or make loans. Upstart is pursuing a national bank centered on deposits and consumer lending.

Chime is taking another route altogether. It has agreed to acquire Stride Bank, the nationally chartered institution that has served as one of its banking partners for more than seven years.

The range of approaches shows why the charter numbers alone don’t tell the full story. FinTech and digital-asset companies are pursuing regulated institutions with different powers and different roles inside their existing businesses.

The Office of the Comptroller of the Currency said Aug. 11 that it had received 40 de novo applications during the previous 18 months, including applications for national trust banks. The OCC received 48 applications during the 14 years from 2011 through 2024.

Digital assets account for much of the recent activity. Comptroller Jonathan Gould said Aug. 19 that 23 of the 40 applications involve some form of digital-asset activity in their business plans.

Revolut and Upstart Seek Deposits and Lending

Revolut received conditional OCC approval Sept. 2 to establish Revolut Bank US, N.A. The company is still working through its applications and approvals with the Federal Deposit Insurance Corporation and Federal Reserve and must obtain final OCC approval before the proposed bank can launch.

Once those approvals are obtained, Revolut says the bank would directly offer U.S. customers loans, credit cards and FDIC-insured deposits, along with access to stablecoins and cryptocurrencies.

Upstart received conditional OCC approval in July for Upstart Bank, N.A. Its application for FDIC deposit insurance and its Federal Reserve application to become a bank holding company remain pending.

The proposed branchless bank would accept FDIC-insured deposits and originate consumer loans nationwide. Upstart has said the bank would complement rather than replace its existing funding relationships with banks, credit unions and institutional credit funds.

National Trust Banks Serve a Different Set of Businesses

Circle received final OCC approval in July to establish First National Digital Currency Bank, N.A., operating as Circle National Trust. The bank will provide fiduciary digital-asset custody services for Circle and its affiliates and may eventually provide custody directly to institutional customers. It can also manage the USDC Reserve.

Circle’s status also illustrates a  distinction within the charter pipeline. It received preliminary conditional approval in December and has since received final OCC approval, while Revolut and Upstart remain at the conditional stage.

Block is earlier in the process. As PYMNTS reported Tuesday, the company has applied to establish Builders Bank & Trust, N.A. The proposed institution would provide custody and related fiduciary services, including services involving bitcoin and stablecoins.

There are limits on some activities. Builders Bank would be an uninsured national trust bank that wouldn’t accept deposits or make loans. Instead, the charter would put certain custody and related activities already offered by Block under a federal supervisory framework.

National trust banks aren’t confined solely to traditional fiduciary activities. As PYMNTS reported in March, the OCC amended its charter regulation to use the statutory language covering the “operations of a trust company and activities related thereto.” The OCC said the change clarified rather than expanded or contracted its existing chartering authority.

That distinction leaves room for trust banks built around custody and related financial infrastructure without requiring them to adopt the deposit-taking and lending model contemplated by Revolut and Upstart.

Chime Buys Rather Than Builds

A FinTech can also obtain ownership of a national bank without establishing a de novo institution.

Chime agreed Tuesday to acquire Stride Bank for $590 million in cash. The transaction is expected to close in the first half of 2027, subject to regulatory approvals and other customary closing conditions.

If completed, Stride would become Chime Bank, N.A., a wholly owned subsidiary of Chime. Stride is already a nationally chartered bank and has served as a Chime partner for more than seven years.

For Chime, buying its partner provides a different route to controlling bank infrastructure. The company said owning Stride could eliminate partner-bank fees, reduce funding costs and allow faster development of regulated products.

The surge in charter activity broadening the roster of federally regulated institutions without clustering around a single, dominant FinTech banking model. Some applicants want deposits and lending. Others are building federally supervised businesses around custody and related activities. Chime proposes to move from relying on a bank partner to owning one.

For established banks, the competitive implications depend on what these institutions are authorized to do. A deposit-taking national bank can compete for funding and credit relationships. A national trust bank can bring custody and related activities under federal supervision without necessarily building a conventional deposit-and-lending business. An acquisition can bring an existing charter, infrastructure and balance sheet under FinTech ownership.

The OCC’s 40 applications show the renewed demand for federal charters. The services attached to those charters show which parts of banking the new entrants want to control.