The news
The fintech bank charter race sharpened in September 2026. Online lender Enova International (ENVA) abandoned its bank acquisition on September 14, while the Office of the Comptroller of the Currency (OCC) approved new trust and credit card banks and more fintechs applied.
Demand is high. Comptroller Jonathan Gould said in August that the OCC had received 40 new charter applications in roughly 18 months, 23 of them involving digital assets. Banking Dive, reporting on Avant's September 18 application to form Avant Bank, N.A., cited OCC figures showing 43 firms, Avant included, have applied for de novo charters since January 2025. The OCC has approved 27, denied two, including Wise's trust charter bid, and returned one; the rest are under consideration.
Enova went the other way. It withdrew its OCC and Federal Reserve applications to acquire Grasshopper Bancorp, a deal Banking Dive valued at $369 million. Chief executive Steve Cunningham said regulators lack clear standards for nonbanks that want to become banks and that the process is open to political pressure. Banking Dive reported that 20 state and district attorneys general and Sens. Elizabeth Warren and Chris Van Hollen had urged regulators to reject the deal. Cunningham added: "Our future growth and success do not depend on becoming a bank."
Approvals kept coming. Banking Dive reported on September 21 that the OCC conditionally approved national trust charters for Bastion, which white-labels stablecoins, Agora, which issues the AUSD stablecoin, and Catena, which is building financial infrastructure for AI agents, with minimum tier 1 capital of $6 million to $10 million. On September 25, Mission Lane won conditional approval for a credit card bank that must raise $35 million in initial capital and hold an 11% leverage ratio for three years; it still needs FDIC deposit insurance.
The rules are shifting too. On September 17, the FDIC proposed that out-of-state state banks get the same treatment as national banks under host-state laws, with comments due November 23. On September 11, federal agencies proposed third-party risk guidance meant to ease bank partnerships with fintechs.
The numbers
- New OCC charter applications in about 18 months (Gould, August)
- 40
- Applications involving digital assets
- 23
- OCC charters approved since January 2025 (Banking Dive)
- 27
- Enova's abandoned Grasshopper deal (Banking Dive)
- $369 million
- Mission Lane required initial capital
- $35 million
Why CEOs should care
For fintech CEOs and boards, the question is no longer whether a charter is possible but whether it is worth the price. Conditional approvals come with fixed capital and liquidity demands: Mission Lane must hold an 11% leverage ratio for three years, and the new trust banks must keep 180 days of operating expenses in liquid assets. Timelines are long; Nubank received conditional approval in January 2026 and Banking Dive reported it expects a full charter in 2027. Enova's experience adds political risk: its CEO said the process is open to political pressure and outside advocacy rather than being guided strictly by the statutory factors.
CFOs should model the trade-off directly. Avant's chief executive said a national charter would lower its cost of funds and let it operate under one regulatory framework. Weigh that against capital locked up at the bank, examination costs and the years of dual operations while a partner bank still serves customers. Build the model on conservative approval dates rather than the dates in the application. Keep sponsor bank relationships healthy during any application, because approvals can slip.
Sponsor banks should plan for successful fintech clients to leave as they win charters, and for new ones to arrive if the third-party risk rewrite eases onboarding. Boards at both banks and fintechs should also watch the FDIC parity proposal, which could make state charters more attractive for digital banks that serve customers nationwide.
The bigger picture
Regulators have reopened the bank door to nonbanks, especially those tied to stablecoins and digital assets, and the approvals list now includes a credit card bank and a trust bank built around AI agents. The window depends on current leadership. The Wise denial shows the bar still exists, and Enova, which blamed unclear standards and a process it called open to political pressure, withdrew before regulators ruled on its deal.
What’s next
Watch for decisions on Avant and other pending applications, Mission Lane's deposit insurance approval, comments on the FDIC parity rule by November 23, and the OCC's final GENIUS Act stablecoin rule, which Gould said would come by November. Each will show how wide the door stays open into 2027.
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