Nonbanks dominate bank charter boom as approval timelines shrink

Nonbanks are coming in droves to apply for national bank and national trust bank charters, capitalizing on the quick approval processes.

Just three months into 2026, 13 bank charter applications have been filed, a pace on track to surpass 2025's total of 33 and mark the busiest year since at least 2018. Nonbanks, and some foreign banks looking to enter the US, are inflating those numbers as they increasingly seek national bank and national trust bank charters with the Office of the Comptroller of the Currency (OCC). Of the 13 bank applications filed so far this year, five are for nondepository trust entities seeking national trust bank charters and four are for national bank charters.

The upcoming implementation of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act and a more favorable regulatory climate are encouraging nonbank companies to step into the world of bank regulation. However, the shift is not without challenges. These approvals can come with steep capital requirements due to the perceived risks of their business models, and they are also sparking pushback from traditional banks.

Fast approval timelines

OCC bank charter applicants are benefiting from accelerated approval timelines.

Among bank charter applications approved since 2025, nondepository trust banks had the fastest approval timelines at a median of 134 days. Approvals for commercial banks have taken nearly two months longer, with a 187-day median, while industrial banks have taken about a year, at 356 days.

Among the 13 commercial bank approvals since 2025, the three entities that applied for national bank charters with the OCC received approvals significantly faster, at a median of 121 days, compared with 195 days for the remaining 10 that applied only for deposit insurance with the Federal Deposit Insurance Corp.

"The OCC is strictly adhering to the stated processing times, that it really will not let them drag on for any reason, and so that is why we can see decisions come out at such a clip, even if they're decisions that don't necessarily look similar to each other in terms of complexity or risk profile," Matthew Bisanz, a bank regulatory partner at Mayer Brown, said in an interview.

Capital requirements are one factor from the OCC that has varied. Minimum Tier 1 capital levels for nondepository trust bank approvals have ranged from $5 million to $45 million. The three national banks' initial paid-in capital levels were $25 million for VALT Bank NA, $504 million for Nubank and $276 million for Erebor Bank NA.

Size, risk and complexity are factors the agency considers when setting capital requirements.

The OCC will "look hard at [a bank's] business strategy and plan, identify the key risks," Brian Graham, partner at Klaros Group LLC, said in an interview. "What could go bump in the night? Figure out how badly the institution could be dinged if something did go wrong and ensure you've got enough capital to work your way through that scenario."

Bank charter benefits

Still, the benefits outweigh the costs, and nonbanks are eagerly seeking charters ahead of the upcoming GENIUS Act implementation.

"Most of the charters that have been approved since the passage of the GENIUS Act relate to companies that plan to issue or service stablecoins," Bisanz wrote in an email. "Some of them wanted to position themselves to have an operating institution in place when the GENIUS Act takes effect."

Morgan Stanley, which already has two national bank charters, is seeking a national trust bank charter, likely to separate its digital asset business. Other large banks could look to do the same.

"They want to be involved with digital assets for their wealth management group, and they'd like to ring-fence that activity within its own trust company," Bisanz said. "I think you'll see the big banks, as they begin to roll out their stablecoin strategies, even if they're not going to be an issuer of stablecoins, they may seek national trust banks, again, to make these discrete and portable units, because it also does things like making life easier if you need to wind down. If you need to sell off the unit, it's not as integrated as your primary offer."

Foreign banks seeking OCC charters

Foreign banks are also seeing the current regulatory environment as an opportunity to enter the US banking market, including recent applicants such as London-based Revolut Ltd., European neobank bunq BV, and Brazilian banks Nu Holdings Ltd. and Itaú Unibanco Holding SA.

Revolut initially wanted to buy a US bank to jump across the pond, according to media reports in 2025, but switched course and applied for a national bank charter with the OCC in March.

"If the regulators approve Revolut, and it actually becomes an OCC bank in the US ... it has the potential to change the entire industry over the next five to 10 years," said Brett Mastalli, who leads the banking practice at consulting firm West Monroe. "It won't be immediate, but I think there's going to be a lot of change."

The banking industry is hoping to stop that change, pushing back against the uptick in OCC bank charters. The Bank Policy Institute has expressed concerns about risks to consumers and the financial system from these charters and is considering suing the OCC, The Guardian reported in March.

On April 2, the Independent Community Bankers of America called the OCC's conditional approval of Coinbase Global Inc.'s trust bank charter a "grave mistake that will only serve to put US consumers at risk."