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← Embedded Finance Index 2026/Bank charters
Charter queue · 2025-26 · updated 2026-10-06
147-day median OCC review · peaked at 9/quarter ↓

Who is applying to become a bank

38 applications tracked since the OCC reopened de novo chartering. Most are national trust banks — custody and stablecoin settlement under one federal supervisor instead of fifty state licences — not deposit-taking banks. Each row is a sponsor-bank relationship that ends the day the charter opens.

8
Application filed
26
Conditional approval
2
Approved
2
Denied
CompanyProposed bankCharterStatusFiledDecisionWhat it is for
RainRain National Trust BankNational trust bank
OCC
Application filed2026-10-06pendingUninsured, non-depository national trust bank to provide fiduciary custody of digital assets and dollars for institutional clients, manage stablecoin issuer reserves, and issue/redeem USD-backed stablecoins — would not accept deposits or make commercial loans. Brandon Soto, CPA (former Square Financial Services president) proposed as President and CEO. Rain leadership: "The institutions we serve, and the people who use their products, want the custody, reserves, and issuance behind stablecoin payments held by a fiduciary that answers to a federal regulator."
Modern TreasuryModern Treasury National Trust BankNational trust bank
OCC
Application filed2026-10-05pendingUninsured, non-depository national trust bank to unify digital-asset custody with Modern Treasury's existing payments/settlement platform, letting customers custody and move stablecoins and fiat through one infrastructure — explicitly would not make loans or issue stablecoins itself. CEO Matt Marcus: "We believe stablecoins are foundational economic infrastructure for the future." Modern Treasury's software/PSP business continues operating separately regardless of the outcome.
BastionBastion Platforms Trust Company, LLC → Bastion Platforms National Trust Company
New York, NY
Conversion to national bank
OCC
Conditional approval2026-03-302026-09-18
Corporate Decision 1391
Converts Bastion's trust company to a national trust bank for stablecoin custody and wallets, payment infrastructure and white-label stablecoin issuance for enterprises.
Catena LabsCatena Trust Bank, N.A.
New York, NY
National trust bank
OCC
Conditional approval2026-05-182026-09-18
Corporate Decision 1392
Custody, conversion, clearing and payment services for AI agents — GENIUS Act stablecoins, fiat and securities — from Circle co-founder Sean Neville's agent-finance bank.
Agora FinanceAgora National Trust Bank
New York, NY
National trust bank
OCC
Conditional approval2026-04-202026-09-18
Corporate Decision 1393
Digital-asset custody, investment advisory and stablecoin issuance for the AUSD issuer under one federal framework instead of state money-transmitter licences.
BlockBuilders Bank & Trust, N.A.
Sioux Falls, SD
National trust bank
OCC
Application filed2026-09-04pendingUninsured, non-depository trust bank for bitcoin and digital-asset custody, riskless-principal execution and stablecoin settlement — a second charter alongside Square Financial Services (Utah ILC), replacing 50+ state MTL and virtual-currency licences. Announced 2026-09-08.
RevolutRevolut Bank US, N.A.
Stamford, CT
National bank
OCC
Conditional approval2026-03-042026-09-02
Corporate Decision 1390
Full US national bank for Revolut's US expansion, filed the same month it received its full UK banking licence.
OpenReserveOpenReserve Bank, National Association
Salt Lake City, UT
National bank
OCC
Conditional approval2026-04-132026-09-02
Corporate Decision 1389
De novo bank with blockchain settlement, tokenized deposits and a GENIUS Act stablecoin subsidiary (ReserveUSD).
Zero HashZerohash National Trust BankNational trust bank
OCC
Application filed2026-08-19pendingStablecoin and crypto infrastructure provider seeking a federal trust charter. Second attempt: an earlier filing was returned by the OCC in July 2026; refiled the same charter the following month.
ItaúItaú Bank, National Association
Miami, FL
National bank
OCC
Conditional approval2026-03-162026-08-14
Corporate Decision 1386
US national bank for Brazil's largest private bank.
World Liberty FinancialWorld Liberty Trust Company, National Association
Bay Harbor Islands, FL
National trust bank
OCC
Conditional approval2026-012026-08-14
Corporate Decision 1385
Trust charter to expand the USD1 stablecoin business to institutional customers.
bunqbunq US Bank, National Association
New York, NY
National bank
OCC
Denied2026-012026-08-04
Corporate Decision 1384 (denial)
Second attempt after withdrawing a 2023 application; US deposits for European nomads resident in the US. The OCC denied the application after its field investigation, noting the proposed holding company would be majority-owned by a single individual who also controls bunq B.V.
UpstartUpstart Bank, National Association
Wilmington, DE
National bank
OCC
Conditional approval2026-03-252026-07-23
Corporate Decision 1382
Own charter for the AI lending marketplace, which has originated through partner banks (Cross River, FinWise) since 2012.
WiseWise National Trust
Austin, TX
National trust bank
OCC
Denied2025-06-162026-07-21
Corporate Decision 1381 (denial)
Trust charter that would have given Wise direct access to US payment rails without a sponsor bank. The OCC denied the application after its field investigation; the letter says a subsequent application would need to address the reasons for the denial.
CircleFirst National Digital Currency Bank, N.A. (Circle National Trust)
New York, NY
National trust bank
OCC
Approved2025-06-302026-07-10
Final OCC approval (Circle announcement)
Places USDC reserve management and digital-asset custody under federal oversight.
KlarnaKlarna Bank USA
Utah
Industrial bank (ILC)
FDIC / Utah DFI
Application filed2026-07-06pendingUtah industrial bank to hold US deposits and fund Klarna's US lending directly, alongside its existing Swedish banking licence.
Sony BankConnectia Trust, National Association
New York, NY
National trust bank
OCC
Conditional approval2025-102026-07-02
Corporate Decision 1380
Sony Bank's wholly owned US trust bank ($40M capital) for dollar-stablecoin issuance and reserves, stablecoin custody and fiduciary asset management; targeting Q1 2027.
Morgan StanleyMorgan Stanley Digital Trust
Purchase, NY
National trust bank
OCC
Conditional approval2026-02-182026-06-18
Corporate Decision 1378
Digital-asset custody trust bank.
NomuraLaser Digital National Trust Bank
New York, NY
National trust bank
OCC
Conditional approval2026-01-272026-05-29
Corporate Decision 1377
Digital-asset custody trust bank for Nomura's Laser Digital unit.
AugustusAugustus National Bank, National Association
Dallas, TX
National bank
OCC
Conditional approval2025-122026-05-08
Corporate Decision 1374
Full-service US bank for the European payments fintech formerly known as Ivy (processes for Kraken).
KrakenPayward National Trust CompanyNational trust bank
OCC
Application filed2026-05-08pendingFederally regulated digital-asset custody for individuals and institutions; opposed by community-bank trade groups.
Interactive BrokersInteractive National Trust Bank
Greenwich, CT
National trust bank
OCC
Conditional approval2025-12-182026-05-05
Corporate Decision 1373
Trust bank for custody and related fiduciary services.
MercuryMercury Bank, National Association
Salt Lake City, UT
National bank
OCC
Conditional approval2025-122026-04-24
Corporate Decision 1372
Own bank to add Zelle, expand lending and run its own payments infrastructure instead of sponsor banks (Choice, Column, Evolve).
CoinbaseCoinbase National Trust Company
New York, NY
National trust bank
OCC
Conditional approval2025-10-032026-04-02
Corporate Decision 1370
Migrates institutional custody from the NYDFS-chartered Coinbase Custody Trust Company to a federal trust bank over the three-year de novo period.
VALTVALT Bank, National Association
Eagle, ID
National bank
OCC
Conditional approval2025-112026-03-13
Corporate Decision 1368
Digital business bank for SMBs — credit, deposits, treasury.
Crypto.comForis DAX National Trust Bank
Chicago, IL
National trust bank
OCC
Conditional approval2025-102026-02-20
Corporate Decision 1367
Trust subsidiary to do business as Crypto.com National Trust Bank.
Protego HoldingsNational Digital Trust Company
Seattle, WA
National trust bank
OCC
Conditional approval2025-062026-02-13
Corporate Decision 1366
Digital-asset custody and fiduciary services (crypto, tokenized securities, stablecoins) — Protego's second run at a federal charter after its 2021 conditional approval lapsed.
BridgeBridge National Trust Bank
New York, NY
National trust bank
OCC
Conditional approval2025-102026-02-12
Corporate Decision 1365
Lets Stripe's stablecoin unit operate stablecoin products under federal oversight; Payoneer announced Bridge-powered stablecoins the same day.
Erebor BankErebor Bank, National Association
Columbus, OH
National bank
OCC
Approved2025-072026-02-09
Final national bank charter (OCC; reported by Banking Dive)
First de novo national bank granted in four years — crypto-friendly bank for tech, AI, defence and manufacturing companies. FDIC deposit insurance approved 2025-12-16 (fdic.gov); full charter followed in February 2026.
NubankNubank, National Association
McLean, VA
National bank
OCC
Conditional approval2025-09-302026-01-29
Conditional Approval 1362
US entry for the Brazilian neobank: deposits, credit cards, lending and digital-asset custody.
AffirmAffirm Bank
Nevada
Industrial bank (ILC)
FDIC / Nevada FID
Application filed2026-01-23pendingNevada industrial loan company so Affirm can fund and hold its own BNPL and consumer loans as an FDIC-insured subsidiary rather than through partner banks.
UKGUKG National Trust Bank
Branchburg, NJ
National trust bank
OCC
Conditional approval2025-09-262026-01-22
Conditional Approval 1361
Trust bank attached to the payroll / HCM platform — payroll funds handling under a federal charter.
PayPalPayPal Bank
Utah
Industrial bank (ILC)
FDIC / Utah DFI
Application filed2025-12-15pendingUtah industrial loan company for small-business lending and FDIC-insured savings, reducing reliance on partner banks; Mara McNeill (ex-Toyota Financial Savings Bank) as president.
RippleRipple National Trust Bank
New York, NY
National trust bank
OCC
Conditional approval2025-07-022025-12-12
Conditional Approval 1359
Federal trust charter for RLUSD stablecoin reserves and custody.
PaxosPaxos Trust Company, LLC → national bank
New York, NY
Conversion to national bank
OCC
Conditional approval2025-08-122025-12-12
Conditional Approval 1358
Converts the NYDFS-chartered stablecoin issuer to a national trust bank.
Fidelity Digital AssetsFidelity Digital Asset Services, LLC → national bank
New York, NY
Conversion to national bank
OCC
Conditional approval2025-06-112025-12-12
Conditional Approval 1355
Converts Fidelity's digital-asset custodian to a national trust bank.
BitGoBitGo Trust Company, Inc. → BitGo Bank & Trust
Sioux Falls, SD
Conversion to national bank
OCC
Conditional approval2025-07-142025-12-12
Conditional Approval 1353
Converts the South Dakota trust company behind BitGo's custody to a national bank.
OneSource VirtualOneSource Virtual Trust Bank, National Association
Dallas, TX
National trust bank
OCC
Conditional approval2025-04-182025-09-12
Conditional Approval 1346
Trust bank for the Workday payroll services provider's client-funds handling.
Sources: the OCC’s Interpretations & Decisions table for every decided row (letter number and date verbatim), the applicant’s own announcement for filings the OCC has not yet decided. The list is diffed against the OCC table weekly. Charters already operating before 2025 are not in the queue — they appear on the vendor pages as held charters.

How fast is this moving

Filings by quarter

5
Q2 '25
6
Q3 '25
9
Q4 '25
9
Q1 '26
4
Q2 '26
3
Q3 '26
2
Q4 '26

Peaked at 9 a quarter in Q4 2025–Q1 2026; the dashed bars are still filling in, not a drop-off.

Filing to first decision

147
Median days
118
Fastest
184
Slowest approval

118–184 days across 19 measured approvals (UKG fastest, Fidelity Digital Assets slowest); Wise's denial took 400 — over 2x the slowest approval.

A filing only enters this queue once announced or decided, so a quarter younger than ~6 months hasn’t had its quieter filings surface yet. Of the OCC applications still pending, Kraken has waited longest so far (158 days) — still inside the approval range above. Affirm, PayPal and Klarna are also pending, but on a separate FDIC-and-state industrial-bank track, not the OCC ladder these figures measure.

Outside the US

14 bank and bank-branch licence applications (filed, approved or announced) tracked in the UK, EU, Switzerland, the Nordics, Latin America and the Middle East. There is no regulator feed to diff these against the way the OCC’s table backs the US queue, so every row needs the company’s or regulator’s own document, or two independent outlets. Single-source bids are left out until a second source appears.

CompanyJurisdictionLicenceStatusDateWhat it is for
RevolutColombia
Superintendencia Financiera de Colombia
Bank (credit institution)Approved2026-09Licence to operate as a bank in Colombia, part of Revolut's push to hold its own banking licence in each major market.
RevolutSwitzerland
FINMA
Bank (credit institution)Application filedfiled 2026-09Standalone Swiss bank for franc salary accounts, Swiss IBANs and deposit protection; Swiss customers are served today by the Lithuanian entity.
Allica BankSweden
Finansinspektionen
Bank (credit institution)Application filedfiled 2026-08First market outside the UK for the digital SME bank; Swedish entity and executive team already set up, with EU passporting as the longer-term aim.
RevolutFinland
Bank of Lithuania + ECB (home) / Finland (host)
Bank branchApplication filedfiled 2026-08Local Finnish account details for the 250,000+ customers served through the Lithuanian bank today.
A branch of Revolut Bank UAB, not a new bank. No timetable disclosed. One source also mentions a Greek application; nothing else confirms it, so it is not recorded.
RevolutFrance
ACPR + ECB
Bank (credit institution)Approved2026-08-10Second full EU bank licence, making Paris the Western European hub alongside Lithuania.
The ECB's product-launch restrictions on the Lithuanian arm (July 2025) are reported by Bloomberg to extend to the French entity; Revolut's announcement did not mention them.
RevolutAustralia
APRA
Bank (credit institution)Approved2026-07Full authorised deposit-taking institution (ADI) licence; banking operations activated in July 2026.
DefactoFrance
ACPR + ECB
Bank (credit institution)Application filedfiled 2026-06Move an SME working-capital lender (today a société de financement) to a full EU credit institution ahead of expansion into Germany and Belgium from 2027.
MalUnited Arab Emirates
Central Bank of the UAE (CBUAE)
Bank (credit institution)Authorised, not yet fully operating2026-05-20Abu Dhabi-based AI-native, Shariah-compliant digital bank spanning banking, wealth, payments and embedded finance, targeting the $7tn Islamic finance market — reportedly the first in-principle approval anywhere for an AI-native digital banking platform.
In-principle approval only — Mal has not yet become a fully licensed bank, and still needs final regulatory clearances before commencing operations. Reported alongside its $230M seed round (largest fintech seed round in MEA history), led by BlueFive Capital.
RevolutUnited Kingdom
PRA + FCA
Bank (credit institution)Approved2026-03-11Full UK bank: FSCS-protected deposits and, over time, lending; ends the e-money-institution setup that served 13 million UK customers.
Authorised with restrictions (mobilisation) on 2024-07-25; the PRA lifted them in March 2026, about 20 months later, longer than the usual 12.
MintosLatvia
ECB
Bank (credit institution)Intent announcedannounced 2026-02Investment platform seeking an ECB banking licence for deposit funding and direct lending.
The release says Mintos is initiating the process and expects 12-18 months; it does not confirm a filing.
NubankBrazil
Banco Central do Brasil
Bank (credit institution)Intent announcedannounced 2026-01Stated intention to obtain a full banking licence in Brazil in 2026, alongside the US national bank charter.
The release states the intention and the country, not the regulator or a filing date.
MonzoIreland
ECB (Central Bank of Ireland)
Bank (credit institution)Approved2025-12EU banking licence to serve the EU without partner banks; Ireland first, Spain launched since.
The sources say Ireland; the ECB / Central Bank of Ireland split is the standard route for a euro-area licence, not something either source spells out.
QontoFrance
ACPR + ECB
Bank (credit institution)Application filedfiled 2025-07Move from a French payment-institution licence to full credit-institution status: longer-term lending, savings and investment, and independence from partner banks for Pay Later.
Announced 2025-07-02. A January 2026 interview (JDN) says Qonto filed in 2024, and its CEO hoped for the licence in 2026. No decision found as of 2026-09-25. EU rules give the ECB six months from a complete application, twelve at most, so the announced date and the missing decision do not fit together: either the file was completed later, or a decision exists that was not found. Check before writing a status.
NubankMexico
CNBV
Bank (credit institution)Authorised, not yet fully operating2025-04CNBV authorisation for Nu México to organise as a banking institution.
Authorisation to organise as a bank; final operational approval was still pending as of the 2026-01-27 release. Recheck.
Payment and e-money licences are not bank licences and are not listed. Each row’s date is its latest status event: a decision, a filing or an intent announcement. Filing and intent dates come from the announcement itself (the company’s own release or press coverage of it), so they are recorded at month precision unless the company or regulator gave a day.

How to read the queue

What the queue says. A bank charter has become an ownership strategy, and the queue splits by what the applicant wants to own. 21 of the 38 applications are for national trust banks: crypto and stablecoin firms (Coinbase, Circle, Ripple, Bridge) that want to hold custody, reserves and settlement under one federal supervisor rather than outsource them to a partner bank and fifty state licences. 10 are for full national banks: fintechs (Revolut, Mercury, Nubank, Upstart) that want deposits, lending and the balance sheet themselves. 4 are existing state-chartered institutions converting to a national charter, today all crypto custodians (Paxos, Fidelity Digital Assets, BitGo) moving their trust companies under the OCC. 3 sit outside the OCC ladder (industrial-bank or state-trust applications). The stablecoin rows are the newest pattern: under the GENIUS Act, issuers are applying to own issuance, reserves, custody and dollar conversion end to end, which is why the trust-bank column now outnumbers the deposit-taking one.

National bank vs national trust bank
A national bank takes deposits and lends, carries FDIC insurance and the Community Reinvestment Act, and can replace a fintech’s sponsor bank outright (Revolut, Mercury, Nubank, bunq, Upstart). A national trust bank is uninsured and non-depository: it custodies assets and settles transfers under fiduciary powers, which is why the stablecoin and custody names — Circle, Coinbase, Ripple, Paxos, BitGo, Bridge, Block’s Builders Bank — file for one. It replaces fifty state money-transmitter and virtual-currency licences with one federal supervisor; it does not replace the sponsor bank behind a deposit product.
The OCC ladder
Application filed is the applicant’s announcement; the OCC posts receipts to its Corporate Applications Search with a delay. Conditional approval is the OCC’s preliminary conditional approval letter, published as a Corporate Decision or Conditional Approval — the bank must then raise capital, pass a pre-opening examination and, for a depository bank, obtain FDIC insurance, typically within eighteen months. Approved is final approval to commence business; Opened is a bank in operation. Conversions (Paxos, BitGo, Fidelity Digital Assets) move an existing state trust company onto a national charter and follow the same letters. A denial is published the same way, as a Corporate Decision with the same “application to charter” title — only the letter text says which way it went. Wise (July 2026) and bunq (August 2026) were denied after the OCC’s field investigation; either can reapply.
Why it matters for the sponsor-bank layer
Every deposit-taking applicant on this list currently runs on a partner bank — Mercury on Choice, Column and Evolve; Chime is buying Stride outright — and the charter is the exit from that relationship. The sponsor-bank leaderboard shows who they leave behind.
Analysis
The network isn't the only rail anymoreMoney-movement railsHow banks sell embedded financeEarly-stage companies to watchConsortiums & alliancesEmbedded finance news
Leaderboards
Sponsor banksBaaSCard issuingKYC / compliance
Regions
USUKEU
By theApideck research team— the unified API platform behind this charter tracker.