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From Entry to Enduring Competition: Flexible Bank Charters and Pathways to Scaling Up

BY | January 29, 2026

This article examines FinTech bank charters through a competition and prudential lens. Drawing on recent OECD analysis on competition in mobile payment services and on balancing prudential regulation and competition...

This article examines FinTech bank charters through a competition and prudential lens. Drawing on recent OECD analysis on competition in mobile payment services and on balancing prudential regulation and competition in banking, it advances three arguments. First, the entry of non-bank financial companies (“NBFCs”) has delivered important competitive benefits, but their long-term impact depends on firms’ ability to scale beyond narrow market segments. Second, partnership-based entry models

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