A surge of FinTechs, stablecoin issuers and digital asset companies seeking federal banking charters has created a potential bottleneck at the Office of the Comptroller of the Currency (OCC). And for companies still waiting for approval, the biggest risk may no longer be regulatory rejection. It may be running out of time.
The OCC received 49 de novo charter applications between January 2025 and October 23, 2026, approving 28, denying two and returning one, according to its published dashboard. PYMNTS covered on Tuesday (Nov. 10) that the agency has reportedly been reshuffling personnel to handle the influx of work associated with those applications.
Staffing is consequential because charter reviews cannot be reduced to administrative processing. Examiners must evaluate capitalization, governance, management, business models, risk controls and operational readiness.
The uncomfortable fact facing unchartered financial services firms is that there’s now a growing mismatch between demand for federal banking privileges and the government’s capacity to evaluate applicants. With the 2028 presidential election approaching, that mismatch could turn a regulatory processing problem into a competitive dividing line.
Companies that secured approval early may gain a head start in custody, digital asset infrastructure and financial services distribution. Those still waiting could find that partnering with an existing bank is faster, cheaper and more commercially attractive than becoming one.
Read more: Three Charts Show Who Wants a Federal Bank Charter and Why
The OCC’s Charter Boom Has a Capacity Problem
For much of the past decade, new federal bank charters were relatively rare. That changed as the Trump administration’s regulatory posture encouraged FinTechs and digital asset companies to reconsider whether federal supervision could offer advantages over fragmented state licensing and bank partnerships.
The appeal is straightforward. Depending on the charter, federal authorization can provide a more consistent supervisory framework, facilitate certain financial activities and give companies greater control over infrastructure they previously accessed through intermediaries.
For institutional customers, a federally supervised entity may simplify certain due diligence and counterparty assessments. For FinTech partners, an approved institution may provide a more credible foundation for launching regulated services. And for investors, regulatory progress removes one important uncertainty from a business model.
Firms including Circle, BitGo, Fidelity Digital Assets and Paxos have advanced through the federal trust charter process, positioning themselves to build regulated digital asset custody and related institutional infrastructure.
Most recently, the crypto exchange Coinbase on Monday (Nov. 9) announced its own regulatory approval to establish a nationally chartered trust bank. The news follows Coinbase’s April announcement that it had been granted conditional approval from the OCC, a move that soon received pushback from The Independent Community Bankers of America. The industry group argued Coinbase’s application did not meet the requirements of the National Bank Act or the OCC’s own regulations and standards.
However, the arrival of a new Congress next year could mean much more scrutiny for the crypto sector, PYMNTS wrote after last week’s election.
“For cryptocurrency firms, the challenge is shifting from securing favorable legislation to demonstrating that their business models can survive more demanding oversight,” the report said. “The midterms did not repeal crypto’s legislative victories. They changed who gets to interrogate them.”
Read more: The New FinTech Scorecard Starts With a Bank Charter
Regulatory Timing Is Emerging as the Next Banking Moat
The OCC has not announced a chartering cutoff, and recent approvals demonstrate that applications continue to advance. But a legally open window is not necessarily a commercially useful one. And conditional approvals also occupy a different category.
Stripe-owned Bridge, Crypto.com and other digital asset applicants have received conditional authorization, but such decisions generally require additional operational, capital and supervisory milestones before an institution can commence business.
The emerging competitive hierarchy is not simply approved versus rejected. It is operating institutions, conditionally approved institutions and applicants whose strategic plans still depend on a regulatory decision. A company filing in late 2026 may face months of review, followed by additional capital, compliance and operational requirements. For full-service banks, separate FDIC and Federal Reserve approvals may extend that process.
For companies unable to secure authorization quickly, partnerships with existing banks may offer a more immediate route to market. Rather than asking whether FinTechs will replace banks, the market may ask which banks and federally supervised institutions will supply the infrastructure behind the next generation of FinTech products.
The next phase of banking innovation, then, may not be defined by how many new companies receive charters. It may be defined by how many decide they no longer need one.
For all PYMNTS digital transformation and B2B coverage, subscribe to the daily Digital Transformation and B2B Newsletters.
