Bank Charters Are Reshaping Who Can Compete for Consumer Deposits

Bank charters represent the operating system (OS) for the U.S. financial sector.

But not all charters are created equal, and the differences matter immensely for what institutions can do, how they’re supervised, how quickly they can scale and how much risk they can take.

For example, the horizon-technology-focused Erebor bank on Friday (Feb. 6) became the first bank to receive a national bank charter from the Trump administration, allowing the entity to operate as a bank nationwide.

On Monday (Feb. 9), YouTube star MrBeast announced the acquisition of the FinTech platform Step, with one of his investors proclaiming on X that they had “bought a bank,” a statement later fact-checked by the social platform’s community notes which clarified that Step is a banking platform, not a bank.

Add to those announcements the fact that more than two dozen new de novo charter applications have been filed with regulators in recent months, and the message is clear: banking is back in vogue.

Just what “banking” refers to, however, is increasingly up in the air as regulators issue or weigh new charters for national banks, state-chartered commercial or savings banks, federal or state savings associations (thrifts), industrial loan companies (ILCs), credit unions and special-purpose banks.

The emerging banking landscape increasingly resembles a constellation of pathways, each with its own constraints and powers. For payments, commerce and FinTech, understanding those distinctions is becoming a competitive necessity.

More here: FinTechs and Automakers Pursue Bank Charters to Expand Lending

Why the Banking Charter Suddenly Matters Again

Traditionally, FinTech companies have built around banks, not as banks. The strategy was simple: partner for access to payments rails, deposit insurance and compliance infrastructure; don’t built it from the ground up yourself.

That model delivered speed but also fragility. Sponsor banks could change terms, regulators could reinterpret guidance and public scrutiny intensified after high-profile failures exposed the limits of “banking-as-a-service.”

Yet “getting a charter” is not a monolith. In the U.S., de novo banking charters cover a variety of “banking” business models. Each answer to different regulators, operate under different statutes and carry different privileges. While the headlines can blur these lines, the operational consequences are anything but vague.

A bank charter “is not a trophy, and it certainly isn’t a product label, but it’s a public trust,” Rodney E. Hood, former acting comptroller of the currency, told Competition Policy International, a PYMNTS company, in a January interview.

A national bank charter, granted by the Office of the Comptroller of the Currency (OCC), is the most expansive and the most demanding. It allows an institution to operate nationwide under a single federal supervisor, preempting a patchwork of state laws. National banks can take deposits, make loans and connect directly to the Federal Reserve’s payments systems.

State-chartered commercial and savings banks offer a different balance. Supervised by state regulators with federal oversight layered on, these institutions can be more closely attuned to local markets.

Savings associations, often called thrifts, are a relic with renewed relevance. Historically oriented toward housing finance, thrifts can still offer deposits and loans but must maintain a qualified thrift lender test, anchoring a significant portion of assets in residential lending. Regulatory oversight differs as well. Federal thrifts fall under the OCC, while state thrifts answer to state authorities.

Special-purpose banks, which are often focused on trust services, payments or custody, offer precision. By limiting activities, they can tailor compliance and operations to specific use cases. For crypto custody or payments processing, that narrowness can be appealing. The OCC received seven digital asset licensing applications from entities planning to offer digital asset products or services in 2025, with five of them being conditionally approved.

The industrial loan company, or ILC, can take insured deposits and make loans, but their parent companies are not subject to the Bank Holding Company Act. That exemption allows commercial firms to own banks. For FinTechs and retailers, the ILC offers a way to integrate financial services deeply into commercial platforms. Payments, credit and data can live under one corporate roof. Last month, the FDIC approved deposit insurance applications submitted by Ford and General Motors to establish their own respective Utah-chartered industrial banks.

See also: Why Banks Want to Issue Stablecoins

What This Means for Payments, Commerce and FinTech

The charter renaissance signals a maturation of FinTech. The era of pure abstraction, of apps floating above banks, is increasingly giving way to integration. This, in turn, is reshaping the financial services landscape.

For example, on Feb. 2, Fifth Third Bancorp and Comerica merged together, forging an institution with roughly $294 billion in assets and signaling a reshaping how regional banks compete across mobile banking, commercial payments and middle-market services. The transaction establishes the ninth-largest U.S. bank by assets and links Fifth Third’s consumer digital platform with Comerica’s commercial franchise, particularly in Texas and California.

Meanwhile, on Feb. 3, Banco Santander announced plans to expand its presence in the United States by acquiring the holding company for Connecticut-headquartered Webster Bank for $12.2 billion.

At the end of January, digital financial services giant Nu received conditional approval from the OCC to establish a new national bank in the United States; while PYMNTS also covered how cryptocurrency exchange ByBit reportedly wants to look more like a bank and plans to begin offering banking services, including accounts that allow users to hold balances in U.S. dollars and other fiat currencies.

Still, it’s important to stress that when it comes to banking charters, what looks like a shortcut can also turn into a long-term governance and reputational challenge if the regulatory winds shift following the current administration.