The OCC may have rolled out the welcome mat for bank charter applicants, but this week reminded everyone there’s still a bouncer at the door.
Yesterday, the OCC released a statement clarifying the filing decision process for charter applicants. It emphasized, “the OCC may approve, conditionally approve or deny a filing. In addition, the OCC may return a filing as materially deficient… [if there is] failure to furnish required biographical and financial information of individuals and corporate background and financial report for entities… [or] responses do not sufficiently respond to the requests.”
The clarification lands amid a broader charter rush. In December, the OCC conditionally approved five national trust bank applications tied to digital assets, including Ripple, Paxos, BitGo, Fidelity Digital Assets and First National Digital Currency Bank. Since then, the pipeline has continued to fill: the OCC’s digital assets licensing page lists a string of 2026 applications from firms including World Liberty Trust Company, Morgan Stanley Digital Trust, Revolut Bank US, and Payward National Trust Company.
The agency has also moved to clarify the authority of national banks to conduct non-fiduciary activities, a change that took effect April 1 and updated the chartering language from “fiduciary activities” to the broader “operations of a trust company and activities related thereto,” perking up the ears of digital asset firms.
So why the sudden warning shot?
We asked leaders at advisory firm Klaros Group what they believe the statement spells for the industry.
“There is (the correct) sense that the window is open and that if you want a bank, now is the time,” said Seth Ross, Partner. “But we are seeing that this is pushing businesses to want to apply for a bank charter before they really know what they want to do with it.”
Michele Alt, Co-founder and Partner, likewise suggested the OCC has been flooded by less-than-stellar requests: “The OCC has been getting bad applications from applicants who assume, in the current environment, they don’t have to do the hard work of designing a credible business plan.”
Applicants, take heed: indeed, the OCC is open for business… but not if the business plan was written on the back of a napkin. Strict checks remain to get past the velvet rope.
-The Editors
