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Licensing

Bank and Trust Charters

Evaluate bank and trust-company charter pathways, regulatory expectations, and the operational readiness required for a potential application or acquisition.

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How we work through it

  1. FeasibilityCompare a charter with licenses and a sponsor bank. Choose the charter type and the regulator, and set out capital, cost, and timing.
  2. Business planThe multi-year business plan regulators ask for: products, markets, financial projections, capital, and liquidity.
  3. ProgramPolicies, the compliance management system, BSA and OFAC program, and risk and vendor oversight, written for a bank and not a startup.
  4. ApplicationReadiness support and document coordination for the applications your banking counsel files, and for regulator questions until a decision.
  5. OpeningPre-opening conditions, the pre-opening examination, and the first year under supervision.

Charter pathways and related approvals

Examples of charter structures and related regulatory approvals. Feasibility and eligibility require detailed analysis.

01

National bank charter

A full-service bank chartered and supervised by the OCC.

02

State bank charter

A bank chartered by a state banking department. Its federal supervisor is the FDIC or, for a Federal Reserve member bank, the Federal Reserve.

03

Industrial bank charter

An FDIC-insured bank chartered by a small number of states, chiefly Utah and Nevada. Whether a commercial parent can own one without becoming a bank holding company depends on the structure and regulatory review.

04

National trust bank charter

A limited-purpose OCC charter for fiduciary activities, including custody. Its powers are narrower than a full-service bank's, and it does not take insured deposits.

05

State trust company charter

A state charter for fiduciary and custody business. Powers vary by state, including for the limited-purpose route some digital asset custodians use.

06

FDIC deposit insurance

A separate FDIC approval decision, needed where a charter will take insured deposits. Not relevant to most trust structures.

07

Acquiring an existing bank

A transaction rather than a charter type, usually requiring several approvals, such as change-in-control or holding company applications.

What the charter expects of you

Regulators review the program behind a charter application, and examine it afterward. We help build it through our compliance service.

  1. Capital and liquidity plans that hold up under stress
  2. A board and management team that meets regulators' expectations
  3. BSA and OFAC program at bank standard
  4. Compliance management system, fair lending, and community reinvestment
  5. Third-party and technology risk management
  6. Internal audit and board reporting

Who regulates what

OCCCharters and supervises national banks and national trust banks.
State banking departmentsCharter state banks, industrial banks, and state trust companies.
FDICDecides on deposit insurance, and is the federal supervisor of industrial banks and many state banks.
Federal ReserveSupervises bank holding companies and state member banks. Its role in an application depends on the charter, holding company, membership, and control.

Who it's for

Established fintechs weighing whether a charter fits better than a sponsor bank, commercial companies weighing an industrial bank, digital asset custodians weighing a trust charter, and organizers of a new bank.

Unsure which of these apply to your model? Start with a regulatory applicability assessment →

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Let's discuss your regulatory needs.

Tell us about your business, product, or licensing challenge. We'll review your inquiry and discuss the appropriate next steps.

Discuss charter feasibility