In a landscape once marked by regulatory quiet, 2025 has seen a dramatic resurgence in applications for new bank charters, particularly from financial technology and cryptocurrency firms. This surge has ignited a fierce debate about the very definition of banking in the digital age. At the center of this conversation is the Office of the Comptroller of the Currency (OCC), the agency responsible for chartering national banks. We delve into this complex issue, exploring the OCC’s perspective on this “return to norm,” the contentious debate around digital asset custody, and the broader vision for a more competitive banking sector. We’ll examine the operational realities of safeguarding new forms of assets and how regulators are collaborating to usher in an era of innovation without sacrificing stability.
You described the 14 de novo applications in 2025 as a “return to the norm.” Could you elaborate on what specific regulatory signals or policy shifts at the OCC encouraged this surge after the previous four-year lull? Please detail the steps your agency took.
The phrase “return to the norm” is really about a shift in regulatory posture more than a single new policy. For the preceding four years, the environment was characterized by what Comptroller Gould called “regulatory dissuasion,” which had a chilling effect on new bank formation. The most significant step the OCC took was to change its tune and actively signal that it is open for business. This isn’t about lowering standards, but about providing a clearer, more predictable path for applicants. When leaders like Gould publicly state that this influx of applications signals “healthy competition” and a “commitment to innovation,” it sends a powerful message to the market that well-conceived, well-capitalized proposals will get a fair hearing. The surge of 14 applications, which is nearly what we saw in the last four years combined, is the industry directly responding to that more welcoming and encouraging stance.
Trade groups argue that crypto custody is “contrary to OCC precedent.” Given that national trust banks hold nearly $2 trillion in nonfiduciary assets, can you provide specific examples of the traditional custody activities that would be disrupted if the OCC changed its long-standing position?
This argument from trade groups misinterprets the fundamental nature of custody and the established role of national trust banks. Reversing the OCC’s long-standing position would be incredibly disruptive. We’re not just talking about futuristic crypto assets; we’re talking about the core, traditional business of these institutions. In the third quarter alone, existing national trust banks held nearly $2 trillion in nonfiduciary custodial assets. This makes up about a quarter of their total assets under administration. If the OCC were to suddenly declare that nonfiduciary custody is out of bounds, you would be threatening to undermine well over a trillion dollars in existing, conventional activities. This isn’t a niche issue; it’s a foundational service that has been part of the federal banking system for decades.
You compared digital asset custody to holding electronic company shares. Can you walk me through the operational similarities in risk management and safekeeping for these two asset types? What specific metrics does the OCC use to evaluate the technological competence of these new applicants?
That’s an excellent and crucial comparison because it grounds this “new” activity in a practice that is already decades old. When a national trust bank holds company shares for a customer, they aren’t typically storing a physical paper certificate in a vault anymore. They are holding rights by electronic means—a digital entry in a ledger. The fundamental principles of risk management are identical for a digital asset. The core functions involve secure key management, robust cybersecurity to prevent unauthorized access or theft, and operational resilience to ensure the asset can be accessed and transferred by its rightful owner. The underlying technology might be a blockchain instead of a more traditional database, but the fiduciary duty and the operational challenge of safekeeping a digital representation of value remain the same. The OCC evaluates an applicant’s technological competence by scrutinizing their entire risk management framework, their cybersecurity protocols, their third-party vendor management, and their plans for operational continuity.
With both you and FDIC Chair Travis Hill championing new bank charters to foster “healthy competition,” what are the key performance indicators you’ll be watching over the next few years? Can you describe the collaborative process between your agencies when vetting these nontraditional applicants?
The ultimate goal, shared by both the OCC and the FDIC, is a more vibrant and innovative banking system that serves consumers and businesses better. The key performance indicators we’ll be watching for are not just the number of new charters, but the impact they have on the market. We’ll look for increased product innovation, better pricing on loans and services, and expanded access to the financial system for underserved communities. Collaboration between the agencies is absolutely critical, especially with nontraditional applicants. While the OCC is the primary chartering authority for national banks and trusts, the FDIC’s role in providing deposit insurance is a crucial part of the safety and soundness framework. The vetting process is a joint effort in evaluating the applicant’s business plan, the strength and experience of its management team, its capital adequacy, and its risk management infrastructure to ensure that any new entrant, no matter how innovative, is built on a solid and safe foundation.
What is your forecast for the future of bank chartering, especially as more fintech and crypto firms seek to enter the traditional banking system?
