Novel Bank Charters and Why Fintechs and Others Should Consider Them Now

On March 27, 2025, bank regulatory partner Matt Bisanz will speak on a Practising Law Institute program about novel bank charters and fintechs.

Interest in bank charters for fintechs, digital asset service providers, and other firms has been reinvigorated by the return of Trump appointees to the federal banking regulators. In the first Trump administration, several lucky applicants secured novel (a.k.a. “special purpose”) bank charters that allowed them to grow their fintech businesses on a national basis, although even more were left with in-process applications that ultimately did not succeed. During the Biden administration, only a small number of financial innovators obtained federal approval for novel arrangements involving national trust banks and uninsured state banks. Faced with these impediments, some firms pivoted to achieve their goals through the acquisition or establishment of full service banks that focus on specific innovative products and services.

Today, there is an increasing number of novel bank charter options to explore. These include uninsured state, territorial, and tribal banks, trust companies, and federal branches of foreign banks. There also are idiosyncratic options, such as Georgia’s merchant acquired limited purpose bank and Wyoming’s special purpose depository institution. These options can create new use-cases for consumer payments, commercial deposits, stablecoins, and currency distribution, and potentially receive access to a Federal Reserve Master Account and payment services. Please join Matt to discuss developments in charter choice and the prospect of tech and fintech firms entering into parts of the business of banking through novel charter options.

For additional information on the program, please visit the event webpage.