The Office of the Comptroller of the Currency (OCC) is facing a growing backlog of applications for federal banking charters, creating a potential bottleneck for FinTechs, stablecoin issuers, and digital asset companies. Between January 2025 and October 23, 2026, the OCC received 49 de novo charter applications, approving 28, denying two, and returning one. The agency has been reshuffling personnel to manage the influx, but the review process is complex, requiring evaluations of capitalization, governance, and operational readiness.
The delay poses a significant risk for late applicants, as the mismatch between demand and the government's capacity to evaluate applications could turn into a competitive disadvantage. Companies that secure approval early may gain a head start in areas like custody and digital asset infrastructure, while those still waiting might find partnering with existing banks a faster and more cost-effective option.
The appeal of federal charters lies in their ability to provide a consistent supervisory framework, facilitate financial activities, and offer greater control over infrastructure. Firms like Circle, BitGo, Fidelity Digital Assets, and Paxos have already advanced through the federal trust charter process. Most recently, Coinbase announced its regulatory approval to establish a nationally chartered trust bank, following its conditional approval in April 2026.
However, the arrival of a new Congress next year could bring increased scrutiny for the crypto sector. The competitive hierarchy is now defined by operating institutions, conditionally approved institutions, and applicants awaiting regulatory decisions. For companies unable to secure authorization quickly, partnerships with existing banks may offer a more immediate route to market, potentially redefining the next phase of banking innovation.