For a decade, the winning fintech strategy was to avoid the banking licence. Renting one from a small partner bank was cheaper, faster, and left all the energy free for the product. In a single week of September 2026, three announcements reversed that logic completely.
On 3 September, Revolut received conditional approval from the OCC for a US national bank charter. On 8 September, Block filed an application with the same regulator to establish a national trust bank. The same day, Chime announced it was buying Stride Bank for $590 million in cash — the bank that had already been holding its members' accounts for seven years.
Three companies, three different doors, one conclusion: the licence is no longer a compliance cost. It is the product.
What was announced
Revolut — the long road. The OCC gave conditional approval for Revolut Bank US. That is a first step only: the FDIC still has to grant deposit insurance, the Federal Reserve has to sign off, and the OCC has to issue final approval. Target launch is 2027. Once the full set is in hand, Revolut can offer Americans loans, credit cards, FDIC-insured deposits, and crypto and stablecoin services directly.
Block — the narrow road. Builders Bank & Trust, N.A. would be an uninsured national trust bank: no deposits, no lending. Custody and related fiduciary services only, including for bitcoin and stablecoins. Block is after a single federal supervisory framework for activities it already runs, instead of a patchwork of state licences. Lee Woolley, previously at Northern Trust and BNY Mellon, would lead it.
Chime — the fast road. $590 million in cash, roughly 1.5x Stride's tangible book value. Stride, founded in Enid, Oklahoma in 1913, becomes Chime Bank, N.A. Chime expects more than $100 million in net synergies: partner-bank fees eliminated, funding costs down, direct control over rolling out credit products. The company is explicit about the trade-off — buying a charter is faster and less uncertain than building one de novo. Closing is expected in the first half of 2027, subject to OCC and Fed approval.
Why the pendulum swung back
The banking-as-a-service model rested on one assumption: that a charter is a commodity you can rent. Two things broke it.
First, the economics. Partner-bank fees are rent taken on every account, every card, every deposit. At ten million active members, they stop being a cost line and become a tax on growth. Chime's arithmetic is blunt: $590 million once, against more than $100 million recurring every year.
Second, supervision. Since the 2023 third-party risk guidance, sponsor banks carry far heavier oversight obligations for the fintech programmes they host. The paradoxical result is that being supervised indirectly, through a partner who is himself under pressure, has become more constraining and less predictable than being supervised directly. Owning the charter means trading an opaque dependency for a direct relationship with the regulator.
The OCC window is open — it will not stay open forever
This is the part most coverage misses. The American acceleration is not structural. It is circumstantial.
In 2025 the OCC received fourteen de novo charter applications, nearly as many as in the previous four years combined. December 2025: five conditional trust charter approvals at once, including Circle, BitGo, Fidelity Digital Assets and Paxos. January 2026: Nubank. March: VALT. April: Mercury. May: Augustus. July: final approval for Circle, plus a conditional green light for Sony Bank to issue dollar-backed stablecoins. On 1 April 2026, an amendment to 12 CFR 5.20 took effect clarifying that national trust banks may conduct non-fiduciary custody activities — precisely the legal brick Block's application rests on.
That architecture sits on a chain of regulatory interpretations advanced under one administration and one Comptroller. The Bank Policy Institute, the traditional banking lobby, has publicly weighed suing the OCC over these approvals. A lawsuit would put the whole chain in front of a judge.
Which gives September 2026 its real reading: the scarce resource is not the licence, it is the window. Everyone is filing now because nobody knows how long the door stays open.
Three doors, three prices
| National bank charter | National trust charter | Buying a bank | |
|---|---|---|---|
| Example | Revolut | Block | Glockenspiel |
| What it allows | Insured deposits, lending, cards | Custody, fiduciary services | Whatever the acquired bank does |
| Regulators | OCC + FDIC + Fed | OCC only | OCC + Fed (change of control) |
| Timeline | Several years | 12–18 months | 9–12 months |
| Cost | Regulatory capital, application | Comparatively low | Premium to book + integration |
| Main risk | The FDIC | Litigation | Price and execution |
Three positions worth stating against the consensus.
The trust charter is arbitrage with a shelf life. It delivers a federal framework without deposit-bank obligations — which is exactly what the incumbent banks are contesting. Anyone obtaining one today is buying a regulatory position whose value depends on an interpretation no court has tested yet.
Buying is the underrated move. 1.5x tangible book value for a small national bank is a modest price for removing three years of uncertainty. There is only a limited stock of US banks experienced in running fintech programmes. If Chime sets the precedent, their valuations rise mechanically. The sector's next wave is not a wave of charter applications — it is a wave of sponsor banks being bought out by their own clients.
And Revolut's real obstacle is not the OCC. The OCC is the most accommodating regulator in the current chain. The FDIC is the one that decides on deposit insurance, and that is historically where fintech applications stall or die. September's conditional approval is a real step, not a finish line.
Revolut: collecting licences as a defensive strategy
Revolut's 2026 reads like a campaign: full UK banking licence in March, after a mobilisation phase that ran four years; Australian ADI licence in July, a first for a global fintech; the launch of its Mexican bank, its first fully licensed entity outside Europe; a French banking licence in August, granted after a joint assessment by the ACPR and the ECB; a payments licence in the UAE; applications in progress in Brazil, Colombia, Peru, Argentina and South Africa. The stated target is 100 million customers by mid-2027.
The usual reading is offensive: Revolut is opening markets. The more accurate reading is defensive. The French licence ends the dependency on the Lithuanian passport for tens of millions of European customers — a single point of failure sitting under most of the portfolio. A company at that valuation cannot leave access to its largest market resting on one national authorisation.
It is also the only real moat. The interface, the interbank exchange rates, the multi-currency cards: all of it can be copied in eighteen months. Eight years spent in a regulator's queue cannot.
What it means from Switzerland
Switzerland is the blind spot on this map. Revolut operates there without a FINMA licence, under its Lithuanian authorisation, which means Swiss customers' deposits are not covered by the CHF 100,000 esisuisse guarantee. Neon runs on Hypothekarbank Lenzburg's licence; Yuh on Swissquote's.
Two consequences.
For Swiss players, the partner-licence model is exactly the one US fintechs are now spending hundreds of millions to escape. It works while volumes stay moderate. It becomes rent on growth as soon as they don't.
For Revolut, the Swiss anomaly gets more conspicuous with every national licence the group stacks up elsewhere. Either Switzerland joins the list, or it stays the market where "we are a bank" comes with an asterisk — a lasting handicap in a country where deposit protection is a core selling point.
What to watch over the next twelve months
- Conversion of conditional approvals into final ones: the only reliable measure of how solid this wave is.
- Whether the Bank Policy Institute actually sues the OCC.
- Revolut's FDIC step, which matters more than the OCC step already cleared.
- Whether Chime's acquisition of Stride actually closes in H1 2027, and whether comparable deals follow.
- The price of small US national banks specialised in fintech programmes.
Sources
- Chime — Agreement to Acquire Stride Bank
- Block — Builders Bank, a National Trust Bank
- Revolut — Conditional approval from the OCC
- Revolut — French banking licence
- Revolut — Australian banking licence
- American Banker — Fintechs asking for, and receiving, bank charters in 2026
- Davis Wright Tremaine — OCC's Recent Charter Approvals Signal Momentum
- PYMNTS — OCC Clarifies Charter Rule and Extends National Path for FinTechs
- Venable — National Trust Bank Charters: A Strategic Pathway