Java|Oct 08, 2026 00:22
@raincards and @ModernTreasury both applied to the OCC for national trust bank charters this week.
How to start a chartered bank in the US:
> Pick the right charter you want (national, state, etc) and the permissible activities
> Recruit a qualified board with relevant banking experience
> Hire an experienced CEO + management team
> Pass background + financial checks
> Submit a 3+ year business plan to show a path to profitability
> Raise sufficient regulatory capital (~25 million)
> Build a capital + liquidity plan
> Build BSA/AML + OFAC programs
> Build the full compliance management system
> Build bank-grade cybersecurity + infosec
> Establish third-party/vendor risk management
> Set up internal controls + independent audit
> Address CRA requirements, if applicable
> Form the legal entity + governance structure
> Handle securities-law requirements for the raise
> Go through public notice and comment
> Receive OCC preliminary approval
> Raise approved capital, generally within 12 months
> Build the bank
> Pass the OCC pre-opening exam
> Obtain any required FDIC/Fed approvals
> Receive final OCC approval and open
> Operate under intense supervision for the first ~3 years
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