Upstart Receives Conditional OCC Approval for De Novo National Bank Charter
The Office of the Comptroller of the Currency granted Upstart Holdings conditional approval on Jul 23, 2026 to establish Upstart Bank, N.A. as a de novo national bank. Upstart submitted its charter application in Mar 2026, roughly four months before the conditional approval. The bank will be based in Delaware, operate without physical branches, and originate loans to consumers nationwide while accepting FDIC-insured deposits.
Upstart's applications to the FDIC for deposit insurance and to the Federal Reserve for bank holding company status remain pending. Operations will not begin until all approvals are received and conditions around capitalization, governance, and operational readiness are met. Banks, credit unions, and institutional credit funds are expected to continue purchasing the vast majority of loans on the Upstart platform; the charter is intended to complement those funding partnerships.
Klaros Group advised Upstart on the de novo charter application.
- Signals continued OCC willingness to grant de novo charters to fintech lenders, potentially encouraging more applications
- Reduces BaaS dependency: Upstart's charter eliminates the need for sponsor bank partnerships, shrinking the addressable market for BaaS providers serving fintechs that pursue their own charters
- Sets precedent for AI-native banks operating under full national bank supervision