Bank Charter Surge Tests OCC Resources and Resolve

The Office of the Comptroller of the Currency is reshuffling internal talent to manage a surge in new bank applications, as interest in federal charters climbs to levels unseen in more than a decade.

Comptroller Jonathan Gould said the agency is moving experienced staff from its supervision arm into one and two year rotations within its chartering function to cope with the increased workload.

The shift follows a sharp uptick in applications during 2025, when 18 new bank charter requests were submitted to the OCC. That figure matches the total number received over the previous four years combined.

The spike has drawn attention because it represents the most pronounced revival in charter activity since the period around the 2008 financial crisis. Yet Gould stopped short of declaring the volume extraordinary.

In an interview this month, he said he does not “presume to know what the, or whether there is, an appropriate level of interest or not.”

Historically, the current numbers remain modest compared with the pre crisis era. Nearly every year between 1990 and 2008 recorded at least twice as many applications as 2025.

In two of those years, applications peaked at roughly seven times the current level. Even so, the rebound marks a notable shift from the post crisis slump that saw charter formation drop sharply.

Gould described the current rise as a positive signal for the financial system.

“Generally, new bank formation in this country is a sign of the health of the banking system,” he said.

“And it is something that, where possible and consistent with the statutory factors, we should encourage, because it is a way to ensure that the banking system remains responsive to the communities and the economies across America that it is designed to serve.”

Following the 2007 08 financial crisis, appetite for new charters fell dramatically.

Although several of the most prominent institutions that failed during the crisis were long established banks rather than new entrants, regulatory tolerance for expansion and experimentation contracted sharply in the aftermath.

Gould said that reduced risk appetite permeated the regulatory environment in the years that followed. “You see it in a whole host of other areas – in terms of our regulation and supervision, too,” he said. The charter slowdown, in his view, reflected a broader tightening of supervisory posture.

As the sole federal chartering authority, the OCC occupies a unique position within the U.S. banking system.

That authority gives the agency significant influence over how new institutions enter the market and how innovation is channeled through the regulated sector.

Since returning to the agency, Gould has sought to elevate the prominence of the chartering function.

Six months ago, he reorganized what had been known as the licensing group, renaming it the chartering organization and structure team. He also changed its reporting line so that it now reports directly to him.

The restructuring signals how central Gould views chartering to the future of federal banking oversight. He described the unit as having “critical importance to the federal banking system,” calling it “in some sense, the gatekeepers of the system.”

The influx of applications has tested the agency’s capacity, prompting the decision to draw temporarily on supervisory personnel.

By rotating experienced examiners into the chartering process, the OCC aims to preserve institutional knowledge and maintain consistency in how applications are evaluated.

The renewed interest in bank formation comes at a time of evolving competition from fintech firms, digital lenders, and nonbank financial institutions. Whether the current wave represents a sustained shift or a temporary rebound remains to be seen.

For now, Gould appears to welcome the renewed activity as a sign of vitality, while ensuring the agency remains equipped to manage the responsibility that comes with opening the gates to new entrants.