FinTechs’ Roadmap to Scale Includes Bank Charters

As FinTechs seek to broaden their reach, many are turning to bank charters as a means of expanding product lines, cutting through state-by-state licensing and gaining direct access to the U.S. financial system.

From Stripe’s merchant acquirer charter in Georgia to Nubank’s bid for a national charter, the surge underscores both opportunity and scrutiny in banking’s new frontier.

FinTechs and digital platforms are pushing to do more than process payments — in some cases, they want to hold deposits, issue loans, manage settlements and scale across borders.

But as their ambitions expand, so do the regulatory obstacles. Bank charters, long the province of traditional financial institutions, have become a way to unlock nationwide reach and access to the payments and settlement rails that keep commerce moving.

Without one, FinTechs must stitch together a patchwork of state money-transmitter licenses and rely on partner banks for access to the Federal Reserve system — a costly, time-consuming route that limits flexibility.

The momentum is building. Last week, Checkout.com announced that the Georgia Department of Banking and Finance had accepted its application for a Merchant Acquirer Limited Purpose Bank (MALPB) charter.  The firm announced its ambition to act as its own acquirer — gaining “direct access to US card networks” and reducing reliance on sponsoring banks.

Stripe’s April 2025 application for a Merchant Acquirer Limited Purpose Bank (MALPB) charter in Georgia offers another example. The state’s Department of Banking and Finance accepted the filing, positioning Stripe to process card payments directly through Visa and Mastercard without relying on a sponsor bank. The move follows Fiserv’s own MALPB charter, under which it processed its first card-based transactions in April.

Meanwhile, Nubank has taken a different tack. The Latin American giant applied this October for a full national bank charter in the U.S., part of a bid to expand beyond its home markets. The charter, if approved, would allow Nubank to take deposits and make loans under a single federal regulator — the Office of the Comptroller of the Currency (OCC) — rather than navigate 50 state regimes.

Cryptocurrency firms are also seeking legitimacy through the charter process. Circle, Ripple and Wise have each filed for national trust bank charters with the OCC, a structure designed for custodial and fiduciary services rather than deposit-taking. These trust charters would allow them to hold customer assets, manage stablecoin reserves and access the Fed’s payment system directly — something impossible under a simple money-transmitter license. Not everyone is on board: banking trade groups have urged regulators to delay or scrutinize these applications over risk and supervision concerns.

The race for charters reveals a spectrum of ambitions — and risk appetites.

At the top sits the full national bank charter, which gives FinTechs the same powers as established banks: they can accept deposits, extend credit and branch nationwide. It’s also the most demanding, requiring high capital buffers, liquidity ratios and compliance standards. That’s the route Nubank is pursuing, and it’s the model that appeals to FinTechs seeking to become true financial institutions rather than service providers.

By contrast, limited-purpose charters — such as Georgia’s MALPB license — offer a narrower, arguably faster path. They allow payments firms like Stripe or Fiserv to operate as their own acquirers, eliminating intermediaries and reducing costs. But they stop short of permitting deposit-taking or lending. For global processors that already move massive payment volumes, the limited scope is a strategic trade-off: efficiency and control without the full regulatory weight of a commercial bank.

A third model, the Industrial Loan Company (ILC) or industrial bank charter, occupies a unique middle ground. Authorized in a handful of states like Utah, ILCs can accept deposits and make loans but remain exempt from the Bank Holding Company Act. That exemption allows their parent firms — often large commercial companies — to remain outside consolidated Federal Reserve supervision. It’s an appealing structure for FinTechs that want banking capabilities without giving up corporate flexibility, but one that raises perennial concerns about mixing commerce and banking.

Finally, there’s the acquisition route — buying an existing bank to inherit its charter and infrastructure. LendingClub acquired Radius Bank, transforming into a regulated institution with deposit and lending powers. Now Revolut is reportedly weighing a similar move to accelerate its U.S. expansion. Acquiring a charter can save time but comes with legacy systems, liabilities and regulatory baggage that de novo applicants can avoid.

Taken together, these pathways form a hierarchy: limited charters for speed and scope, ILCs for flexibility, national charters for full control, and acquisitions for immediacy. Each reflects how deeply a company wants to embed itself in the financial stack — and how close it’s willing to get to the regulatory core.

• April 4, 2025 – Stripe’s MALPB application accepted by Georgia Department of Banking and Finance.
• April 30, 2025 – Fiserv processes first transactions under its MALPB charter.
• Mid-2025 – Circle, Ripple, Wise apply for national trust charters.
• Oct. 3, 2025 – Nubank applies for a U.S. national bank charter.
• 2025 (ongoing) – Revolut considers acquiring an American bank to land a U.S. license.

Whether through a national charter, a limited-purpose license or a merger, the goal is the same: direct participation in the regulated banking system and the efficiency that comes with it.

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