Mission Lane won conditional OCC approval for a CEBA credit card bank charter, the first of its kind in two decades according to adviser Klaros Group. The charter lets the subprime lender issue its own cards and export its rates free of state opt-outs, but it bars the small deposits that let full-service banks fund themselves cheaply.
Reality
- Evidence62
- Adoption30
- Hype gap+15
- Incentives70
- Confidence60
Bastion, Agora and Catena Labs won conditional national trust charters requiring $6 million or $10 million of working capital each, a low bar because trust banks do not lend. That makes eight such approvals before the GENIUS Act takes effect in January 2027.
Reality
- Evidence74
- Adoption34
- Hype gap+12
- Incentives62
- Confidence66
The OCC and FDIC now want supervisory criticism aimed at risks with material financial impact, which turns process and control weaknesses into informal observations a board can fund, defer or ignore.
Reality
- Evidence58
- Adoption30
- Hype gap+15
- Incentives76
- Confidence55
The regulator cleared the core bank and moved leveraged FX, forwards, merchant acquiring and correspondent banking into a separate queue, each needing its own sign-off before Revolut can sell it in the States. No other charter it granted this year works that way.
Reality
- Evidence68
- Adoption32
- Hype gap−8
- Incentives60
- Confidence63
The disintermediation story assumes money leaves banking. The mechanics of reserve placement and primary dealer accounts point somewhere less dramatic and more awkward for small banks.
Reality
- Evidence32
- Adoption14
- Hype gap+12
- Incentives58
- Confidence38