A single pre-crisis year produced more new U.S. banks than all of 2010 through 2024

Divide Cornerstone Community Bank's roughly $27 million by its 230-plus shareholders and the average subscription comes to under $117,000 ^[18]. Because no individual or group holds more than 5% ^[8], the largest stake in the bank is worth about $1.35 million ^[19]. So the raise scaled with the number of investors Owensboro could supply, and the organizers finished about $7 million above what they were required to hold ^[8].

Jason Hawkins, who runs First United Bank and Trust Company in Madisonville and is vice chairman of the Kentucky Bankers Association, made the geography explicit. "If we were to try to start First United Bank today, we're not in as large of a community as Owensboro," Hawkins told lawmakers. "Madisonville is a much smaller community, and that capital raise of $20 million would be pretty tough." ^[13] First United was itself chartered as a de novo in 1996 and ended 2025 with more than $600 million in assets ^[12].

Subcommittee Chairman Andy Barr asked Cornerstone chief executive Kyle Aud why forming a new community bank has become so difficult ^[15]. "We started the process in June of 2025 and opened in June of 2026, and it probably wasn't until February or March of '26 that I felt pretty good that we were going to have a bank," Aud said. "A lot of that had to do with timing and with the capital that we were required to have; everything revolved around the capital." ^[9] That is roughly twelve months of payroll, premises, a core banking system, correspondent relationships and outside IT, human resources and compliance work ^[11][22]. All of it comes before the first loan. "Those costs arrived well before the earning assets did," Aud said in his written testimony ^[10].

The formation record is blunter than the testimony. Federal Deposit Insurance Corp. data put the weakest year between 1995 and 2007 at 93 new banks, and the whole of 2010 through 2024 at 86 ^[2]. That is about 5.7 a year ^[16], and seven fewer in fifteen years than that one weak year managed alone ^[17]. Applications and approvals at the Office of the Comptroller of the Currency fell about 90% after 2008 ^[3].

According to pymnts, the $20 million is what Cornerstone's regulators required of its organizers ^[7]. The hearing coverage does not include a published national minimum, so the claim that $20 million is the gate every applicant faces rests on what the Kentucky witnesses told the subcommittee.

The OCC's pipeline is also thinner than the headline count. Forty applications in eighteen months is about 27 a year ^[20] against fewer than four a year from 2011 through 2014 ^[5]. Comptroller Jonathan Gould said 23 of the 40 involve some form of digital asset activity ^[6], leaving 17, or about 11 a year, that do not ^[21]. The OCC counts national trust banks in the total ^[5].

I would expect a lower capital floor on its own to add a handful of charters a year. The other two constraints in the Richmond testimony sit outside it: the year of spending before any earning asset ^[10], and the investor count Hawkins doubts his own town could produce ^[13]. The counter-case is Aud's, that capital is the gate everything else waits behind ^[9]. If the Act cuts the requirement and charters start appearing in markets the size of Madisonville, that reading wins and mine loses. Timothy Schenk of the Kentucky Bankers Association told Barr that a bank can cross a regulatory threshold because its balance sheet grows, even when its business and risk profile have changed little. He said the Main Street Capital Access Act would require greater consideration of business models ^[14].