The de novo window reopened, and the management team is the application
In all of 2024 the OCC received exactly 1 application to charter a new bank. It approved none. Through August 5 of this year it has received 22 and approved 14.
Last Monday the FDIC changed how it reviews the deposit insurance half of those applications. The new process applies to anything filed after August 15. If you have been half-watching de novo formation as a curiosity, this is the week it stopped being one.
What actually changed
The FDIC split its review in two. Organizers who clear the bar get a contingent authorization within 120 days of filing. Then they get up to 12 more months to raise the capital, hire the people, and build the systems before coming back for the actual approval and deposit insurance order.
The old way, you spent the money first and found out later.
The FDIC's own explanation is that the two-phase process gives organizing groups clarity before they commit real time and money to "capital raising, staffing, infrastructure development and other start-up activities." Note the word sitting second in that list.
Applicants can now generally file with the FDIC and their chartering authority at the same time, and the FDIC says it will coordinate with that authority throughout. For a national bank that means the OCC. For a California state charter it means the DFPI.
The part I would pay attention to
The OCC has been running its own conditional-approval version of this for a while, and it is moving. Comptroller Jonathan Gould said the agency has decided many charter applications within 120 days of a complete filing, and that a full-service national bank has opened its doors for the first time in 5 years.
The OCC also rejected 2 de novo applications in recent days. Sullivan & Cromwell, which tracks this for its bank clients, flagged the stated grounds: concerns about the proposed business, management, finances or operational plans.
And the OCC says it plans to publish its denials as public letters.
Read that as a working recruiter would. The management slate named in a charter application is part of what gets graded, and a weak one is now a public document.
What this looks like from the search seat
I place production and credit leadership at California community and regional banks, so I get a specific version of this call.
An organizing group has capital lined up and a market it wants to serve, usually somewhere consolidation left a gap. It needs a CEO, a Chief Credit Officer, and 2 or 3 producers who can move a book with them. Until now, all of that had to be recruited on a maybe.
Try recruiting a sitting Chief Credit Officer out of a $2B bank into an institution that has no charter, no timeline, and no name on the door yet. I have had that conversation. It is a short one.
A contingent yes inside 120 days gives a candidate a date to point at. That is a different pitch, and it lands differently with a spouse.
One thing I want to be straight about: I do not have a verified count of how many of those 22 applications came from California organizing groups. The OCC's Corporate Applications Search will tell you, and I would check it before assuming your market is quiet.
Organizing a bank, or getting the call?
I run retained searches for production and credit leaders at California community and regional banks. If you're building a de novo management team, or weighing a seat on one, I'm glad to walk through the hiring sequence with you.
Talk to JonIf you are the banker getting the call
A de novo can be the best seat of a career. The person who runs credit at a bank from day 1 writes the credit culture instead of inheriting somebody else's. Before you get excited, get answers to 4 things.
Has the deposit insurance application actually been filed, and on what date? The 120-day clock starts at filing, not at the coffee meeting where somebody sketched it on a napkin.
Who else is on the management slate, and has any of them chartered a bank before? The regulator is grading that roster, and now it publishes when it does not like the answer.
What happens to your compensation during the organizing period, before the bank has a dollar of revenue?
And if the application gets denied, what is your landing spot? Ask it out loud. A serious organizing group will have thought about it.
The baseline this is coming off
From 2011 through 2014 the OCC averaged fewer than 4 charter applications a year. Some years, zero.
22 applications and 14 approvals in 8 months is a different market. Every one of those banks has to hire a management team before it can open the door, and the regulator is now reading that team as closely as the capital plan.
The regulator now reads the management team as closely as the capital plan, and a contingent yes gives that team a date to recruit against. That's the part of a de novo I'd want to get right first.
If an organizing group called you tomorrow, which of those 4 questions could they answer today?
Sources
- OCC, News Release 2026-67, “OCC Commends FDIC Reform, Advances Priority to Reinvigorate De Novo Chartering,” August 11, 2026. occ.gov
- OCC, “De Novo Bank Charters” fact sheet, charter applications and approvals by year, data as of August 5, 2026. occ.gov
- Sullivan & Cromwell LLP, “Bank Chartering Developments,” August 12, 2026. sullcrom.com
- Banking Dive, Dan Ennis, “FDIC tweaks de novo application process,” August 13, 2026. bankingdive.com
- FDIC, press release announcing the new review process for deposit insurance applications, August 10, 2026. fdic.gov
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