Since the financial crisis, we’ve had very few new banks.
-Dodd-Frank made it more expensive to start one.
-Scale became critical in a way that shut out small entrants: fixed costs of compliance, regulatory reporting, cybersecurity, core IT systems, AML monitoring all increased
-low-interest-rate environment made banking margins unattractive
-Most fintechs actually benefited from not being banks, because of Durbin (scaled banks make less per card swipe than smaller banks that fintechs partner with)
-most importantly, the OCC simply wasn’t granting very many new charters
Now the landscape is shifting
-Regulators are signaling a friendlier posture, with the OCC and FDIC saying they want more de novos.
-Congress is pushing too (Promoting New Bank Formation Act)
-Rise of stables means we'll need regulated, trustworthy banks to custody reserves and provide payment access
-Fintechs that avoided charters are now seeking them for a variety of reasons - some to get direct access to payment rails, some just because working with partner banks was so difficult... every marketing message has to get approved through some convoluted system and each new ad takes weeks to get approved.
The combination is finally reopening the door to new bank formation... we're going to see a lot of new banks in the coming years, the door is open.
BREAKING: US approves Erebor, a new bank from
@PalmerLuckey and
@JTLonsdale
This is the fastest conditional approval for a depository institution de novo application in 25 years.