把握银行牌照机遇：对金融科技企业与银行的影响

Implications for fintechs andbanks CONTENTS Introduction 1. The allure of the bank charter and the 2025 application surge5 2. Which fintechs should pursue charters?12 FOCUS POINT 1: 10 tips for successful charter pursuits15FOCUS POINT 2: Apply versus buy20FOCUS POINT 3: Valuation implications of a charter24 3. Implications for the future of banking25 4. Call to action31 End notes 33 Glossary 34 INTRODUCTION 2025 has become the year of the bank charter inthe US, with a surge in bank licensing activity fromfintechs and non-traditional applicants. Since January,20 filings for de novo charters, bank acquisitions, orconversions have been submitted by these players,representing an all-time high.1This may only be theleading edge of a broader wave, givenexpectationsof more filings in thepipeline. many fintechs, the right approach will be to forgo acharter altogether and continue operating throughbanking-as-a-service (BaaS) arrangements withsponsor banks. This proven model remains highlyrelevant and benefits from more favorable regulatorytreatment under the current administration. Theoptimal path depends on a fintech’s strategy, maturity,financials, and likelihood ofapproval. Ultimately, this next wave of bank charters mayexert a significant influence on the future of financialservices. Out of the many fintech charters expectedto be approved, the broader industry impact will likelybe concentrated in a few scaled fintechs that pursuefull-service charters and follow SoFi’s lead in reachingthe ranks of the top 50 banks by assets. However,charters will also be strategically important to smallerfintechs or those pursuing more targeted strategieswith limited-purpose banks. On the whole, the charterwave may further boost fintechs’ momentum in takingshare from incumbents by improving economics andremoving friction from the customerexperience. This presents a seeming paradox: Why wouldfintechs — known for their nimble, innovative go-to-market approach — willingly subject themselves tothe greater regulatory oversight that comes with abank charter? THE REASONS ARE THREEFOLD •Leading fintechs are reaching new levels ofscale and maturity, allowing them to reap greaterstrategic and financial benefits from a charter tooffset the accompanyinginvestments. •New leaders at supervisory agencies in thecurrent administration have shifted regulatorypriorities, leading to greater receptivity to bankcharters from non-traditional applicants. Thiscreates a timebound window to act withurgency. The fintech charter trend will have implicationsacross the broader financial services ecosystem,with clear calls to action for fintechs, incumbents,andregulators: •Some fintechs harbor continued concerns overthe long-term risks that come with relying ona sponsor bankto access banking and paymentsrails, and the corresponding lack of control overtheir owndestiny. •Fintechsface a narrow window to evaluate theirbanking strategy and the strategic fit of a charterto ensure sufficient time to develop, apply for, andreceive regulatory input on a charter during thecurrent administration; future administrations maynot prove to be as amenable to newcharters. But the decision to pursue a charter is not one-size-fits-all. It is a significant undertaking that requiresa thoughtful approach, along with a significantinvestment of time, effort, and capital, all with anuncertain probability of success. There are many typesof charters to consider in addition to the decision ofwhether to apply de novo or buy an existing bank. For •Incumbent bankswill face increased competitivepressures from fintechs. Defending against furtherencroachment requires a more customer-first anddigital-centric orientation for product innovationas well as a comprehensive strategy for fintechM&A andpartnerships. In Section 3, we share our hypotheses about howthis wave of charters will alter the future competitivelandscape, before closing in Section 4 with a call toaction for different stakeholders in theecosystem. •Policymakersshould consider whether to updatebank charter policy to reflect the continuingevolution of banking. The key will be to ensureclear and flexible frameworks that promoteinnovation and competition while maintaininga level playing field and upholding principles ofsafety andsoundness. This report is informed by expert insight, secondaryresearch, and analysis from Oliver Wyman and QEDInvestors, as well as conversations with over a dozenC-suite executives at leading fintechs. Anonymousquotes from these conversations are includedthroughout thisreport. This report is organized into four sections. In Section 1,we level-set on the appeal of the bank charter and thedrivers behind this year’s uptick in charter pursuits.In Section 2, we assess which fintech attributes makecharters more valuable and explore the economictrade-offs that come with bankstatus. THE ALLURE OF THE BANKCHARTER AND THE 2025APPLICATION SURGE What is the role of a bank charter? Given theimp