This Week in Credit Risk: De Novo Banks, Faster FDIC Reviews, and CRA Comments
De novo bank applications are surging, the FDIC is speeding up its review of new banks, and comments on the proposed CRA revisions are due October 13.
De novo bank chartering is surging: the OCC has received 40 de novo applications in the last 18 months, compared with 48 from 2011 through 2024. The FDIC has also sped up its review of new banks, and comments on the proposed CRA revisions are due October 13.
What New Banks Mean for Your Loan Pipeline
The OCC has received 40 de novo applications in the last 18 months, compared with 48 total from 2011 through 2024. The FDIC also adopted a two-phase review of deposit insurance applications from new banks, aiming for a contingent authorization within 120 days.
The 40 include national trust bank charters, so not all are lending competitors, but full-service de novos will compete for loans and deposits in their markets. For existing community banks, the best response is a well-trained credit team that wins business on the strength of its underwriting, not just its pricing.
When Are CRA Proposal Comments Due?
The OCC and FDIC have proposed CRA revisions designed to refocus on meeting community credit needs while reducing unnecessary burden for community banks. The proposal was published in the Federal Register on August 12, and comments are due October 13, 2026.
If the proposal affects your institution, now is the time to review and respond.
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What is a de novo bank?
A de novo bank is a newly chartered bank. Full-service de novo banks add competition for loans and deposits in the markets they enter, though some new charters, such as national trust banks, do not lend or take retail deposits.
How fast can a new bank get FDIC deposit insurance approval?
Under the FDIC’s new two-phase process, it aims to grant a contingent authorization within 120 days of receiving an application from organizers that meet its requirements, then approval within the following 12 months once organizers supply the remaining information and complete key steps.
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Last updated August 26, 2026.