How to Successfully Launch a Digital Bank in the U.S. Key Steps You Need to Know!

How to Successfully Register and Operate a Digital Bank in the United States

Registering a digital bank in the United States, especially amid the rapid development of financial technology FinTech, has become a focal point for many entrepreneurs and tech companies. With surging consumer demand for online financial services and the gradual transformation of traditional banking models, digital banks are entering an unprecedented era of opportunity. So, how can you successfully establish and operate a digital bank in the U.S.? Below are the essential steps and insights you need to know.

1. Understand the U.S. Financial Regulatory Framework

The U.S. financial regulatory system is complex, involving multiple federal and state-level agencies. To register a digital bank, you must first determine whether you will apply for a full bank charter or a Money Services Business MSB license. If your goal is to offer comprehensive banking services such as accepting deposits and issuing loans, a formal bank charter is required. However, if you plan to provide basic services like payments or money transfers, an MSB license may suffice.

According to an announcement by the Office of the Comptroller of the Currency OCC in 2025, the agency is actively promoting regulatory support for emerging FinTech firms and encouraging technically capable companies to apply for a Special Purpose National Bank SPNB Charter. This policy offers greater flexibility for setting up digital banks.

2. Choose the Right Type of Charter

There are three primary paths to launching a digital bank in the U.S.

1. State Charter

Apply with the financial regulatory authority of the relevant state. The process is relatively flexible, but cross-state operations require additional approvals.

2. National Bank Charter

Approved by the OCC, this allows nationwide operations. However, the review process is rigorous and often takes longer.

3. Special Purpose National Bank SPNB Charter

Designed specifically for FinTech firms, it enables focus on specific banking functions such as payments or lending.

Notable digital banks like Chime and Varo Bank have spent years pursuing federal charters. In particular, Varo Bank became the first fully digital bank approved by the OCC in 2025. Its experience highlights that building robust compliance systems is key to success.

3. Build a Solid Technological Infrastructure

Technology lies at the heart of any digital bank. You'll need to develop a secure, efficient, and scalable banking platform covering the following areas

Core Banking System

Customer Identity Verification and Anti-Money Laundering KYC/AML Systems

API Interfaces for Third-Party Integration

Cybersecurity Measures

Many startups opt to collaborate with established FinTech platforms such as Marqeta, Plaid, or Galileo to access card issuance and payment processing services, thereby reducing costs and risks associated with building systems from scratch.

4. Assemble a Professional Team and Develop a Business Plan

A successful digital bank requires a multidisciplinary team with expertise across finance, law, and technology. Your team should ideally include

Legal advisors well-versed in financial regulations

Executives with banking operations experience

Technically strong product developers

Equally important is a detailed business plan. It should clearly outline your business model, target customer base, revenue strategies, and your understanding of and approach to regulatory requirements. Additionally, you must prepare sufficient capital - typically, launching a digital bank requires several million dollars in initial investment.

5. Complete the Regulatory Approval Process

Once you’ve decided on your charter type and technical setup, you can begin submitting your application. This process can take anywhere from six months to two years. Key elements include

Submitting detailed corporate governance and compliance plans

Demonstrating adequate capitalization and risk management capabilities

Undergoing on-site inspections and interviews by regulators

It’s worth noting that both the OCC and the Federal Reserve have been actively promoting innovation lab initiatives to assist new FinTech entrants in navigating the regulatory landscape. For example, in 2025, North Carolina launched a FinTech sandbox, allowing companies to test their products and services within limited scopes - a promising development for new market entrants.

6. Seek Partnerships and Funding Channels

Given the high initial costs and long return horizon, securing strategic investors or partners is crucial. Consider bringing in venture capital funds, angel investors, or forming partnerships with traditional banks to leverage their existing licenses and infrastructure.

You might also explore collaborations with other FinTech platforms, such as offering embedded financial services within third-party applications to expand your user base.

Conclusion

Establishing a digital bank in the U.S. is no easy task. However, with a clear strategic vision, strong technological capabilities, and a deep understanding of the regulatory environment, there remains a real opportunity to stand out in this competitive market. Just as many FinTech firms have made breakthroughs in recent years under the dual drivers of regulatory reform and technological advancement, the next few years are expected to be a golden age for digital banking.

Seize the opportunity, plan ahead, and you could very well become the founder of the next successful digital bank.