First Trump-Era Bank Charter Signals Shift in Fintech Oversight as Crypto Card Service Collapses

First Trump-Era Bank Charter Signals Shift in Fintech Oversight as Crypto Card Service Collapses

The Office of the Comptroller of the Currency approved its first de novo bank charter under President Trump's second term, granting Erebor—a bank targeting AI, crypto, and defense startups—the green light to open for business on February 8th, just days after a controversial crypto card service abruptly shut down citing network termination.

The timing underscores a broader recalibration in how financial regulators are approaching fintech infrastructure, particularly services operating in regulatory gray zones. For CFOs navigating vendor risk and banking relationships, the contrast between Erebor's approval and UnCash's collapse offers a preview of which business models will survive heightened scrutiny.

UnCash, a self-described "no KYC" crypto card service, announced its shutdown on February 14th—one day after being featured in a Fintech Business Weekly analysis of compliance gaps in crypto card programs. The company blamed Mastercard for what it called a "clean, corporate guillotine," saying the abrupt termination by its card issuers constituted "a death sentence" for a service where 90% of cards ran on Mastercard's network. The company said it would refund users, who can withdraw funds to external crypto wallets.

Erebor, by contrast, represents the establishment path. The bank, whose name references Tolkien's fictional mountain fortress, initially submitted its charter application to the OCC in June 2025. Its business model focuses on serving high-net-worth individuals, businesses and startups in AI, manufacturing, defense, and crypto industries, as well as payment service providers, investment funds, and trading firms.

The bank's positioning suggests an attempt to fill gaps left by Silicon Valley Bank's 2023 failure, which left many venture-backed companies scrambling for banking relationships. Erebor has connections to Palmer Luckey, founder of defense contractor Anduril, signaling its focus on sectors aligned with current administration priorities.

The divergent fates of UnCash and Erebor illustrate a pattern finance leaders should watch: regulators and payment networks appear increasingly willing to cut off services operating without clear compliance frameworks, while simultaneously fast-tracking traditional bank charters for well-connected applicants targeting politically favored industries.

For corporate treasury teams, the lesson is straightforward. Banking-as-a-service arrangements and fintech partnerships that rely on regulatory ambiguity face growing termination risk, particularly when card networks decide to enforce compliance standards. Meanwhile, the OCC's willingness to approve new charters—after years of drought—may expand options for companies seeking direct banking relationships outside the traditional money-center banks.

The question for 2026 is whether this represents a genuine opening in bank charter approvals or merely a narrow window for politically connected applicants. Either way, the infrastructure supporting corporate finance operations is shifting, and CFOs relying on fintech intermediaries should be mapping their backup plans.