One Charter, Fifty States…

September 11, 2026
Nancy Kuenstner
One Charter, Fifty States - Atlantis International on the US national bank charter as an alternative to state-by-state licensing

One charter can replace state-by-state licensing patchwork.

For a fintech or financial institution planning entry into the U.S., few decisions carry longer term consequences than the choice of regulated vehicle. Simply applying for the U.S. charter or license with the ‘least onerous’ or ‘quickest’ approval processes is short-sighted. Ask the fintechs that cobble together a cumbersome network of Money Service Business licenses –one for each U.S. state—about the administrative burden of responding to 50 state regulators. Gaining an MSB license may be expeditious, but it is limiting. An MSB entity:

  • does not allow for foreign branching
  • is often an unacceptable counterparty for NGOs, government agencies and big banks. or
  • if an approved counterparty, requires enhanced due diligence

Look beyond the Fifty States…

The regulatory framework around certain regulated vehicles including the National Trust Bank charter recently changed, encouraging new applications, and easing entry. Earlier this year, the Office of the Comptroller of the Currency finalized amendments to its national bank chartering rule under 12 CFR Part 5, with the changes taking effect April 1, 2026. The amendments replaced a narrower reference to “fiduciary activities” with statutory language drawn directly from the National Bank Act. The practical effect is clarifying: national trust banks may engage in non-fiduciary custody and safekeeping activities alongside their traditional fiduciary services, resolving a confusion that earlier text had invited.

The data

The data: one national charter can replace the state-by-state licensing patchwork facing US market entrants

For fintechs and foreign institutions, the significance lies in the reaffirmation of the national charter itself. A single national charter can replace the state-by-state licensing patchwork that has long taxed the time and capital of new entrants. In its place: one uniform set of rules, national access, commercial economies of scale and cohesive federal supervision rather than fragmented oversight across dozens of jurisdictions.

None of this is without cost. A charter brings capital costs, full Bank Secrecy Act compliance, and potential constraints on affiliate activities. These are not obstacles so much as the terms of trade – the obligations that accompany the powers. The strategic question is whether the scope and certainty of a national vehicle justify those obligations for a given institution’s plan, and that is a question best answered before an application is drafted, not after.

In context

The direction of U.S. regulatory policy during 2026 has been toward clearer, more usable national charter pathways. For an institution that intends to operate across the U.S., the national charter deserves a fresh look. Atlantis International advises foreign banks and fintechs on selecting the appropriate chartering path – and stands with them from application, through approval, to opening the doors.

One uniform federal charter, national scale and cohesive federal supervision in place of fragmented state oversight

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