Upstart Holdings, the fintech lender headquartered at 220 Park Rd. in Burlingame, won conditional approval from the Office of the Comptroller of the Currency on Thursday, July 23, to establish a nationally chartered bank built around artificial intelligence underwriting.
The approval puts Upstart one step closer to operating Upstart Bank, N.A., a branchless institution that would originate consumer loans and accept FDIC-insured deposits across all 50 states. The company filed its charter application in March 2026, and the OCC completed its review in roughly four and a half months.
"Upstart Bank will allow us to lower the cost of lending and bring our full product offering to all 50 states, advancing our mission to radically reduce the cost and complexity of credit for all Americans," CEO Paul Gu said in the company's July 23 announcement.
Gu, a co-founder who succeeded fellow co-founder Dave Girouard as CEO in 2026, said the conditional approval is "an important milestone" while work continues with federal regulators on remaining steps.
What still needs to happen
Upstart Bank cannot open until it secures FDIC deposit insurance, Federal Reserve approval to become a bank holding company, and meets OCC conditions for capitalization, governance, and operational readiness. The company filed applications with the FDIC and the Federal Reserve in March 2026; both remain pending.
Annie Delgado, Upstart's chief risk officer since 2015, is the proposed CEO of the new bank. In the company's press release, Delgado said the charter process challenged the company extensively and called that scrutiny appropriate for any institution seeking the privilege of becoming a national bank.
Scale and local footprint
Upstart, founded in 2012, says it has originated more than $57 billion in loans and served over 4 million customers through a platform that connects borrowers with more than 100 banks and credit unions. The company says more than 90% of its loans are fully automated with no human intervention.
The proposed bank would be incorporated in Delaware but would not replace Upstart's existing lending partnerships. The company said banks, credit unions, and institutional investors are expected to continue purchasing the vast majority of loans originated on its platform.
Upstart says it currently operates under 248 state licenses and works with more than 100 origination partners and four federal regulators. A national charter would consolidate that patchwork into a single federal framework.
Regulatory backdrop
The OCC's approval came the same day the agency rejected payments company Wise's application for a national trust bank charter, according to CU Today. OCC Comptroller Jonathan Gould has accelerated consideration of fintech charter applications, but the agency is not approving every applicant.
Separately, a coalition of 21 state attorneys general, including California AG Rob Bonta, sent a letter to the OCC, FDIC, and Federal Reserve on July 15 urging caution in granting bank charters to fintech companies. The letter raised concerns about fintechs using charters to bypass state consumer protections on high-cost lending. It was not directed specifically at Upstart.
What's next
No opening date has been announced. Delgado said the company's next task is to execute its business plan and demonstrate to regulators that the institution is ready to open. FDIC deposit insurance and Federal Reserve approval remain the final hurdles before Upstart Bank, N.A. can accept its first customer.
