Chartering a New Path Toward Banking: How the Rise of Novel Charters is Reshaping the Regulatory Perimeter for Fintechs, Payments Companies, and Others

Trends converging in recent months have the potential to reshape the operating environment for fintechs, digital asset and payments companies, and other nonbank financial firms in the United States, in important ways. These include: persistent and growing consumer demand for new ways to access financial services, especially through digital channels; the continued maturation and integration of fintech business models into traditional banking and payments ecosystems; and congressional efforts to clarify rules of the road for digital assets and stablecoins. But one trend stands out for its potential to effect lasting changes to the sector: the rise of “novel” charter types that allow nonbank firms to expand their products and services, and access many of the privileges associated with a banki