The New BANK Act directs the Comptroller of the Currency, the National Credit Union Administration Board, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation to publish annual reports that enumerate charter and related applications, processing times, and common reasons for denial or withdrawal. It also requires a joint, state-by-state report on State depository institution and State credit union charter applications prepared in consultation with state regulators.
Those reports create a recurring public dataset on how long new-bank and related approvals take, how often applications are successful or withdrawn, and the routine stumbling blocks applicants face. For applicants, counsel, regulators, and investors the bill substitutes transparent benchmarks for opaque anecdote—but it raises practical questions about data definitions, confidentiality, and administrative cost that the text does not fully resolve.
At a Glance
What It Does
The bill requires agencies to publish annual reports listing application counts and dispositions (e.g., approved, denied, withdrawn, mooted, returned), average and median processing times, and common reasons for adverse outcomes. It adds a joint report with state-level breakdowns for state-charter applications.
Who It Affects
National banks, Federal savings associations, Federal credit unions, depository institution holding companies, applicants for FDIC insurance, state-chartered banks and credit unions, and their legal and compliance advisers. State banking and credit union regulators also must coordinate for the joint report.
Why It Matters
The measure creates standardized, public performance metrics that enable benchmarking, oversight, and data-driven decisions about charter choice and timing; at the same time it introduces disclosure and data-workload trade-offs that can alter behavior by applicants and regulators.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The bill instructs four federal agencies (the OCC, NCUA, Fed Board, and FDIC) to publish yearly reports covering different kinds of applications tied to bank formation and corporate structure. Each agency’s report must move beyond simple counts to include measures of processing speed—mean and median times for milestones such as preliminary and final approvals—and a qualitative accounting of frequent reasons applications fail or are withdrawn.
For Federal credit unions the NCUA report also requires tracking of an intermediate step the bill calls a “proof of concept.”
For state-charter activity the bill requires a joint report prepared by the Fed, the FDIC, and the NCUA in consultation with state regulators that shows counts and timing broken out for each State (as defined to include territories and D.C.). The bill supplies statutory definitions for ‘‘State,’’ ‘‘State bank,’’ ‘‘State savings association,’’ and ‘‘State depository institution,’’ which governs the scope of the joint dataset.
The reporting categories across agencies include several dispositions—approved (preliminary and final where relevant), denied, withdrawn, expired, mooted, and returned—so readers can see how many filings never reach a substantive decision.Operationally the bill is a disclosure mandate, not an appropriations or process-reform statute. It does not prescribe submission formats, require publication of applicant identities, or create new approval deadlines.
That means agencies will have to build or adapt data systems, agree on common definitions (for example, what constitutes ‘‘preliminary approval’’ or when a file is ‘‘returned’’), and decide how to present cause-of-denial information without violating confidentiality rules. The bill also leaves the frequency at “annual” but does not set a calendar date or a start year for the first report.The predictable consequence is better public benchmarking: prospective charters and investors gain a clearer view of expected timelines and common pitfalls; policymakers gain oversight tools to spot outliers and friction points.
But the requirement also encourages agencies to codify internal labels and to weigh confidentiality against transparency—choices that will matter to small applicants and to states competing for charters.
The Five Things You Need to Know
The Comptroller of the Currency must report counts and dispositions for national bank and Federal savings association charter applications, including preliminary approvals and final approvals.
The NCUA report uniquely requires tracking of 'proofs of concept' for Federal credit union applications and the mean and median times to establish them, in addition to final approvals and denials.
The Board of Governors must publish counts and average processing times for top-tier depository institution holding company applications and list common reasons for denial or withdrawal.
The FDIC must publish counts, mean and median approval times, and common denial or withdrawal reasons for applications for Federal deposit insurance.
A joint report by the Fed, FDIC, and NCUA must show State depository institution and State credit union charter application counts and approval times with separate line-items for each State (including D.C. and territories), and the bill defines key State-charter terms.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Sets the Act’s short names: the 'New BANK Act of 2025' and the 'New Bank Application Numbers Knowledge Act of 2025.' This is purely stylistic but signals the bill's transparency purpose and will be how future references cite it.
OCC annual report on national bank and Federal savings association charters
Directs the Comptroller of the Currency to publish an annual report that enumerates applications by disposition (received, preliminarily approved, finally approved, denied, withdrawn, expired, mooted, or returned) and to provide mean and median times to preliminary and final approval, plus common reasons for adverse outcomes. Practically, the OCC must capture timestamped milestones in its processing workflow and summarize qualitative denial rationales without the bill specifying how much narrative to include or whether to name applicants.
NCUA annual report on Federal credit union charters and proofs of concept
Requires the NCUA Board to report counts of Federal credit union charter applications and an intermediate metric the bill calls 'proofs of concept'—including counts, mean and median times to establish proof of concept, final approval timing, and frequent denial or withdrawal reasons. The 'proof of concept' requirement stands out: it asks an agency to make public an internal staging point that could reveal procedural bottlenecks specific to credit union formation.
Federal Reserve annual report on depository institution holding company applications
Compels the Board of Governors to publish counts and mean/median approval times for top-tier depository institution holding company applications and to list common denial or withdrawal causes. The provision focuses on the structural gatekeeping function the Fed performs for holding company status, making that supervisory output visible for the first time in a standardized, recurring way.
FDIC annual report on deposit insurance applications
Requires the FDIC to report the number and dispositions of deposit insurance applications, average and median approval times, and common reasons for denial or withdrawal. Because deposit insurance is a binary gate to federally-backed deposit-taking, public metrics here could influence market perceptions of perceived supervisory risk attached to certain charters or business models.
Joint state-charter report and definitions
Obligates the Fed, FDIC, and NCUA to produce a joint, state-by-state annual report—prepared in consultation with state regulators—showing counts, mean and median approval times, and common denial/withdrawal reasons for State depository institution and State credit union charter applications. The section also defines 'State,' 'State bank,' 'State depository institution,' and 'State savings association' to fix the population covered. The practical implication is a mandate for federal–state coordination and standardized state-level performance indicators.
This bill is one of many.
Codify tracks hundreds of bills on Finance across all five countries.
Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Prospective bank and credit union founders — gain predictable benchmarks for timing and common failure points, helping structure launch schedules and capital planning.
- Investors and potential acquirers — get data to assess regulatory friction and time-to-market risk when valuing de novo charters or holding-company transactions.
- Researchers, journalists, and policymakers — receive standardized, comparable data for oversight, academic study, and identification of jurisdictional outliers.
- State regulators — obtain comparative data to justify policy changes or to market their regulatory environment to prospective charters.
Who Bears the Cost
- Federal agencies (OCC, NCUA, Fed, FDIC) — must allocate staff and IT resources to collect, reconcile, and publish new datasets and to consult with states for the joint report.
- Applicants (especially small de novos) — face reputational risk if their applications appear in public tallies of withdrawals or denials, and may be dissuaded from filing for fear of exposure.
- State banking and credit union regulators — incur coordination costs and may need to standardize data reporting, which could strain smaller state agencies.
- Agencies and states — bear legal and operational costs to redact confidential supervisory information and to defend any disclosure decisions when commercial-sensitivity claims arise.
Key Issues
The Core Tension
The central dilemma is between public accountability—using standardized metrics to demystify charter and insurance approvals—and the need to protect confidential supervisory information and applicant privacy; achieving meaningful transparency requires data definitions and redaction rules that the bill does not provide, and those design choices will materially affect both the utility of the reports and the behavior of applicants and regulators.
The bill is narrowly focused on disclosure mechanics but leaves critical design choices to the agencies. It does not specify whether the reports must include applicant identities or what level of granularity is required for the "common reasons" narrative, creating a tension between transparency and confidentiality.
Agencies will need to adopt common definitions for dispositions and time-zero events (when a filing is 'received' or when 'preliminary approval' occurs) to make cross-agency and state comparisons meaningful; absent uniform definitions, the promised benchmarking risks producing apples-to-oranges comparisons.
Operational and behavioral side effects are likely. Public timing metrics can incentivize regulators to prioritize speed over thoroughness or encourage applicants to shop for the jurisdiction that reports the fastest numbers rather than the best supervisory fit.
Smaller applicants may be disproportionately harmed if withdrawn or denied filings are publicly tallied without context. Finally, the statute contains no funding or enforcement mechanism for producing the reports, and it does not set publication deadlines or minimum data standards—details that will drive whether the reports are operationally useful or merely symbolic.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.