FDIC Announces New Deposit Insurance Application Process

On August 10, 2026, the Federal Deposit Insurance Corporation (FDIC) announced a new process to review applications by prospective new banks for deposit insurance for all applications received after August 15, 2026. According to the FDIC, the two-phase process is intended to encourage new bank formation, accelerate the speed of the review process, and improve the efficiency of the application process. In an accompanying press release, FDIC Chairman Travis Hill said, “[i]mproving the de novo process and encouraging more new bank formation has been a key priority for the FDIC . . . Today’s action is one of several steps the FDIC has been working on in furtherance of this goal.”

Key Takeaways

• Increased efficiency and clarity. The new process delineates the information the FDIC deems most relevant for each phase, allowing applicants to prioritize resources.
• During the first phase, the FDIC expects, for example, a comprehensive business plan, accompanying financial projections, complete ownership and organizational structure (including foreign ownership), and a description of the planned capital raise.
• If contingent authorization is granted, second-phase activities involve capital raising, staffing, infrastructure development, and other start-up activities.
• Interagency coordination. The new process generally aligns with the two-phase chartering process adopted by the Office of the Comptroller of the Currency (OCC)—a welcome sign of interagency coordination for de novo applicants.
• The FDIC expects that, with some exceptions, applicants will generally be able to file applications concurrently with both the FDIC and the chartering authority (which could be the OCC or a state chartering authority). The FDIC has also noted that it will coordinate with the chartering authority throughout the application process to promote efficiency, avoid duplication, and ensure timely action.
• Informal prefiling 60-day feedback period preserved.  The new process cites prior FDIC guidance from 2018, preserving an additional avenue for applicants to seek the FDIC’s informal feedback (to be provided within 60 days of the draft application) prior to the formal application filing.

Two-Phase Approach

Under the new process, entitled “FDIC’s Two-Phase Approach for Processing Deposit Insurance Applications,” the FDIC will process applications in two stages where relevant requirements are met: (i) a contingent authorization phase within 120 days of receiving the application; and (ii) an organizational phase, which occurs within the subsequent 12 months following the contingent authorization phase. The guidance also references 2018 guidance from the FDIC establishing a process for prospective organizers to request FDIC review of a draft deposit insurance proposal, with feedback to organizers delivered within 60 days of receipt. This pre-application review remains available to applicants and distinct from the post-application timelines established by the new process.

Contingent Authorization Phase

At the initial stage, the FDIC will, if warranted, grant applicants contingent authorization, subject to receipt of additional information and satisfaction of pre-opening conditions. The FDIC expects to receive information including a comprehensive business plan with financial projections, an ownership/organizational chart, details on any planned capital raise, and the identities and Interagency Biographical and Financial Reports for proposed officers, directors, and principal shareholders.

The timeline for achieving contingent authorization is detailed below, with days measured as the number of calendar days following the FDIC’s receipt of an applicant’s submission:

1. Within 30 days: The FDIC will communicate with organizers regarding the application’s completeness and, if necessary, request additional information.
2. Within 90 days: The FDIC will meet with organizers to conduct initial management and topical interviews, in coordination with the chartering authority to the extent possible.
3. Within 120 days: The FDIC will issue a contingent authorization letter, if warranted, detailing pre-opening conditions.

Organizational Phase

Within 12 months of contingent authorization, applicants will need to finalize and submit a detailed list of remaining materials, including any outstanding officer/director identifications, employment agreements, final capital raise details, organizational documents, key vendor contracts, and final risk management and compliance policies.

After review of these supplemental materials and any follow-up investigations, the FDIC will coordinate a pre-opening meeting with the chartering authority, where possible. The FDIC will obtain the applicant’s written agreement to all conditions in the deposit insurance order and will issue a transmittal letter communicating the final disposition. Within six months of approval, and at least 30 days before the bank’s proposed opening, the FDIC will coordinate a pre-opening examination with the chartering authority, when possible, and issue the deposit insurance certificate.

Our View

The FDIC's new process could significantly accelerate deposit insurance approvals, consistent with a recently enacted law directing the federal banking agencies to streamline de novo applications. Definitive timelines and the two-step process will provide organizers with more clarity before committing to activities such as hiring employees or raising capital. Applicants should not assume, however, that the expedited timeline signals a lower bar for approval.

Applicants seeking to benefit from the new process should ensure they have: identified key employees and sources of capital; drafted a comprehensive business plan detailing the products and services that will be offered, the market that the applicant will serve, and how operationally the activities will be performed; and developed financial projections based on defensible assumptions that demonstrate a path to profitability. Non-traditional applicants in particular should seek to demonstrate adequate risk controls and leadership with prior banking experience.

Applicants should also take advantage of the opportunity to engage with the FDIC and their chartering authority in pre-filing meetings. The FDIC states in its guidance that these meetings promote “open communication between the applicant and the FDIC regarding the specifics of the potential application, regulatory expectations, and the application process.”

The 120-day clock associated with the new application process rewards preparation, not haste. Applicants who invest the time up front to assemble a complete submission with a strong business plan, identified leadership, and a credible capital strategy will be best positioned to take advantage of the FDIC’s streamlined process.