A special purpose national bank (SPNB) is a national bank whose charter restricts it to a narrow line of business. It is chartered and supervised by the Office of the Comptroller of the Currency, the federal agency that charters national banks in the United States, but it does not offer the full range of deposit-taking, lending and payment services associated with a commercial bank. Long-established examples are national trust banks and credit card banks.
The term gained wide attention when the OCC proposed a version for financial technology companies, often called the fintech charter. That proposal would have allowed a company that lends or handles payments, but takes no deposits, to operate nationwide under one federal license. It became the subject of a long dispute between federal and state regulators over who should supervise non-bank financial firms.
Legal basis
The National Bank Act gives the OCC authority to charter associations to carry on the business of banking. The agency's chartering regulation provides that a special purpose bank conducting activities other than the operations of a trust company and related activities (wording that replaced a narrower reference to fiduciary activities on 1 April 2026, confirming that national trust banks may also carry on non-fiduciary business such as custody) must engage in at least one of three core banking functions: receiving deposits, paying checks or lending money. The OCC has read this to mean that a national bank need not take deposits, provided it lends or pays checks, and it has treated electronic payments as the modern equivalent of paying checks.
Trust banks rest on a separate footing. Federal law expressly allows the OCC to charter a national bank whose operations are limited to those of a trust company and related activities.
Established types
- National trust banks. These act as trustee, custodian and fiduciary and generally do not make commercial loans or take ordinary deposits. Several digital asset custody and stablecoin firms have sought this form of charter.
- Credit card banks. These are limited to issuing credit cards and related lending, and were historically used by retailers and card companies.
- Bankers' banks and community development banks. These serve other banks or a defined public purpose.
The fintech charter proposal
In December 2016 the OCC announced that it would consider applications from fintech companies for special purpose national bank charters, and in July 2018 it said it would begin accepting them. An approved company would be subject to capital, liquidity and risk management requirements set case by case, to examination by the OCC and to a financial inclusion commitment. Because it would take no deposits, it would not need insurance from the Federal Deposit Insurance Corporation.
The attraction for applicants was federal preemption. A national bank is largely exempt from state licensing, so a lender would not need a license in each state and a payments company would not need a state-by-state money transmitter license. A national bank may also charge interest at the rate allowed in its home state to borrowers across the country.
Litigation and opposition
State regulators objected that the OCC had no authority to charter a bank that does not take deposits and that the charter would weaken state consumer protection. The Conference of State Bank Supervisors and the New York Department of Financial Services each sued. The supervisors' cases were dismissed as premature because no charter had been issued. In the New York case a federal district court ruled in 2019 that the National Bank Act requires a national bank to take deposits, but in 2021 the federal appeals court for the Second Circuit set that ruling aside, holding that the claim was not ready for decision without an actual charter, and did not rule on the underlying question.
No company is known to have received a charter under the 2018 fintech policy. The legal uncertainty, the prospect of further lawsuits and the unresolved question of payment system access discouraged applications.
Access to payment systems and deposit insurance
A charter alone does not connect a firm to the payment system. To settle payments directly a bank needs a Federal Reserve master account, which is granted by the regional Reserve Banks under guidelines that apply closer scrutiny to institutions without federal deposit insurance. National banks must also become members of the Federal Reserve System. The treatment of uninsured special purpose banks under these rules has been a practical obstacle and a matter of continuing policy debate.
Alternatives and later developments
Fintech companies seeking bank powers have used other routes. Some have obtained a full-service national bank charter with deposit insurance, either by applying for a new bank or by buying an existing one. Others have applied for an industrial loan company charter from states such as Utah, or for state special purpose charters such as Wyoming's special purpose depository institution. Most continue to rely on a sponsor bank together with state licenses.
Interest in the national trust bank form revived with the growth of digital assets. The OCC granted its first such charters to crypto custody firms in 2021, and after the GENIUS Act of 2025 gave the OCC a role in approving federally licensed non-bank stablecoin issuers, a number of digital asset and payments firms filed applications for national trust charters, and from December 2025 the OCC gave conditional approval to several of them. State regulators and banking trade groups have continued to question how far such charters may extend into payments.