Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—OCC conditionally approves Mission Lane de novo subprime credit card bank, (Sep 28, 2026)

By A. Bryan Gerepka

Approximately 95% of Mission Lane’s customers fall within the VantageScore range of 550 to 700, which the application identifies as the Bank’s target market.

The Office of the Comptroller of the Currency (OCC) has granted preliminary conditional approval to Mission Lane Bank to establish a national credit card bank under the Competitive Equality in Banking Act (CEBA), allowing it to fund and issue its own credit cards. Before the approval, Mission Lane teamed up with various unaffiliated banks to sponsor its credit card program.

The new bank, called Mission Lane Bank, National Association (Mission Lane NA), will be a special-purpose credit card bank headquartered in Richmond, Virginia. It will not have any branches and will not exercise any trust powers, the OCC stated. The bank will fund its credit card lending products through large deposits and other funding sources consistent with the CEBA, the OCC added.

“Our approval is based on Mission Lane’s representations, submissions, and information available to the OCC as of this date,” the agency stated, adding that “the OCC may modify, suspend, or rescind this approval if a material change in the information on which the OCC relied occurs before the date of the transaction.”

The OCC also granted Mission Lane NA’s request for residency waivers for its five board members. The preliminary conditional approval also requires the bank to apply for stock in a Federal Reserve Bank in accordance with 12 USC 2222 and to obtain deposit insurance from the Federal Deposit Insurance Corporation (FDIC), the OCC added.

Background. On April 17, 2026, the OCC received an application from Mission Lane NA’s organizers to establish an insured de novo national bank, the latest fintech company to seek a national bank charter for specialized limited banking operations. Mission Lane NA will focus on subprime credit card lending, primarily to consumers with low credit scores. Approximately 95% of Mission Lane NA’s customers have a VantageScore that ranges from 550 to 700, the application noted.

During the first three years of operations, the parent company will transition its existing credit card program to Mission Lane NA, which will become the sole issuer of Mission Lane-branded credit cards. In addition, the company plans to offer diversified credit products to its customers, including optional credit protection, the application noted.

Conditions for Final Approval. The OCC outlined the following requirements for final approval of the application.

• At least $35 million of bank capital, with a minimum Tier 1 leverage ratio of 11% for three years. The means by which the capital is raised must not deviate from that described in the application without prior written OCC notification, the agency stated. This approval will expire if the capital is not raised within 12 months or if the Bank is not opened for business within 18 months of the preliminary conditional approval date. expires.

• The Bank must limit its operations to those of a national CEBA credit card bank, as specifically stated in the Business Plan. The Bank must meet the requirements of section 2(c)(2)(F) of the Bank Holding Company Act.

• The Bank shall: (i) give the regional OCC office at least sixty (60) days prior written notice of its intent to significantly deviate or change from its Business Plan or operations; and (ii) obtain the OCC’s written determination of no objection before the Bank engages in any significant deviation or change from its Business Plan or operations. The OCC may impose additional conditions it deems appropriate. This condition shall remain in effect throughout the Bank’s in-organization period and during the Bank’s first three years of operation.

• The Bank must submit information and receive OCC approval before the appointment of any individual to the position of “senior executive officer,” as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of directors.

• The Bank must maintain policies on compliance, risk management, and security, including an independent audit and security testing. It must submit detailed descriptions of its information systems, including vendor management, security measures, and contingency plans. The Reviewer must confirm that the security measures, including the firewall, have been satisfactorily implemented and tested.

• The Bank must have adequate fidelity bond coverage and a security program aligned with federal guidelines.

• The Bank can begin organizing after submitting Articles of Association and Organization Certificate

• The Bank must submit a letter to the Chartering, Organization and Structure staff at least 60 days before the Bank is scheduled to open, notifying the OCC that all conditions and requirements necessary to receive a national bank charter have been met and that the Bank is fully operationally ready to conduct business. The Bank must request a preopening examination and provide the anticipated opening date.

• The Bank must engage an independent, external auditor to perform an audit, consistent with generally accepted auditing standards of sufficient scope to enable the auditor to render an opinion on the financial statements of the Bank taken as a whole. The Bank must engage an external auditor for annual audits for at least three years after it begins operations.

• The directors of the Bank must own qualifying shares in conformance with 12 USC 72 and 12 CFR 7.2005.

Residency Waiver and Key Personnel. The OCC approved a waiver of residency requirements for all five board members. The Bank must obtain prior OCC approval for any new key officers or directors before appointment.

Companies: Mission Lane Bank, NA

RegulatoryActivity: BankingOperations CreditDebitGiftCards FinancialIntermediaries FinTech