Buy now, pay later pioneer Affirm has become the latest fintech to apply for a U.S. banking charter. Filed in Nevada, the application is the most recent wave of filings prompted by a more favorable regulatory environment at both the state and federal levels.
Affirm was the second high-profile fintech to announce a state charter this month, following Checkout.com’s approval of its Georgia charter. They join fintech giants like PayPal, Ripple, and Circle, all of which have sought bank charters over the past year.
An Upturn in Applications
The surge is partly driven by the Trump administration’s relaxed regulatory stance, which has created a welcoming climate for fintechs pursuing banking charters. In a speech last month, Comptroller Jonathan Gould noted that the Office of the Comptroller of the Currency received 14 de novo charter applications in 2025—compared with an annual average of fewer than four from 2011 through 2024.
This regulatory approach has also influenced state-level frameworks. Because obtaining banking approval from the OCC can be challenging, several states have developed fintech-friendly banking structures designed to attract new entrants.
“Two types of banking models are those governed by national charters, which fall under the OCC’s purview, and those under the scrutiny of state banking authorities,” said Brian Riley, Co-Head of Payments at Javelin Strategy & Research. “Both charters may be insured by the FDIC. State chartered banks typically attract fintechs, non-traditional banks, and bank-as-a-service models. States like Nevada, Texas, and Utah tend to be more friendly to alternative models, and have high rate caps that fintechs can export to other states, thanks to the Marquette decision.”
New Access to Products
The 2020 Marquette decision, a Supreme Court ruling, allowed states to let banks export their state-authorized rates to borrowers in other states. This sparked a competition among states to offer incentives to financial entities while still permitting nationwide operations.
Beyond fostering a more favorable lending environment, state charters enhance a fintech’s credibility and simplify compliance with a patchwork of state laws. Affirm said the charter would help it expand access to unspecified “honest financial products.” The application closely followed a newly announced collaboration with Fiserv, aimed at expanding banks’ access to Affirm’s BNPL programs for debit card holders.
