De Novo Bank Formation

On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors of the Federal Reserve System (“FRB”) (the OCC, FRB and FDIC are collectively, the “Federal Banking Agencies”) issued revisions to the Interagency Biographical and Financial Report (the “Report”).

In general, individual directors, officers, or an individual or group of shareholders acting in concert that will own or control 10 percent (10%) or more of a bank must file the Report in connection with the following: (i) applications to establish a de novo bank, (ii) notices for a change in control, (iii) Section 914 applications for new executive officers and directors, and (iv) applications for new executive officers and directors following a change in control.

Continue Reading Bringing a Level of Clarity to the Interagency Biographical and Financial Report

According to the Federal Deposit Insurance Corporation (“FDIC”), from 2000 to 2008 there were 1,042 de novo community banks newly chartered in the United States.  From 2011-2017, the FDIC received only 30 de novo applications for deposit insurance.  Of those 30 applications received, six have been approved, 10 withdrawn and 14 remain outstanding.  At year end 2017, the number of U.S. banks fell below 5,700 – a number the industry hasn’t seen since the 19th century.  Recently, the FDIC indicated that it has warmed to the idea of accepting de novo bank applications. Now may be the time for interested investors to assess the possibility of entering the community bank industry.

Continue Reading Phoenix Rising: De Novo Bank Formation?

On October 27, 2017, the Office of the Comptroller of the Currency (OCC) issued a full-service national bank charter since the financial crisis to Winter Park National Bank.  Winter Park National Bank is the first de novo national bank and first de novo approved for federal deposit insurance in Florida since the financial crisis.

Provided below are some takeaways from Winter Park National Bank’s application and approval.

De Novo Application Filed:  December 5, 2016
OCC Preliminary Conditional Preapproval:  April 18, 2017
FDIC – Deposit Insurance Approval:  June 28th, 2017
OCC – Charter Approval:  October 27, 2017
Market/State:  Orange and Seminole County, Florida
Holding Company:  None
Products & Service:  Full-service (no trust powers)
Initial Capitalization:  $30MM
Target Customers:  Small to medium-sized businesses
Banking Experience – Management:  2/3 of management has significant banking experience
Banking Experience – Directors:  100% of board has banking experience
Stock Option Plan:  Yes

To see the OCC’s Press Release, click here.