Summary
Erebor Bank received OCC preliminary conditional approval on October 15, 2025, with conditions including: 12% minimum Tier 1 leverage ratio (first 3 years), OCC non-objection for any significant business plan deviation, and pre-approval of senior executives. The bank opened February 8, 2026 with $635M in capital. Senator Elizabeth Warren launched an investigation into whether political connections influenced the approval — the application was submitted by Adam Cohen, who became OCC Chief Counsel two months later.
Key Points
- OCC conditions: 12% minimum Tier 1 leverage ratio (3 years); OCC non-objection for business plan changes; pre-approval of senior executives
- Pre-opening requirements: independent external auditor, GAAP financial statements, BSA/AML/OFAC program, security program, IT architecture review
- Opened Feb 8, 2026 with $635M capital — first new national bank chartered under Trump administration
- OCC Comptroller Jonathan Gould: "committed to a dynamic and diverse federal banking system"
- Political controversy: application submitted by Skadden partner Adam Cohen; Cohen named OCC Chief Counsel July 2025 (2 months later)
- Fundraising memo reportedly said "political network will get this done" and cited "unique connectivity to banking regulators"
- Senator Warren (Feb 2026): requested all communications between Erebor and White House/OCC/FDIC
- Bank serves crypto, AI, defense, and manufacturing sectors — "a farmers' bank for tech" (Luckey)
- Palmer Luckey serves on board but not in operating role