Finance Law and Banking Law

IPO readiness extends far beyond technical accounting, requiring companies to operate like public entities months before filing. Finance leaders must establish robust financial architecture, align stakeholders across departments, and address historical accounting issues that can derail timelines when exposed to public-company scrutiny.

On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) (together, the Agencies) issued a final rule (the Final Rule) adopting a regulatory definition for the term “unsafe or unsound practice” and revising the supervisory framework for issuing matters requiring attention (MRAs), as part of the Agencies’ more comprehensive efforts to focus supervisory and institution attention on material financial risks. On the same date, the OCC issued a notice of proposed rulemaking (the MRA Rule) to establish regulatory standards for the types of legal violations that can support an MRA.

Interest in national trust bank charters has surged in recent years as companies seek to offer fiduciary, custody, and related trust services under federal supervision. This comprehensive guide examines the OCC's application process, capital requirements, and key regulatory considerations for institutions pursuing a national trust charter, from prefiling consultations through final approval and opening.