What Community Banks Can Learn About Speed From De Novo Banks

New de novo bank charters, which had been mostly dormant for over a decade, are picking back up with speed this year. So far in 2026, the OCC has had 22 charter filings, with 14 approved so far. At the same time, the FDIC rolled out a faster approval process which hopes to cut the wait for qualified applications to 120 days for initial approvals. Even with the approval pipeline beginning to reopen, establishing a bank charter from scratch still requires tens of millions in capital and months of regulatory review before taking anything to the market.

At ICBA LIVE 2026, Jorge Garcia, Linker Finance CEO, and Mike Olson, President and CEO of Bank of Brodhead, took the stage for a Learning Lab centered around how Mike was able to launch a new brand with the speed of a de novo, without having to file for a new charter. Here were some of the lessons learned.

One Charter, Two Cores

If you’ve had to update or add to the tech stack at a bank, it’s highly likely you’ve come across a piece of legacy technology that caused some friction. Something uniquely special to starting a de novo is getting a clean slate by default, no new charter, core, or other legacy obstacles to work around.

When launching Vault.Bank, Mike didn’t look to switch core providers. Instead, they stayed on the same setup that’d been powering the Bank of Brodhead for years. What did change was the addition of a second instance of that core, built specifically to power Vault.Bank, bringing that same clean-slate effect to their launch, without being subjected to the clean-slate timeline.

Typically, the path for a new digital brand usually requires a separate “sidecar” core or charter, often a multi-year build, but in this case, a new instance of the existing core was able to accomplish the same job without the added headache.

Decisions Not Made By A Committee

Digital problems can be stuck in the weeds of data for a long time before they’re fixed. The “fix” has to be one that’s able to work with lower-stakes, slower-moving applications.

It only hurts the case when disparate departments within the bank are measuring for just a small piece of the bigger puzzle. Marketing might be tracking impressions and clicks, whereas the funded accounts and average deposits per account may point to a different path.

In Vault.Bank’s early launch, their onboarding flow had three screens to go through. The new brand asking applications to agree to a compliance-heavy notice carried enough uncertainty that people started dropping off. When an internal team at the bank saw this coming across clearly in the data, they were able to fix it, without having to worry about a multi-week committee approval process slowing things down. The change showed quick results, with the flow changing within weeks.

This decision process worked quickly, and worked well, because it happened with accuracy and speed. The part of the process where a visitor becomes a customer was repaired, rather than leaning into an attempt to pay more to try and fill up the leaking funnel.

A Narrow Mission

Jack of all trades, master of none? A bank trying to serve everyone, everywhere is seldom able to actually serve any of them well, especially early on. The instinct to try and move fast on every front carries a whole separate list of risks.

A de novo is required to have a mission statement and financial projections before they can have their charter. A bank trying to launch without knowing who they will serve and how they’ll do that is unlikely to survive for long, making a narrow, focused scope a fundamental of launching.

When launched, Vault.Bank was meant for residents of Wisconsin only, a decision meant to control growth against the $400 million balance sheet. Their hook, high-yield savings, with checking, trust, and minor accounts, were available to layer on as the bank saw fit, rather than trying to launch each piece all at once.

They made a deliberate decision to define who they were, without an examiner having to require it from them.

Founding Decisions

For a de novo, fraud and compliance programs are a founding decision around which the bank is built. The stack is chosen based on what’s available and top of class now, by a group of people building the bank from the ground up.

An established bank is unlikely to get that same clean-cut decision point. The fraud methodology has been in place for years, usually an accumulation of multiple vendor’s point solutions. They’re rarely revisited unless a major event forces a change. It’s no surprise that for Mike, digital growth meant the likelihood of inheriting more risk.

What they did more closely resembled a founding decision. The fraud stack was designed intentionally, the way a de novo would have to be. Behavioral and device-based data now gives Vault.Bank the insights they need to keep fraud and losses down.

Speed, On Purpose

A de novo gets speed built into its founding by default. There’s a clean, new core, a freshly defined mission, and technology that’s chosen to work together, rather than inherited.

Bank of Brodhead wasn’t handed those things when they launched Vault.Bank; they were built purposefully within the charter that it already had.

Speed doesn’t have to be rushing to become something else, but rather a series of decisions a bank can make on purpose.

Want to learn more about how your bank can launch their own digital brand? Let’s discuss!