Banking leaders should pay attention to what the OCC’s chartering decisions are signaling about competition.
On September 2, the Office of the Comptroller of the Currency posted charter decisions for Revolut Bank US and OpenReserve Bank. They are not isolated developments. The OCC’s 2026 decisions also include proposed or approved charters involving digital-first firms such as Nubank, Mercury, Upstart and bunq. The operating lesson is bigger than any one entrant: technology companies increasingly want to own more of the banking relationship rather than simply sit beside it.
Do not confuse an installed customer base with relationship strength
A bank may have decades of history, a branch network and a large deposit base. None automatically guarantee loyalty. Traditional banks should ask what the client receives from the relationship that is difficult to replicate: judgment, continuity, local knowledge, credit understanding, responsiveness and the ability to connect deposits, lending, business banking and wealth needs.
Make digital convenience the floor, not the strategy
Clients increasingly expect basic banking to be easy. Incumbents need reliable digital access because friction destroys trust. But the strategic advantage comes from what happens after the transaction becomes easy.
Protect the moments that require a banker
Use technology to remove low-value work and create more capacity for high-value conversations. As discussed in Your Digital Banking Strategy Still Needs a Human Operating Model, channels should strengthen the relationship, not fragment it.
Measure whether relationships are actually deepening
Track primary-account behavior, deposit retention, funded credit relationships, product relevance, business-owner engagement, wealth connectivity, complaint themes and movement between digital and human channels. A bank can have excellent digital adoption and still become easier to leave.
The Executive Principle
New bank charters do not prove that every digital entrant will succeed, and preliminary or conditional approvals should not be confused with permission to begin full operations. They do show that the competitive perimeter is changing.
Relationship banks should not defend themselves by arguing that technology cannot replace people. They should prove that their people create value technology alone does not.
Digital convenience can win access. Relationship depth has to win the client.
Discussion question: If a digital-first competitor matched your bank’s products and pricing tomorrow, what part of your client relationship would still be difficult to replicate?
