Anduril founder Palmer Luckey’s new digital bank, Erebor, told prospective investors in a fundraising memo that it expects federal banking regulators to approve its plans by late 2025 — a speedy timeline that it says is possible because of Luckey’s “political network” and the bank’s close ties to regulators.
The memo said the bank anticipated receiving a charter from the Office of the Comptroller of the Currency “less than 6 months” after it submitted its application, which happened in June.
The startup is in part banking on Luckey’s political ties to clinch the approval required to become a regulated bank in the US.
“Palmer’s political network will get this done,” the memo said. Luckey contributed over $1 million to politicians and political committees last year, most of them linked to Republicans, federal records show.
The memo also touted an Erebor cofounder’s “unique connectivity to banking regulators” including Jonathan Gould, who was sworn in as Comptroller of the Currency in July.
Gould, who was a senior official in the OCC in President Donald Trump’s first administration, served for less than a year as the chief legal officer of the bitcoin mining company Bitfury. More recently, he spent two years as a partner at the law firm Jones Day.
Adam Cohen, a top Skadden lawyer who worked with Erebor on its OCC application, recently left the firm and was appointed Gould’s chief counsel at the OCC. In a LinkedIn post announcing his job change, Cohen thanked Gould for “the opportunity to support a safe and sound banking system that embraces innovation and promotes fair access to financial services.”
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When reached for comment, the OCC referred to its general timelines and didn’t respond to specific questions about Erebor and any ties to Gould. The OCC says that it generally aims to make a preliminary, conditional decision on charter applications within 120 days.
“The OCC carefully considers every bank charter application submitted based on the facts of the application and consistent with its statutory and regulatory requirements,” agency representative Stephanie Collins said in an email. Gould couldn’t immediately be reached for comment on Thursday.
Luckey, other Erebor executives, and a lawyer who has represented the bank didn’t respond to requests for comment.
A spokesperson for Peter Thiel’s Founders Fund, which Business Insider previously reported has invested in Erebor, said that the fund “invested a relatively small amount ($1m) in Erebor and is not involved in its operations.”
Todd Baker, a senior fellow at Columbia University and a consultant for fintech companies, said that nine months would be a more realistic timeline, even under a president who has been embraced by some tech investors and cryptocurrency advocates.
Michele Alt, a consultant with the Klaros Group, said standing up a bank after getting preliminary approval usually takes longer than three months. Banking regulators typically won’t let a full-service bank open without deposit insurance, either, she said.
Erebor submitted an application to the Federal Deposit Insurance Corp. on July 28. In its OCC application, it said it would proceed with that step once it received preliminary approval. The startup’s fundraising memo budgeted less than four months for preliminary approval and about three months for final approval. As of August 7, no approval had surfaced in the OCC’s public database.
In 2024, the median time to decide on a deposit insurance application was 295 days, or almost 10 months.
Banking law experts told Business Insider that it isn’t unusual for the full completion of both processes to take a year or longer.
Baker said he believes Erebor will be approved by the OCC and the FDIC because of the “stricter control” the Trump White House has shown over agencies, even those with a reputation for independence.
“Assuming they had a reasonably conservative business plan, you might say nine months would be typical,” Baker said. “To the extent it has issues — and this, in the past, would be considered to have real issues — if this would have happened three or four years ago, one would have expected a year, a year and a half, or not approved at all.”
Regulators will often “have lots of follow-up questions” once an application is submitted, said Paige Pidano Paridon, a former staffer at the Federal Reserve who is now co-head of regulatory affairs at the Bank Policy Institute.
The number of commercial banks in the US has been dwindling for decades, partly because of low interest rates as well as risk-averse regulators. Fintech-industry applicants have had a particularly tough time. While the OCC has granted approval to one fintech bank in under two months since 2017, and others within its 120-day timeframe, other applications were withdrawn after years of delay.
Varo Bank, an online bank that targets low-to-middle-income consumers, spent a reported $100 million and took three years before winning full approval from the OCC and the Federal Deposit Insurance Corp.
SoFi applied for a national bank charter in July 2020, pivoted in 2021 to acquire a bank, and received conditional approval from the OCC in January 2022.
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