Davis Polk partner David Portilla was quoted in the Wall Street Journal discussing the process to gain approval for a bank application with the Office of the Comptroller of the Currency (OCC).

David noted that the OCC has told applicants that it will attempt to grant conditional approvals within 120 days, after which applicants must work to raise capital and build the risk-management systems necessary to obtain final approval.

“What they want to do is get people up and running to start building the bank, rather than precluding people at the front end,” he said. “That will encourage bank formation.”

“How Hobbit-Inspired Startup Plans to Replace Silicon Valley Bank,” Wall Street Journal (October 16, 2025) (subscription required) 

Copy link to share post