Congratulations to Upstart!

By Brian Graham & Michele Alt

Congratulations to Upstart Holdings, Inc. (NASDAQ: UPST), the leading AI lending marketplace, which today announced its plan to submit an application to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) to establish an insured national bank, Upstart Bank, N.A. Upstart Holdings, Inc. will also apply to the Federal Reserve for approval to become a bank holding company.

This is a huge milestone for Upstart, which has established itself as the leading AI lending marketplace, connecting millions of consumers to more than 100 banks and credit unions that leverage Upstart’s AI models and cloud applications to deliver superior credit products. Upstart has demonstrated that it can approve more borrowers at lower prices by harnessing the power of AI. It also marks an important transition for Annie Delgado, Upstart’s Chief Risk Officer, who’s been selected as Chief Executive Officer of Upstart Bank, N.A. A national bank charter will allow Upstart to reduce operational, regulatory, and financial costs and complexity for itself and for its bank and other business partners. Upstart’s goal of launching the first bank built from the ground up on AI and working with regulators to set the standard for modern AI model deployment within the banking system is ambitious, but also essential given the rapidly expanding impact of AI everywhere. If anyone can do it, it will be this talented team. It’s a real pleasure to work with them toward this goal.

Going into 2026, it was clear that the regulatory landscape in the U.S. had become much more open to innovation generally and more welcoming to companies like Upstart and momentum has only increased in the first quarter. We’re proud to have assisted Upstart in reaching this important milestone. If you’d like to chat bank strategy and charters, give us a call.