Corporate Decision 1382 — Preliminary Conditional Approval to Charter Upstart Bank, National Association

Chartering, Organization and Structure
Corporate Decision #1382
July 2026
July 23, 2026
Annie Delgado
Upstart Bank, National Association (Proposed)
2950 S Delaware Street, Suite 410
San Mateo, California 94403
Re: De Novo Charter Application and Citizenship and Residency Waiver Requests OCC Control Nos.: 2026-Charter-345359, 2026-Waiver-345452, and 2026-Waiver-345453 Dear Ms. Delgado:
The Office of the Comptroller of the Currency (OCC) has reviewed your application to establish a new national bank with the title of Upstart Bank, National Association (proposed Bank or Bank). The OCC hereby grants preliminary conditional approval of your charter application upon determining that your proposal meets certain regulatory and policy requirements. Your requests for residency waivers for all five directors and a citizenship waiver for one director, Sanjay Datta, are also conditionally approved. This preliminary conditional approval is granted based on a thorough evaluation of all information available to the OCC, including the representations and commitments made in the application and by the Bank’s representatives. The OCC has also made its decision to grant preliminary conditional approval with the understanding that the proposed Bank will apply for stock in a Federal Reserve Bank in accordance with 12 USC 2221 and will obtain deposit insurance from the Federal Deposit Insurance Corporation (FDIC). The OCC has granted preliminary conditional approval only. Final approval and authorization for the Bank to open will not be granted until all preopening requirements are met. Until final approval is granted, the OCC has the right to modify, suspend or rescind this preliminary conditional approval should the OCC deem any interim development to warrant such action. Proposed Operations The Bank will be a wholly owned subsidiary of Upstart Holdings, Inc. (Upstart), a financial technology company founded in 2012 that operates a cloud-based, artificial intelligence (AI) lending marketplace. Upstart serves as a technology intermediary between consumer borrowers and a network of more than 100 commercial banks and credit unions, processing loan applications and using proprietary AI models to underwrite unsecured, home-secured, and auto￾secured loans both as principal and on behalf of its partner banks. Its primary operating subsidiary, Upstart Network, Inc. (Upstart Network), operates the lending marketplace and 1 See also 12 CFR 209.2.