A New Speed Limit: Inside Erebor's Four-Month Sprint

Erebor, a new national bank, received preliminary conditional approval for its charter just four months after applying. We spoke to four financial experts who explain how it happened.

Oct 23, 2025

Many sources have described Erebor’s four-month approval process as “lightning-quick.” Was Erebor’s process actually faster than typical?

Graham Krizek, Founder & CEO of Voltage: Yes, it was unusually fast by traditional banking standards. Four months is quick for any institution seeking approvals in a heavily regulated space.

Arthur Azizov, Founder and Investor at B2 Ventures: Absolutely. Four months is lightning-fast by banking standards.

Why did that happen?

Fergus Hodgson, Director of Econ Americas: Time is money, and faster approval is immensely preferable for firms working in rapidly innovating sectors. Further, we all know the Office of the Comptroller of the Currency is supposed to meet a 120-day target anyway.

Brian Graham, Partner and Co-Founder, Klaros: The four-month turnaround requirement from receipt of a complete application has been on the books for a long time, but frequently previous administrations from both parties would not declare applications to be complete, causing the timelines to extend. The OCC’s action and Comptroller Gould’s statement on Erebor are clear signals that this OCC leadership is committed to hitting those deadlines even on complex and novel applications.

Graham Krizek, Founder & CEO of Voltage: It likely happened because regulators are getting more comfortable with digital-asset frameworks. The compliance work done by previous entrants in this space has helped lay the groundwork for others, making it easier for qualified firms to move more quickly through the process.

Arthur Azizov, Founder and Investor at B2 Ventures: I think it happened because regulators saw Erebor’s model as timely — post-crash, the market needed a stablecoin-focused institution with robust compliance. Erebor leaned into transparency early, which helped accelerate the process.

Does their approval signal a new era of looser regulation, or is this a one-off?

Fergus Hodgson, Director of Econ Americas: Not necessarily. Erebor is a unique, well-backed bank on a mission to foster crypto development on a national basis. There are only a few comparisons to make, a small sample size. If there is a political element to the approval, it likely stems from Peter Thiel. He has been a respected, forward-thinking venture capitalist for many years, and he has worked closely with the US vice president.

Arthur Azizov, Founder and Investor at B2 Ventures: It’s not a free pass, but it does reflect some of the ongoing changes. We’ve already seen signs — like Trump’s crypto-in-401(k) order — that regulators are, slowly but surely, leaning towards crypto assets. Erebor’s approval fits that narrative. Still, it’s conditional: compliance is front and center. So this doesn’t look like deregulation to me — rather, it’s ongoing recalibration.

Brian Graham, Partner and Co-Founder, Klaros: Whether or not the regulators charter a new bank is distinct from how the regulators may supervise banks on an ongoing basis. We do expect a much higher number of charter applications and of approvals in the next couple of years. Separately, a number of the regulators, including the OCC, have recently taken concrete action to reduce what they see as unnecessary regulatory burdens. It wouldn’t surprise us to see additional similar actions.

Graham Krizek, Founder & CEO of Voltage: I wouldn’t call it looser regulation, more like better-understood regulation. Agencies are still cautious, but they’ve had years to study stablecoins, custody, and payment rails built on Bitcoin. We’re seeing more consistency in how oversight is applied.

Erebor plans to target “technology companies and ultra-high-net-worth individuals that use virtual currencies.” Is it risky to depend on volatile industries and clients?

Arthur Azizov: We’ve been seeing a lot of volatility lately, yes — but also resilience. Markets got another valuable lesson to avoid repeating it in the future. After Friday’s flash crash, Ethereum rebounded 16%, and Bitcoin reclaimed around 6%. To me, that shows systemic confidence and foundation. Erebor’s clients understand risk and demand institutional-grade service. If anything, Erebor is built to serve the volatility, not avoid it.

Graham Krizek: Every client segment has volatility, but that’s where diversification and infrastructure strategy matter. Technology firms and high-net-worth investors tend to adopt early and push boundaries. If Erebor builds sound risk management, those clients could actually accelerate adoption rather than destabilize it. The key is using frameworks, like Lightning payments, that minimize custodial exposure and settlement risk.

Brian Graham: Impossible to say without a deeper understanding of the bank’s business plan, which is undoubtedly what the OCC invested the last four months in evaluating. For instance, virtual currencies can be volatile (as has been the case with Bitcoin recently) or stable (see stablecoins). That’s where good bank design, risk management, and effective risk-based supervision come in.

Some tech investors have been irked about crypto startups getting “debanked” by traditional institutions. Is this an answer to those complaints?

Fergus Hodgson: Yes. Traditional financial institutions are top heavy and becoming obsolete or less relevant. They are rationally fearful of creative destruction and will resist helping firms perceived as a threat. Although healthy for the economy, creative destruction means specific sectors that must evolve or die. Dragging their feet has played into the hands of Erebor and other fintech-oriented banks.

Graham Krizek: Partly, yes. The “debanking” trend has shown how fragile access to fiat rails can be for digital-asset companies. Institutions like Erebor help close that gap by combining compliance and innovation under one roof. But the broader answer is decentralized payment infrastructure. The Lightning Network gives companies the ability to move value instantly without relying solely on traditional banking relationships.

Arthur Azizov: Yes, Erebor could be viewed as a response to the persistent “debanking” of crypto startups. What I particularly like in this story is that Erebor demonstrates that crypto-focused finance can be fully regulated, transparent, and suitable for institutional use. It aligns with larger trends, such as the inclusion of crypto in retirement plans and the growing popularity of tokenized U.S. Treasuries. Together, these changes indicate that the barrier between traditional finance and digital assets is beginning to crumble, and Erebor is playing a big role in building that bridge.

It’s been said that Erebor wants to fill the void left by the collapse of Silicon Valley Bank. Why?

Brian Graham: Silicon Valley Bank carved out an iconic place for itself as THE bank for tech. The bank’s failure continues to leave a hole in the market and it is logical some banks will see that as an opportunity.

Fergus Hodgson: Given SVB’s profound influence over decades, its absence is meaningful. However, the two banks are different animals. SVB had a broader mandate and arose prior to the 1990s internet boom. Erebor is dealing at the tip of the spear with a faster-moving fintech landscape. Still, SVB offers a fascinating case study and lessons regarding risk management and herd behavior for Erebor.

How does Erebor avoid similar pitfalls?

Arthur Azizov: SVB collapsed in 2023 due to a duration mismatch and concentrated exposure to venture-backed tech clients. It held long-term Treasuries while funding short-term deposits, and when rates rose, it couldn’t meet withdrawals. Erebor’s model avoids this by using tokenized short-duration assets and stablecoin rails for real-time liquidity. For example, Erebor’s treasury operations include tokenized U.S. bills with daily mark-to-market pricing, unlike SVB’s held-to-maturity accounting.

Brian Graham: To be clear, the failure of SVB had almost nothing to do with tech (or for that matter ultra-high-net-worth individuals or virtual currencies). SVB failed for the simplest of reasons: in the middle of the pandemic-induced zero interest rate environment, the bank plowed billions into long-term fixed rate securities; when rates increased, the securities lost value and the bank became insolvent.

SVB did serve a unique clientele, many of whom knew each other and were connected through twitter and other platforms. Concentrated and coordinated action among a bank’s depositors to pull their funds is a nightmare scenario. Any bank that serves a concentrated clientele needs to understand and prepare for that risk.

Erebor has said they want to become “the most regulated entity conducting and facilitating stablecoin transactions” and facilitating “broader acceptance of stablecoins.” What kind of downstream effects will that have, if they are successful?

Graham Krizek: If they succeed, it accelerates the normalization of stablecoin use for everyday payments and treasury operations. That means faster settlement, reduced cross-border friction, and potentially a clearer regulatory path for other fintechs. For companies using the Lightning Network, it would increase liquidity and create a bridge between fiat-denominated assets and Bitcoin’s payment rails, making global settlement cheaper and near-instant.

Arthur Azizov: If Erebor succeeds in becoming the most regulated stablecoin facilitator, it could fundamentally reshape how digital assets integrate into mainstream finance. This transformation really depends on having a solid infrastructure in place. Pricing needs to be clear and updated in real-time, custody should meet top-notch fiduciary standards, and risk protocols must be strong enough to handle sudden market drops, like the one we saw on October 11.

Erebor isn’t just aiming to make stablecoin transactions easier — it’s working to create a trust layer that enables digital assets to thrive within regulated financial systems. If they pull this off, it could lay the groundwork for a whole new wave of crypto-integrated financial products.

Fergus Hodgson: The nod to regulation points to privilege derived from first-mover advantage, network effects, and compliance. Assuming costly compliance, it is a barrier against competitors.

The writing is on the wall for state-issued currencies. The question is whether their demise will take years or decades. Erebor’s backers want in on the ground floor—to profit from and catalyze the shift to stablecoins.

Brian Graham: There’s pretty broad consensus across the industry that stablecoins have significant potential to lower the cost and delays inherent in many payments transactions that use traditional rails. It is easy to complain about the burdens of regulation. But, as the Erebor application for a bank makes clear, there are benefits that come with being regulated, the most important of which is that being a regulated bank provides customers with a level of comfort and trust in working with that institution. Trust is a priceless asset in banking. If the trade-off of regulatory burden for trust and other powers didn’t make sense, Erebor would never have applied for a charter.