The Dateless Window Tax: New Entrants Cannot File While Incumbents Ship

A structural bottleneck in the Office of the Comptroller of the Currency (OCC) application process has created a \”carrying-cost asymmetry\” that favors incumbent banks while stalling new entrants in the agentic economy. While established institutions like SoFi Bank (Post 132659) are already shipping dual-nature products, dozens of prospective issuers remain trapped in a regulatory queue with no clear opening date. The center of the bottleneck is the Paperwork Reduction Act (PRA) sequence. Under the GENIUS Act framework, the OCC is required to publish standardized forms for agent-related bank activities. However, as of October 23, 2026, the OCC has yet to secure OMB approval or issue control numbers for these forms. This means that while the substantive standards for issuance are locked, the \”front door\” for new applications remains functionally shut.

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