How to start a neobank: the vendor stack, layer by layer

A new neobank rents its licence from a partner bank and buys most of its product from specialist vendors, from identity checks to cards. The founding team keeps the customer, the ledger and the decision on what customer balances earn, and stablecoins have changed the options for that last layer since the GENIUS Act passed in July 2025.

Chime agreed on 9 September 2026 to buy Stride Bank, its partner bank in Enid, Oklahoma, for $590 million in cash. Chime built its business on partner banks, and its CEO said owning a charter would give it full control of the product and the delivery cycle. For a team working out how to start a neobank, the deal shows both ends of the path. You launch on a partner bank's licence, and you might buy a bank once you're as large as Chime.

Everything between those two points is a set of vendor choices, one for each layer of the product.

The seven layers of a neobank stack

A neobank looks like one app to its customers. Behind the screens sit seven layers, and a new team builds two or three of them and buys the rest.

A restaurant works the same way. It buys its bread, coffee and fish from different suppliers, and the menu, the room and the service are its own. A neobank buys its bank, its card processor and its wallets the same way, and keeps the app, the brand and the record of who owns what.

The ledger and the customer relationship are the two layers you can't hand off. The remaining five can be rented at launch and replaced later, as Chime is now doing with its bank.

A partner bank holds the licence at launch

A new US neobank usually starts on a partner bank's charter, either signed directly or through a banking-as-a-service (BaaS) provider that sits between the app and the bank. Purrweb, an app studio, estimates a BaaS-based MVP from around $80,000 and 6 to 9 months, against $12 to 30 million and 18 to 36 months of regulatory review for a new US bank charter. Those are a vendor's estimates, and compliance staff and card program fees push real budgets higher.

Flex, a business banking app for founders, runs on this model at scale. Its customers hold their accounts at Column N.A., a chartered bank, and spend with a Flex Visa card. Flex runs on its partner bank's charter, and it raised $70 million at a $1.2 billion valuation in July 2026, with more than $10 billion in annualised payment volume. Our comparison of banking as a service providers covers how the main platforms differ, and embedded banking vs BaaS explains who holds which licence.

The licences a neobank and its card program need

In the US the partner bank holds the charter, and the neobank runs its program under the bank's oversight. The neobank needs licences of its own once it holds or moves customer money outside the partner bank, and most teams borrow those from licensed partners at launch.

Many neobanks keep customer dollars in one pooled account at the partner bank, called an FBO ("for benefit of") account, and record each customer's share on their own ledger. In most programs the bank still moves the money, including card payments out to Visa or Mastercard, which keeps those flows inside the bank's licence.

Money transmission takes the longest, because each state licenses it separately. FinCEN treats any business that transfers funds as a money transmitter with no minimum volume, and New York's BitLicense covers anyone storing or maintaining custody of crypto on behalf of others. More than half of US states have adopted the CSBS model money transmission law, which brings their rules closer together. In the EU, MiCA has applied in full since 30 December 2024. Card programs sit mostly on their card sponsor's membership: Rain holds principal memberships with Visa and Mastercard and sponsors programs for its partners.

The licence choice also shapes yield. Money transmission and e-money rules limit what a program can do with balances that are a claim on it, and stablecoin Earn products usually run on balances the customer owns, such as custodied or self-custodied USDC. Each neobank takes its own legal advice on where its balances fall.

The ledger and compliance stay closest to you

The ledger is the record of what each customer owns, and it's the layer that broke in 2024. Synapse, a BaaS provider sitting between apps such as Yotta and Juno and several partner banks, kept its own record of each customer's share of pooled accounts. When Synapse filed for bankruptcy on 22 April 2024, that record no longer matched the money at the banks, and the CFPB put the gap at between $60 million and $90 million. Customers of the apps on top couldn't reach their money for months, even though the apps themselves hadn't failed. Two months later the Federal Reserve took an enforcement action against Evolve Bank & Trust over how it managed its fintech partnerships. In September 2024 the FDIC proposed a rule requiring banks to keep a record of each customer's share of pooled fintech accounts. A team that owns its ledger, on software like Modern Treasury or its own database, can show its partner bank a daily match from the first test account.

Compliance follows the same split. Vendors run the identity checks and screen transactions, while the neobank writes the policy, decides who gets an account and files the reports its partner bank asks for.

Cards and money movement now run on stablecoins too

Card issuing used to mean a long contract with a processor and a card sponsor, the bank or network member that puts its Visa or Mastercard membership behind the program (also called a BIN sponsor). The card sponsor is often the same bank that holds the neobank's accounts. Rain, which issues Visa cards backed by stablecoin balances, raised a $250 million Series C in January 2026 and said it processed more than $3 billion in annualised transactions for over 200 partners, including Western Union and KAST. Stripe's Bridge partnered with Visa in April 2025, letting developers issue stablecoin-linked Visa cards through a single API, starting in six Latin American countries.

Money movement has moved the same way. Flex Global settles its customers' international transfers in stablecoins in minutes, and the business owner never sees the token. For a new neobank this means the customer can hold dollars as USDC, pay with a card anywhere Visa works and send money abroad without a correspondent bank chain.

Wallets hold the stablecoin balances

A neobank that holds customer stablecoins needs somewhere to keep the keys. Custodied USDC means the customer owns the tokens while the neobank, or a custody provider, holds the keys on their behalf. A bank can be that custodian too: the OCC confirmed in 2020 that national banks may hold crypto for customers, and in 2025 that they can use sub-custodians. Embedded wallet providers such as Turnkey and Privy create a wallet for each customer at sign-up, behind an email or passkey login, and enforce spending policies on every transaction. Our wallet-as-a-service comparison lists the main options.

Yield is the last layer, and customers see it first

The GENIUS Act, signed on 18 July 2025, bars stablecoin issuers from paying holders interest or yield. Law firm Stinson notes that the Act sets no matching ban on platforms such as exchanges paying similar returns. A neobank can offer an Earn product on customer USDC, and the return comes from what the balance is invested in, from Treasuries to lending. How the GENIUS and CLARITY Acts reshape stablecoin yield covers the detail, and each neobank takes its own legal advice for the markets it serves.

The yield options sit in risk bands. The most conservative holds tokenized money market funds and earns the T-bill rate around the clock, including weekends. Higher bands add lending and market-neutral strategies, each with its own withdrawal terms. Many neobanks launch with one conservative band and add a second once the first has a track record, and tiered stablecoin yield shows how those menus are built.

Upshift is onchain yield infrastructure that lets fintechs and asset managers offer yield inside their own products, from 24/7 tokenized money market funds to DeFi strategies. Each vault is non-custodial: the customer's balance sits in a vault contract, the customer holds a receipt token for their share, and the vault's limits are enforced onchain. Tria went live on the Upshift SDK two weeks after starting its integration, and the yield options page lists the bands with indicative rates. A neobank's DD team will usually run a vault provider review before launch.

Vault yields float with the market and aren't guaranteed, and every strategy carries smart contract, counterparty and liquidity risk. Always make sure to do your own research and be aware of the above and any other risks before depositing.

A launch order for a small team

1. Pick the market and the customer, then the partner bank or BaaS provider that serves that market.
2. Write the compliance policy and choose the identity vendor.
3. Stand up the ledger and reconcile it daily from the first test account.
4. Add cards and money movement, in dollars, stablecoins or both.
5. Add wallets if customers hold stablecoins, then switch on yield with one conservative band.

Steps 4 and 5 can run in parallel once the ledger is live.

Frequently asked questions

How much does it cost to start a neobank?

Purrweb puts a BaaS-based MVP from around $80,000, and a new US bank charter at $12 to 30 million. Card program minimums, compliance hires and partner bank fees sit on top of the build cost.

Do you need a banking licence to start a neobank?

Not at launch in the US. The partner bank holds the charter and the deposits. The neobank needs state money transmitter licences only if it holds or sends customer money outside the bank, and many start by using a licensed partner for that too.

How long does it take to launch a neobank?

Purrweb estimates 6 to 9 months for an MVP on a BaaS provider. Partner bank due diligence often sets the pace, and a bank charter adds 18 to 36 months of review.

What is a stablecoin neobank?

A neobank that holds customer balances in stablecoins such as USDC, often alongside a dollar account. Customers spend through a stablecoin-backed card, send money abroad in minutes and can earn on the balance through a vault.

Can a stablecoin neobank pay yield in the US?

The GENIUS Act stops issuers from paying yield, and Stinson reads it as leaving platforms free to pay similar returns. Neobanks usually route the balance into a vault or tokenized fund and take legal advice for each market.

Keep reading

• Embedded finance companies: the 2026 map: who sells each layer of the embedded finance stack.
• How consumer apps are distributing onchain yield: the apps that added vaults in 2026 and how they did it.
• How card programs earn yield on customer float: the float between card load and settlement.
• Why every financial product will run on vaults: the case for vaults as the yield layer.