Ramp avoids deposits and loans

This shows Ramp is trying to get the regulatory upside of a bank charter without becoming a balance sheet lender. A national trust bank would let Ramp manage investments and custody digital assets under direct OCC supervision, while leaving the messy parts of banking, taking deposits, making loans, and funding credit risk, with partner institutions. That fits Ramp’s long running pattern of owning the software layer and outsourcing the regulated plumbing beneath it.1 2 3 4 5

• A trust bank is a narrower kind of bank. OCC guidance says most national trust banks do not accept deposits or offer loans, and the 2026 rule clarifies these charters are for trust operations and related activities rather than full service commercial banking. That makes the no deposits, no loans point a feature of the charter design, not a missing product.4 5
• Ramp has already built treasury through partners, not its own charter. Ramp Treasury and Ramp Checking run through partner financial institutions, while Ramp focuses on the interface where finance teams move cash, set controls, and reconcile activity alongside cards, bill pay, procurement, and travel. The proposed charter extends that model into fiduciary investing and digital asset custody instead of replacing it with a traditional bank model.1 2 3
• The closest contrast is Mercury. Earlier research showed Mercury pursuing a national bank charter to vertically integrate deposit gathering and interest economics, while Ramp stayed focused on SaaS and AI. That split still matters. Mercury is built around deposits and bank revenue, while Ramp is using a trust charter to deepen product breadth and compliance credibility without turning into a lender.2 6

The likely next step is a finance platform where operating cash, short term investments, and digital asset custody sit beside cards, AP, travel, and AI spend controls in one workflow. If approved, the charter gives Ramp a cleaner regulatory base for higher trust treasury products, while preserving the fast product iteration and capital light model that has driven its expansion so far.1 2 3 5