Erebor Bank
Erebor Bank is a de novo federally chartered national bank providing deposit, lending, and digital asset services to technology, defense, and AI-adjacent companies. Its co-founders also founded <a href="/dossiers/anduril-industries">Anduril Industries</a> and co-founded <a href="/dossiers/palantir-technologies">Palantir Technologies</a>, and its investor base overlaps with both companies.
Erebor Bank, N.A. (FDIC CERT 59378, OCC Charter 25357) is a federally chartered national bank incorporated in Columbus, Ohio, co-founded by Palmer Luckey and Joe Lonsdale with backing from Peter Thiel's Founders Fund, 8VC, Lux Capital, and Andreessen Horowitz. The bank raised $350 million at a $4.35 billion valuation and launched with approximately $635 million in total committed capital 12. Its stated purpose is to provide banking services—including stablecoin integration and crypto-collateralized lending—to AI, defense, and manufacturing companies 1. It received an OCC conditional charter on October 15, 2025, FDIC deposit insurance on December 16, 2025, and became fully operational on February 6, 2026 3.
The OCC conditional charter was granted 114 days before the bank opened for business, and a comparison of FDIC charter records indicates it is only the second fintech to receive a de novo OCC national bank charter after Varo Bank, whose process took over three years 4. OCC Comptroller Jonathan Gould publicly described Erebor's charter as "the first full-service national bank charter granted during my tenure — the first in four years" 2. A fundraising memo obtained by Business Insider stated that a co-founder's "unique connectivity to banking regulators" was a selling point for investors, and separately predicted regulatory approval by end of 2025 — a prediction that proved accurate 5. Adam Cohen, the Skadden, Arps partner who worked on Erebor's OCC charter application, joined the OCC as Chief Counsel on August 11, 2025 — two months before Erebor's conditional approval — transitioning directly from representing the applicant to a supervisory role at the approving agency 5, Connection #2790.
The bank's Columbus, Ohio address (500 Neil Ave Ste 140) places it in the same metropolitan area as Anduril Industries' Arsenal-1 manufacturing facility, which Luckey founded and which is valued at $30.5 billion 6. Investors in Erebor overlap substantially with investors in Anduril: Founders Fund, 8VC, and Lux Capital hold positions in both 1. Senator Elizabeth Warren (Ranking Member, Senate Banking Committee) sent letters to Comptroller Gould, FDIC Chair Hill, and Luckey on February 25, 2026, calling the approval process "deeply troubling" and citing the fundraising memo as evidence that political connectivity drove regulatory timing 5.
Founding and Capital Structure
Palmer Luckey conceived Erebor Bank following the March 2023 collapse of Silicon Valley Bank, identifying a gap in banking services for venture-backed technology and defense companies 2. He co-founded the bank with Joe Lonsdale, who also co-founded Palantir Technologies and runs 8VC Connection #2793. The bank appointed Owen Rapaport as CEO and Jacob Hirshman — a former adviser to Circle, the issuer of the USDC stablecoin — in a senior role 1.
Lux Capital led the $350 million fundraising round at a $4.35 billion pre-money valuation. Co-investors include Founders Fund, 8VC, and Haun Ventures. Total committed capital including prior rounds reached approximately $635 million 2. The investor base overlaps substantially with the capitalization of Anduril Industries: Founders Fund, 8VC, and Andreessen Horowitz are investors in both entities 1. This alignment positions Erebor as a potential financial services provider to companies within the same investor portfolio — a vertical integration across defense-contracting and banking that the bank's founders have described as intentional 1.
Regulatory Approval Timeline
Erebor filed its OCC national bank charter application in mid-2025. OCC Comptroller Jonathan Gould granted conditional approval on October 15, 2025 (OCC NR-2025-101), describing it publicly as "the first full-service national bank charter granted during my tenure — the first in four years" 2. The FDIC Board approved deposit insurance on December 16, 2025. The full charter became effective February 6, 2026 — 114 days after conditional approval 3.
For comparison, Varo Bank — the only prior fintech to receive an OCC de novo national bank charter — spent more than three years in the application and approval process. Varo had approximately $376 million in assets after five years of operation and reported a net income of negative $91.7 million as of December 2025. Analysis of FDIC records and fundraising disclosures indicates Erebor launched with $635 million in committed capital on day one 4. The OCC imposed a 12 percent Tier 1 leverage ratio requirement on Erebor for its first three years of operation — more than double the standard well-capitalized threshold of 5 percent — indicating that regulators assessed the bank as carrying elevated risk 3.
Gould's prior professional background included a position at Bitfury, a Bitcoin infrastructure company, creating an alignment of professional history with Erebor's stated stablecoin and crypto-lending product plans Connection #2808. No formal recusal or ethics disclosure documents regarding Gould's role in the Erebor charter approval have been made public as of the investigation date.
Adam Cohen: OCC Application and Appointment
Adam Cohen was a partner at Skadden, Arps, Slate, Meagher & Flom LLP and co-head of its Financial Institutions Regulatory Group. In that capacity he worked on Erebor's OCC charter application 5. Cohen joined the OCC as Chief Counsel on August 11, 2025 (OCC NR-2025-76), placing him in a supervisory role over bank licensing and supervision — at the same agency reviewing the application he had recently helped prepare Connection #2790. Conditional approval followed 65 days later.
Senator Elizabeth Warren's February 25, 2026 letter to Comptroller Gould described this sequence as a "textbook revolving door" and requested documentation of any recusals, ethics screenings, or waivers related to Cohen's involvement in the Erebor application process 5. Cohen's career history prior to Skadden included roles at the Federal Reserve Board of Governors and the CFTC, providing him with working relationships across multiple federal financial regulatory agencies 5. The OCC had not responded publicly to Warren's letter as of the investigation date.
Erebor Bank
Network Context and Geographic Alignment
Both of Erebor's co-founders operate within the network associated with Peter Thiel. Luckey founded Anduril Industries in 2017 with Trae Stephens, a partner at Founders Fund; Founders Fund is Anduril's lead investor and also backed Erebor Connection #2792. Lonsdale co-founded Palantir Technologies with Thiel in 2003 and later founded 8VC, which invests in defense companies including Epirus, Saronic, and Overland AI Connection #2793.
Erebor is registered at 500 Neil Ave Ste 140, Columbus, OH 43215 (Franklin County; FDIC CERT 59378; Fed RSSD 6053129) 76. Columbus is also the location of Anduril's Arsenal-1 manufacturing facility — Luckey's flagship production site for defense hardware — despite both Luckey and Lonsdale being based in California and Texas respectively 6. The shared geography positions Erebor to serve Arsenal-1 employees, suppliers, and the broader defense-industrial ecosystem growing around that facility 1. The bank currently operates a single office with no branches 6.
Both company names — Erebor and Anduril — are drawn from J.R.R. Tolkien's fiction, continuing a naming convention established by Palantir Technologies, which took its name from the seeing stones in the same mythology 2.
Erebor Bank
Product Strategy and Stated Market Position
Erebor has described itself as a digital-first bank targeting AI, cryptocurrency, defense, and manufacturing companies — explicitly framing its target market as the post-SVB gap in startup and VC-backed company banking 1. Its announced product suite includes standard commercial deposit and lending services, stablecoin integration, crypto-collateralized loans, and banking-as-a-service via API 1. Jacob Hirshman's background as a Circle adviser is relevant to the stablecoin product line, and Comptroller Gould's Bitfury background aligns with the crypto-lending component 1, Connection #2808.
The bank has not yet filed Call Reports with the FDIC — it is too newly chartered to have generated required financial disclosures — so no independent assessment of its asset base, lending activity, or profitability is yet available 8. Its OCC-imposed 12 percent Tier 1 leverage requirement will constrain leverage ratios during the first three years of operation 3.
All Connections
4 total
All Connections
4 totalFounder of Erebor Bank. Fundraising memo cited his 'political network' as key to securing regulatory approval. Also founder of Anduril Industries ($30.5B defense contractor).
Co-founder of Erebor Bank. Also founder of 8VC, co-founder of Palantir, DOGE advisor. Fundraising memo cited co-founder's 'unique connectivity to banking regulators' — likely refers to Lonsdale's connections.
Cohen was Skadden partner who worked on Erebor's OCC charter application, then joined OCC as Chief Counsel (Aug 11, 2025) where he oversees bank supervision and licensing. Textbook revolving door — from representing the applicant to reviewing the application.
Gould as OCC Comptroller granted Erebor's national bank charter — conditional Oct 2025, full Feb 2026. Erebor's fundraising memo claimed co-founder had 'unique connectivity' to Gould. Gould publicly celebrated as 'first full-service charter in four years.' Gould has crypto background (Bitfury) aligning with Erebor's stablecoin plans.
All Findings
8 total
All Findings
8 totalfinancial (4)
Erebor Bank: Founded by Palmer Luckey (Anduril) and Joe Lonsdale (8VC/Palantir), backed by Peter Thiel (Founders Fund). Digital-first bank for AI, crypto, and defense companies. HQ in Columbus, Ohio (same city as Arsenal-1). Raised $350M at $4.35B valuation led by Lux Capital. Total capital ~$635M. Investors: a16z, Founders Fund, Lux Capital, 8VC, Elad Gil. Secured OCC charter and FDIC deposit insurance approval 'in record time.' Positioned to fill SVB gap for startups and VC-backed companies. Plans to offer stablecoin integration, crypto-collateralized loans, traditional banking via API. Led by Owen Rapaport and Jacob Hirshman (former Circle adviser).
Erebor Bank represents a vertical integration play by the Thiel defense tech network: the same people who build weapons (Anduril), invest in weapons companies (Founders Fund, 8VC, a16z), lobby for weapons contracts (Invariant LLC), and hold government positions overseeing weapons procurement (Trae Stephens on Trump transition team) are now creating the banking infrastructure to serve this ecosystem. Columbus, Ohio location is strategic: same city as Anduril's Arsenal-1 factory. Erebor can bank Arsenal-1 employees, subcontractors, and the defense ecosystem growing around it. Key investors overlap with Anduril investor base: Founders Fund, a16z, 8VC, Lux Capital. This is the same capital network investing in defense companies AND the bank that will serve those companies. Senator Warren flagged concerns about tech billionaires using wealth to 'fuel the MAGA agenda' through financial infrastructure like Erebor. The bank's rapid OCC/FDIC approvals during the Trump administration raise questions about regulatory facilitation for politically aligned entities. Named after the dwarven kingdom in Tolkien's Lord of the Rings (like Anduril, the sword). Peter Thiel named Palantir after the seeing stones in Tolkien; Luckey named Anduril after the flame of the west.
Erebor Bank raised $350M at $4.35B valuation. Founded by Palmer Luckey (Anduril) and Joe Lonsdale (8VC/Palantir). Charter approved by OCC in 4 months (conditional Oct 2025, full Feb 2026), FDIC deposit insurance Dec 2025. Investors: Lux Capital (led), Founders Fund, 8VC, Haun Ventures. Plans: digital-first bank serving AI, crypto, defense, manufacturing companies. Stablecoin integration, crypto-collateralized loans.
Erebor named after Tolkien's Lonely Mountain. Luckey conceived the bank after SVB collapse (2023). Located in Columbus OH — same city as Anduril's $1B Arsenal-1 factory. 4-month OCC charter approval timeline is extraordinarily fast for a de novo national bank charter. Comptroller Jonathan Gould publicly celebrated granting the charter as 'the first full-service national bank charter granted during my tenure — the first in four years.'
Erebor Bank FDIC Registration: CERT 59378, OCC Charter 25357, chartered Feb 6, 2026 at 500 Neil Ave Ste 140, Columbus OH 43215
Erebor Bank, N.A. (FDIC CERT 59378) is a federally chartered national bank registered at 500 Neil Ave Ste 140, Columbus, OH 43215 (Franklin County). OCC Charter #25357. Bank class: N (national, OCC-supervised). Federal Reserve District: 04 (Cleveland). FDIC supervisory region: Chicago. Insured through the Deposit Insurance Fund (DIF). Established and insured as of 02/06/2026. Single office location (no branches). Federal Reserve RSSD ID: 6053129. UNINUM: 676181. No financial data reported yet (too new to have filed Call Reports). CBSA: Columbus, OH metro area (18140). CFPB supervised: No.
Erebor Bank structural identifiers: OCC-regulated national bank, Fed RSSD 6053129, UNINUM 676181, FDIC Chicago region, Cleveland Fed district
Key regulatory identifiers for Erebor Bank, N.A.: FDIC CERT 59378; OCC Charter 25357; Federal Reserve RSSD ID 6053129; UNINUM 676181. Regulatory chain: chartered by OCC (Comptroller of the Currency), supervised by OCC, insured by FDIC Deposit Insurance Fund. FDIC supervisory region: Chicago (DBS 9, SUPRV_FD 09). Federal Reserve district: 04 (Cleveland). Bank class: N (national bank, commercial). CLCODE: 3 (commercial bank with assets under M). CBSA Metro: Columbus, OH (18140). CSA: Columbus-Marion-Zanesville, OH (198). Not designated as MDI (Minority Depository Institution). Not CFPB supervised. Not a member of the Savings Association Insurance Fund (SAIF) or BIF separately. The RSSD ID 6053129 can be used to query the Federal Reserve's NIC (National Information Center) for holding company data and organizational hierarchy.
legal (2)
Erebor fundraising memo told investors 'Palmer's political network will get this done' and touted co-founder's 'unique connectivity to banking regulators' including Comptroller Gould. Adam Cohen, Skadden lawyer who worked on Erebor's OCC application, left Skadden in August 2025 and became OCC Chief Counsel under Gould — reviewing bank charter applications. Senator Warren sent letters to Gould, FDIC Chair Hill, and Luckey demanding answers about the approval process.
Sen. Elizabeth Warren (Ranking Member, Senate Banking Committee) sent letters Feb 25, 2026 alleging: (1) Erebor's fundraising memo predicted approval by end of 2025, correctly predicting the actual timeline; (2) Adam Cohen (Skadden, Arps partner) was co-head of Financial Institutions Regulatory Group, worked on Erebor's OCC application, then joined OCC as Chief Counsel Aug 11, 2025 — a textbook revolving door; (3) the 4-month approval timeline is abnormally fast for a de novo charter. Warren stated: 'it is deeply troubling that Erebor's fundraising memo may have correctly described the reason for the approval: the bank's political network and unique connectivity to banking regulators.' Cohen's prior experience includes Fed Board of Governors and CFTC.
Erebor Bank regulatory timeline: OCC conditional approval Oct 15 2025, FDIC deposit insurance Dec 16 2025, full charter Feb 6 2026 -- under 4 months from conditional to operational
Complete regulatory timeline: OCC application filed mid-2025. OCC conditional approval granted Oct 15, 2025 (NR-OCC-2025-101) -- the first de novo national bank charter under Comptroller Jonathan Gould. FDIC deposit insurance application approved Dec 16, 2025 by FDIC Board. Full charter and insurance effective Feb 6, 2026. Total time from conditional approval to fully operational: 114 days (~3.8 months). Conditions: maintain minimum 12% Tier 1 leverage ratio for first 3 years (vs standard 5%), implement deposit account processing protocols for failure scenarios, exercise Capital Call Agreement rights as needed, engage independent external auditor, pass pre-opening examination. The 12% Tier 1 ratio is more than double the standard well-capitalized threshold of 5%, indicating regulators see elevated risk.
intelligence (1)
SYNTHESIS: Erebor Bank as de novo national bank -- structural comparison with Varo Bank (only other fintech with OCC national charter, CERT 59190) and regulatory capture indicators
Erebor Bank (CERT 59378) is only the second fintech to obtain a de novo OCC national bank charter, after Varo Bank (CERT 59190, chartered Aug 2020). Key differences: (1) Timeline: Varo's charter took 3+ years; Erebor's took under 1 year from application to full charter. (2) Capital: Varo had ~376M in assets as of Dec 2025 after 5 years of operation; Erebor launched with 635M in venture capital on day one. (3) Varo has been unprofitable (net income -91.7M as of Dec 2025 Call Report); Erebor's financial model is untested. (4) Both are OCC-regulated national banks (class N). The speed of Erebor's approval is notable: Comptroller Gould publicly stated Erebor was the FIRST de novo charter he approved. Fundraising memo (Finding 4754) cited 'unique connectivity to banking regulators' as a selling point. Adam Cohen left Skadden (where he worked on Erebor's OCC application) to become OCC Chief Counsel under Gould in Aug 2025, two months before Erebor's conditional approval. The 12% Tier 1 leverage ratio requirement (vs normal 5%) suggests regulators imposed extra buffers, possibly reflecting the crypto/digital asset risk profile.
location (1)
Erebor Bank registered address 500 Neil Ave Ste 140, Columbus OH 43215 -- single office, no branches, coordinates 39.9718/-83.0089
FDIC BankFind shows Erebor Bank's sole registered office at 500 Neil Ave Ste 140, Columbus, OH 43215, Franklin County. Coordinates: 39.971755/-83.008947. This is the main (and only) office -- no branch locations. Columbus was chosen as HQ despite founders being based in California (Luckey in Orange County, Lonsdale in Austin/SF). Columbus is also home to Anduril's Arsenal-1 manufacturing facility, suggesting geographic alignment between Luckey's defense company and his banking venture. The 500 Neil Ave address is in downtown Columbus near the Short North arts district.
- 1.Finding #4684
- 2.Finding #4753
- 3.Finding #4945
- 4.Finding #4948Sources: FDIC BankFind CERT 59190 (VaroView source record, FDIC BankFind CERT 59378View source record, Finding #4754 (fundraising memoView source record, Senate Banking Committee (Warren letter Feb 25 2026) OCC NR-2025-76 (Cohen appointment) Business Insider (fundraising memoView source record, OCC NR-2025-101View source record
- 5.Finding #4754
- 6.Finding #4946
- 7.Finding #4944
- 8.Finding #4947