Dossier

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. According to Round 6 analysis, its OCC approval letter cites Brooks-era Interpretive Letters #1170 and #1174 together with IL #1184 as the legal scaffold for holding non-asset-backed virtual currencies on balance sheet — making Erebor the canonical instance of durable deregulation scaffolding, where deregulatory artifacts authored at the OCC under one administration are reanimated by counsel from the issuing law firm in a later administration to charter a new entity.

Silicon Valley Defense Complex Jeffrey Epstein
31 findings 13 connections 0 entities

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. The OCC granted preliminary conditional approval on October 15, 2025 under control number 2025-Charter-342076 (Charter 25357), the FDIC approved deposit insurance on December 16, 2025, and the bank opened for business on February 6, 2026 34.

The OCC approval letter was signed to Skadden, Arps, Slate, Meagher & Flom LLP partner Wendy M. Goldberg as counsel of record, and explicitly cites Brooks-era OCC Interpretive Letters #1170 (July 20, 2020) and #1174 (January 4, 2021) together with the Hood/Gould-era IL #1184 (May 7, 2025) as the legal scaffold authorizing the bank to hold non-asset-backed virtual currencies on balance sheet under 12 USC 24(Seventh) 3. Application counsel of record was Adam J. Cohen, who filed the charter application on June 11, 2025, then was named OCC Senior Deputy Comptroller and Chief Counsel effective August 11, 2025 — placing him in supervisory authority over bank licensing 65 days before Erebor's conditional approval 5.

The board of directors named in the OCC approval letter includes Palmer Luckey (Director and Principal Shareholder; founder of Anduril Industries), Diogo Mónica (Independent Director and co-founder of Anchorage Digital, the holder of the prototypical 2021 OCC crypto-bank charter), Michael Mosier (Independent Director and former Acting Director of FinCEN), and Owen Rapaport, Jacob Hirshman, Michael Hagedorn, Trevor Capozza, Richard Grant, Vlad Dubinsky, and Aaron Pelz 6. Senator Elizabeth Warren's February 25, 2026 letter to Comptroller Jonathan Gould stated that the OCC's process 'may have been contaminated by backroom political manipulation' 5. Warren's March 25, 2025 pre-confirmation letter to Gould had previously demanded a four-year cooling-off period from representing national banks following his service as Comptroller and asked whether he would approve a merger directed by the White House after a payment to the President or his family 7.

Charter Approval and Conditions

Erebor filed its OCC national bank charter application on June 11, 2025 5. OCC Comptroller Jonathan Gould granted preliminary conditional approval on October 15, 2025 under OCC Control Number 2025-Charter-342076, Charter 25357, with companion residency waivers under 12 USC 72 (control number 2025-Waiver-342510) for six of the eleven organizers and directors 36. The FDIC Board approved deposit insurance on December 16, 2025, and the full charter became effective February 6, 2026 48.

The OCC approval letter was signed to Wendy M. Goldberg of Skadden, Arps, Slate, Meagher & Flom LLP as counsel of record. The organizing entity Erebor Group Inc., a Delaware corporation, merges into the bank under 12 USC 215a-3, and existing subsidiary Atticus Digital Inc. becomes a wholly-owned subsidiary post-merger 3. The OCC imposed a 12 percent Tier 1 leverage ratio condition for the first three years — well above the standard 9 percent Community Bank Leverage Ratio — together with deposit-failure-processing protocols, Capital Call Agreement enforcement rights, and mandatory pre-opening examination 34.

Analysis of the OCC approval letter indicates that the legal authority cited for holding non-asset-backed virtual currencies on balance sheet under 12 USC 24(Seventh) is built directly on three OCC interpretive letters: IL #1170 (July 20, 2020), IL #1174 (January 4, 2021 — the last business day of the Brooks tenure), and IL #1184 (May 7, 2025) 3. The first two letters were authored under Acting Comptroller Brian Brooks; IL #1184 was issued in the current administration. According to the Round 6 cross-lens review, the framework Brooks wrote at OCC and then served alongside at Bitfury is now operative scaffolding for the Erebor charter 9.

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Board, Management, and Principal Shareholders

The OCC approval letter names eleven organizers, directors, and senior officers 6. Owen Rapaport (CEO, Director, and Principal Shareholder) is the former CEO of Aer Compliance, the regulatory technology firm acquired by StarCompliance, with prior tenures at Bain & Company and the Electrum bitcoin wallet 106. Jacob E. Hirshman (Chief Strategy Officer, Director, and Principal Shareholder) was previously a regulatory adviser to Circle Internet Financial, the issuer of the USDC stablecoin, and an associate at Sullivan & Cromwell 10. Michael Hagedorn (President and Director) is a former Senior Vice President at Valley National Bank and a 17-year veteran of Wells Fargo 10. Richard E. Grant (Chief Financial Officer) previously held senior roles at Customers Bank, Goldman Sachs, and JPMorgan investment banking 10. Trevor Capozza (Independent Director) heads operations at Palmer Luckey's family office 106.

Three directors warrant particular attention. Palmer Luckey sits on the board as a Principal Shareholder; he separately founded Anduril Industries; according to reporting from Ohio Tech News, Anduril's Arsenal-1 manufacturing facility is being built south of Columbus 611. Diogo Mónica is an Independent Director and a co-founder of Anchorage Digital, which holds the OCC's prototypical 2021 crypto-bank charter — itself a product of the same Brooks-era interpretive-letter framework now cited in Erebor's approval 6. Michael Mosier is an Independent Director and the former Acting Director of FinCEN 6. The OCC granted residency waivers under 12 USC 72 for Capozza, Hagedorn, Hirshman, Luckey, Mosier, and Rapaport 36.

Joshua Rosenberg, named in the OCC approval letter as Chief Risk Officer with a 22-year career at the Federal Reserve Bank of New York, departed before the bank opened for business per Senator Warren's February 25, 2026 letter 610. Vlad Dubinsky (Chief Credit Officer) and Aaron Pelz (CTO) round out the management team 6. The principal shareholders identified in the approval letter — Luckey, Rapaport, and Hirshman — are joined by external backers including Peter Thiel's Founders Fund, Joe Lonsdale's 8VC, Lux Capital, Andreessen Horowitz, and Haun Ventures, according to the investor map compiled in Round 6 1213.

Erebor Bank

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Brooks-Era Interpretive Letters as Live Legal Scaffold

The OCC approval letter's legal foundation is unusual to the point of being diagnostic. To authorize the bank to hold non-asset-backed virtual currencies on balance sheet to pay 'gas fees' under 12 USC 24(Seventh), the letter cites three OCC interpretive letters as authority 3. Two were issued during the 2020-2021 tenure of Acting Comptroller Brian Brooks: IL #1170 on July 20, 2020 (national-bank custody of cryptocurrency assets) and IL #1174 on January 4, 2021 (national-bank participation in independent node verification networks and stablecoin settlement). The third, IL #1184, was issued under the current administration on May 7, 2025 3.

Analysis of the Round 6 evidence indicates that the Brooks-era framework now functions as durable deregulation scaffolding: legal artifacts authored during a friendly administration that persisted across administration changes and are now reanimated by counsel from the same chartering channel 9. According to the cross-lens review, the structural pattern is a three-link revolving door — Cohen (Skadden→OCC), Mónica (Anchorage Digital, the prototype crypto-bank charter), and Gould (Bitfury Group→OCC) — operating around the same Brooks-era interpretive-letter framework that scaffolded both Anchorage in 2021 and Erebor in 2025 14.

Records of Jonathan Gould's prior employment, as listed in Senator Warren's March 25, 2025 pre-confirmation letter, identify Bitfury alongside BlackRock and Promontory Financial Group as senior roles preceding his OCC appointment 7. According to corporate registry records compiled in Round 6, Brian Brooks himself sat on the Bitfury Group Ltd UK 11441275 board following his OCC tenure, placing two consecutive ex-Bitfury executives in the Comptroller's office across two administrations 9.

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Adam J. Cohen: Skadden Application to OCC Approval

Adam J. Cohen joined Skadden, Arps, Slate, Meagher & Flom LLP in May 2024 as co-head of the Financial Institutions Regulatory Group 5. On June 11, 2025 he filed Erebor's OCC national bank charter application on behalf of the organizers 5. OCC press release NR-OCC-2025-76, dated July 30, 2025, announced Cohen's appointment as Senior Deputy Comptroller and Chief Counsel effective August 11, 2025 — sixty-one days after he filed Erebor's application 5.

The OCC granted preliminary conditional approval on October 15, 2025; Cohen had then served as OCC Chief Counsel for sixty-five days 5. The approval letter was addressed to Wendy M. Goldberg of Cohen's former Skadden practice 35. In her February 25, 2026 letter to Comptroller Gould, Senator Elizabeth Warren wrote that the OCC's process 'may have been contaminated by backroom political manipulation' and posed Questions 8 through 10 demanding documentation of Cohen's recusals and asking whether Gould had 'discussed Erebor's application with Mr. Cohen either before or after he joined the OCC' and whether Gould 'was aware he served as counsel to Erebor and submitted the company's charter application' when Cohen was hired 5. Cohen's prior government experience, according to the OCC biography and reporting reviewed in this investigation, includes the Federal Reserve Board of Governors and the CFTC, and he previously served as general counsel at SoFi 515.

Analysis of the documented timeline indicates a 65-day window between Cohen's assumption of OCC supervisory authority over bank licensing and the conditional approval of his most recent client's charter application — according to the Round 6 cross-lens review, among the tightest such windows in the federal banking-regulator dataset 9. In parallel, LDA records show that Erebor Group Inc. retained Rich Feuer Anderson for banking and financial-institutions lobbying with effective date June 1, 2025 — the same month as the charter application — through lobbyists with prior service at the Treasury Department, Senate Banking Committee, House Financial Services Committee, and the House Majority Leader's office 1617.

Erebor Bank

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The Warren Probe and the Recusal Question

On February 25, 2026, Senator Elizabeth Warren, Ranking Member of the Senate Banking Committee, sent letters to OCC Comptroller Jonathan Gould, FDIC Chair Travis Hill, and Palmer Luckey regarding the Erebor charter approval 185. In her February 25, 2026 letter to Comptroller Gould, Senator Elizabeth Warren wrote that the OCC's process 'may have been contaminated by backroom political manipulation' 5. The letter cited a fundraising memo, according to Business Insider reporting referenced in the Warren correspondence, describing a co-founder's 'unique connectivity to banking regulators' — including Comptroller Gould — and predicting approval by end of 2025; conditional approval came within four months of application 1814.

Warren's March 25, 2025 pre-confirmation letter to Comptroller-designate Gould posed more than one hundred questions across regulation, supervision, bank-merger review, crypto assets, ethics, and agency independence 7. Question 2 demanded a four-year recusal commitment for matters related to former clients; Question 6 requested a four-year cooling-off period from representing national banks after the Comptroller's service; Question 5 asked whether Gould would approve a merger directed by the White House after a payment to the President or his family 7. The same letter listed Bitfury alongside BlackRock, Promontory Financial Group, and the Senate Banking Committee as Gould's prior senior roles 7.

Analysis of the documented sequence frames Erebor as the first material chartering action under Gould — an application reviewed by Cohen as Chief Counsel after the application was submitted by Cohen as Skadden partner 714. The recusal-voidability question follows directly: according to standard reading of federal ethics regulations and OCC internal procedures, if Cohen's involvement post-appointment was not properly walled off, aspects of the approval may be voidable 14. The OCC had not publicly released recusal documentation as of the investigation date.

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Structural Significance: Durable Deregulation Scaffolding

According to the Round 6 cross-lens synthesis, Erebor is the canonical instance of durable deregulation scaffolding 9. Records show that the mechanism has four moving parts. First, OCC Interpretive Letters #1170 and #1174 were authored under Acting Comptroller Brian Brooks in July 2020 and January 2021 respectively. Second, the letters survived the entire Biden administration as live legal authority without being rescinded. Third, the framework was supplemented in May 2025 by IL #1184 issued under the Hood and Gould tenures. Fourth, the entire stack was cited as authority in the Erebor approval letter signed October 15, 2025 to a partner at the same firm that filed the application 39.

Analysis of the broader pattern reveals two institutional channels converging on the Erebor approval, according to the Round 6 review 914. According to Round 6 corporate-registry and Senate-Banking-Committee records, the first is Bitfury→OCC: Brian Brooks served on the Bitfury Group Ltd UK 11441275 board following his 2020-2021 OCC tenure, and Jonathan Gould served as Bitfury Chief Legal Officer from 2022 to 2025 before his confirmation as the 32nd Comptroller 79. The second is Skadden→OCC: Adam J. Cohen joined Skadden in May 2024, filed the Erebor application in June 2025, and was named OCC Chief Counsel in August 2025 5. According to the cross-lens review, the two channels meet at the Erebor approval letter, which Comptroller Gould's office signed and which OCC Chief Counsel Cohen's law department oversaw — addressed to a partner at Cohen's former firm 314.

Analysis of the Round 6 evidence frames the structural significance plainly: the Brooks-era deregulation framework, written when Brooks ran the OCC, then carried into the private sector when Brooks served at Bitfury, is now the legal scaffold under which a Bitfury-affiliated Comptroller charters a bank advised by his Chief Counsel's old law firm — for backers who include Palmer Luckey, Peter Thiel, and Joe Lonsdale 149. According to the same review, the same Brooks-era framework is also the legal scaffold cited in connection with the World Liberty Financial token and the Tahnoon-anchored stablecoin flows reviewed in Round 6 9.

Founding, Capital, and Geography

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 a data-analytics firm with Peter Thiel in 2003 and later founded 8VC 16. According to investor-disclosure reporting reviewed in this investigation, Lux Capital led the $350 million fundraising round at a $4.35 billion pre-money valuation; co-investors include Founders Fund, 8VC, Andreessen Horowitz, and Haun Ventures, with total committed capital of approximately $635 million 212.

Erebor is registered at 500 Neil Avenue, Suite 140, Columbus, OH 43215 (Franklin County; FDIC CERT 59378; OCC Charter 25357; Federal Reserve RSSD 6053129; LEI 254900S59ZHI2UFM9J76) and operates a single office with no branches 192021. According to Ohio Tech News and the press record reviewed in this investigation, Columbus is also the location of Anduril Industries' Arsenal-1 autonomous-weapons manufacturing facility — Luckey's flagship production site, supported by a $310 million Ohio grant — despite both Luckey and Lonsdale being based in California and Texas respectively 11. Analysis of the geographic record positions Erebor as a financial counterpart to Arsenal-1 employees, suppliers, and the broader defense-industrial ecosystem aggregating around the facility 11.

According to the investor map reviewed in this investigation, the investor base overlaps substantially with that of Anduril Industries: Founders Fund, 8VC, and Andreessen Horowitz hold positions in both entities 12. According to the Round 6 cross-lens review, Erebor's announced product suite — stablecoin integration, crypto-collateralized loans, banking-as-a-service via API, and lending into AI compute and defense manufacturing — was designed to serve the post-SVB gap that these same investors identified 112.

All Connections

13 total
Palmer Luckey corporate strong

Founder of Erebor Bank. Fundraising memo cited his 'political network' as key to securing regulatory approval. Also founder of Anduril Industries ($30.5B defense contractor).

Joe Lonsdale corporate strong

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.

Adam Cohen legal strong

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.

Jonathan Gould legal strong

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.

Adam Cohen employment strong

Cohen filed Erebor OCC charter application as Skadden partner (Jun 2025), then became OCC Chief Counsel (Aug 2025) that approved Erebor (Oct 2025)

Palmer Luckey owns strong

Palmer Luckey co-founded Erebor Bank. Investor memo cited his political network for charter approval

Peter Thiel funds strong

Thiel/Founders Fund is a backer of Erebor Bank

Joe Lonsdale owns strong

Lonsdale co-founded Erebor Bank with Palmer Luckey. Also 8VC founder

Rich Feuer Anderson contracts_with strong

Erebor Group Inc retained Rich Feuer Anderson for banking/financial lobbying effective 2025-06-01, $60K Q2 2025

Founders Fund funds strong

Founders Fund is a backer/investor in Erebor Bank. Peter Thiel (FF co-founder) is named as investor. FF portfolio company Anduril's founder Palmer Luckey co-founded Erebor.

Lux Capital funds strong

Lux Capital led Erebor Bank's $350M raise at $4.35B valuation

Lux Capital funds strong

Led Erebor Bank $350M round at $4.35B valuation. Co-investors: Founders Fund, 8VC, a16z, Haun Ventures. Erebor is defense-tech banking infrastructure.

Kenneth Howery corporate circumstantial

Howery is Founders Fund co-founder. FF invests in Erebor. Howery's potential carry interest in FF creates indirect financial exposure to Erebor's success.

All Findings

31 total

financial (9)

financial medium 2025-12-22

Erebor Bank complete investor map and defense-tech network integration: $635M total capital. $350M round led by Lux Capital at $4.35B valuation. Full investor list: Andreessen Horowitz (a16z, also American Dynamism defense fund), Founders Fund (Peter Thiel), Lux Capital, 8VC (Joe Lonsdale), Haun Ventures, Elad Gil. Every major investor has significant defense-tech portfolio: Founders Fund (Anduril, Palantir, SpaceX), 8VC (Palantir, Anduril, Saronic, Epirus), a16z (Anduril, Shield AI, ACS). Planned services directly serve defense ecosystem: compute loans for AI chips/GPU clusters, underwriting for defense contractors/robotics firms/advanced manufacturers, crypto-collateralized loans, stablecoin integration, credit lines backed by private securities. Bank explicitly designed to fill SVB gap for startups and VC-backed companies.

[ref] Axios erebor-valuation-2025-12
financial confirmed 2026-02-13

Erebor Bank GLEIF record: LEI 254900S59ZHI2UFM9J76, legal name 'Erebor Bank, National Association', registered at 500 Neil Ave Suite 140, Columbus OH 43215, US-OH jurisdiction, GLEIF entity creation date 2025-11-05, LEI registration date 2026-02-13, status ACTIVE, registered as FDIC CERT 59378, S&P Global ID 1949686530, NON_CONFORMING conformity flag, no parent entity reported (reporting exception)

[ref] GLEIF 254900S59ZHI2UFM9J76
financial medium

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.

[ref] CNBC July 2025 Fortune July 2025 PYMNTS.com Benzinga The Block WebProNews
financial high

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.'

[ref] Yahoo Finance Axios (2025-10-15) OCC NR-2025-101 Banking Dive
financial confirmed

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.

[ref] FDIC BankFind API CERT 59378
financial confirmed

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.

[ref] FDIC BankFind API CERT 59378 full institution record
financial high

Erebor Bank N.A. received OCC conditional charter approval 2025-10-15, FDIC deposit insurance Dec 2025, final charter Feb 2026. CERT 59378, Columbus OH.

Erebor Bank, N.A. (FDIC CERT 59378) is a national charter bank established 2026-02-06 in Columbus, OH. Charter application filed 2025-06-11 by Erebor Group, Inc. (NY corporation). OCC conditional approval granted 2025-10-15 (OCC NR-2025-101) - just 4 months after application, compared to median 9.5 months. FDIC deposit insurance approved Dec 2025. Final charter granted Feb 2026. Bank is active per FDIC records (no assets/deposits reported yet). Founded by Palmer Luckey (Anduril founder), Joe Lonsdale (8VC), with backing from Peter Thiel/Founders Fund, 8VC, Haun Ventures. Initial capital $275M. Dec 2025 fundraise: $350M at $4.35B valuation led by Lux Capital. Target market: tech companies in crypto, AI, defense, manufacturing. Services planned: stablecoin integration, crypto-collateralized loans, traditional banking via API. Conditions: 12% Tier 1 leverage ratio for 3 years, independent external auditor, pre-opening examination.

[ref] FDIC BankFind CERT 59378 OCC NR-2025-101 and NR-2025-101a Senate Banking Committee 2026-02-25 letter
financial confirmed

Erebor Group Inc hired Rich Feuer Anderson for banking/financial lobbying. Registration effective 2025-06-01, $60K in Q2 2025 income.

Erebor Group, Inc. (NY) retained Rich Feuer Anderson (DC government relations firm) for lobbying. LDA registration effective 2025-06-01 (same month as OCC application filed). Issues: Banking (BAN) and Financial Institutions/Investments/Securities (FIN). Lobbyists registered: Andrew Carr Palmer (former LA to Rep Fleischmann, Rep Fincher), Jared Cody Sawyer (former Deputy Assistant Secretary Treasury, Senior Counsel Senate Banking Committee, PSM House Financial Services Committee), Matthew Kellogg (former Deputy Asst Sec for Leg Affairs Treasury 2017-2018, Sr Policy Adviser to House Majority Leader McCarthy 2015-2017), Jennifer Rust (former Deputy Chief Counsel House Financial Services Committee). Q2 2025 reported income: $60,000. All four lobbyists have 'covered positions' (government revolving door). Sawyer's prior Senate Banking Committee role is particularly notable given Erebor's need for charter approval.

[ref] LDA Senate filing e1b7b759-e1d1-424c-8cc5-7323a6eed981 (registration) LDA filing 839d4bfe-e1fb-43de-b692-81233ef32600 (Q2 report
financial high

Erebor Bank: defense-tech banking infrastructure with $4.35B valuation, Warren probe into approval

Erebor Bank, founded by Palmer Luckey (Anduril) and Joe Lonsdale (8VC), raised $350M at $4.35B valuation. Backed by Founders Fund, 8VC, Lux Capital, Haun Ventures. OCC conditional charter Oct 2025; FDIC deposit insurance Dec 2025; final charter Feb 2026. Serves defense, AI, crypto companies. Holds stablecoins on balance sheet. Senator Warren probed approval: fundraising memo allegedly stated Luckey's political network will get this done with references to unique connectivity to banking regulators including the Comptroller of the Currency. Erebor lobbied via Rich Feuer Anderson ($220K in Q2-Q4 2025).

[ref] FDIC press release Dec 2025
[ref] LDA lobbying filings Q2-Q4 2025
[ref] Senate Banking Committee minority press release

relationship (1)

relationship medium 2025-06-01

Rich Feuer Anderson lobbying firm retained by Erebor Group Inc. also lobbies for Coinbase, JPMorgan Chase, American Express, Amazon, London Stock Exchange, SoFi, and FINRA — total $7.6M in 2025 lobbying across 56 clients. The SoFi connection is notable: Adam Cohen (Erebor's OCC application lawyer who became OCC Chief Counsel) previously served as general counsel at SoFi per Banking Dive. The lobbying team targeting Congress on banking issues included 5 lobbyists, all with revolving-door backgrounds from Treasury Department, Senate Banking Committee, House Financial Services Committee, and House Majority Leader's office.

[ref] LDA:e1b7b759

legal (8)

legal confirmed 2025-06-01

Erebor Group Inc. (NY) lobbied Congress on Banking and Financial Institutions issues through Rich Feuer Anderson (DC firm, 1133 Connecticut Ave NW Ste 620). 4 LDA filings: Registration (Q2 2025), Q2 report ($60K), Q3 report ($80K), plus Q4. Lobbying effective date 2025-06-01 — same month as OCC charter application (June 11, 2025). Lobbyists: Andrew Carr Palmer (fmr LA for Rep. Fleischmann/Fincher), Jared Cody Sawyer (fmr Deputy Asst Secretary Treasury; fmr Senior Counsel Senate Banking Committee), Matthew Kellogg (fmr Deputy Asst Sec Legislative Affairs Treasury 2017-18; fmr Sr Policy Adviser House Majority Leader McCarthy), Jennifer Rust (fmr Deputy Chief Counsel House Financial Services Committee), John A. Anderson (fmr Sr Policy Adviser Sen. Crapo). All lobbyists have revolving-door Congressional/Treasury backgrounds.

[ref] LDA:e1b7b759-e1d1-424c-8cc5-7323a6eed981
legal medium 2025-08-01

Adam Cohen revolving door: Skadden Arps partner who co-headed Financial Institutions Regulatory Group and submitted Erebor Bank's OCC charter application on June 11, 2025. Named OCC Chief Counsel and Senior Deputy Comptroller in August 2025 — less than 2 months after filing Erebor's application. In his OCC role, he oversees the Law Department including licensing actions (bank charter approvals). OCC bio omits Skadden by name, describing him as co-head of Financial Institutions Regulatory Group at 'a major international law firm.' Prior government: Board of Governors Federal Reserve System, CFTC. Education: Duke BA political science, Columbia Law. Also served as general counsel for unnamed financial institution (reported as SoFi by Banking Dive).

[ref] OCC nr-occ-2025-76
legal confirmed 2025-12-16

FDIC approval conditions for Erebor Bank (Dec 16, 2025): Must maintain minimum 12% tier 1 leverage ratio during first 3 years of operation (above standard requirement). Must implement protocols for processing deposit accounts in event of bank failure. Must exercise Capital Call Agreement rights to obtain capital if it ceases to meet 'well capitalized' status. Approval expires if bank not established within 12 months. Business model explicitly stated as serving 'technology, payment systems, investment, and defense industries, including virtual currency market participants.'

[ref] FDIC erebor-deposit-insurance-2025-12-16
legal medium 2026-02-06

Erebor Bank regulatory timeline confirms record speed for de novo national bank: Application filed June 11, 2025 (public notice Columbus Dispatch June 12). OCC conditional approval October 15, 2025 (~4 months). FDIC deposit insurance approved December 16, 2025 (~6 months from application). Full OCC charter granted February 6, 2026 (~8 months from application). This is the first de novo national bank chartered under the second Trump administration, and the first new national bank charter in years (fewer than 6 charters annually 2010-2023 vs ~130 annually pre-2008). Typical de novo bank process takes 12-18 months. Comptroller Gould publicly promoted the approval on X. The bank's investor memo had predicted approval by end of 2025.

[ref] OCC nr-occ-2025-101
legal high 2026-02-26

Senator Elizabeth Warren probe of Erebor Bank charter (Feb 25-26, 2026): Sent letters to OCC Comptroller Jonathan Gould, FDIC Chairman Travis Hill, and Palmer Luckey. Cited investor memo predicting approval by end of 2025 with language 'Palmer's political network will get this done' and touting co-founder's 'unique connectivity to banking regulators.' Warren alleged charter approval was potentially a 'corrupt political favor.' Requested unredacted charter applications and all correspondence related to Erebor's approval process. Response deadline: March 12, 2026.

[ref] Senate-Banking Warren-Erebor-2026-02-25
legal confirmed

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.

[ref] Senate Banking Committee (Warren letter Feb 25 2026) OCC NR-2025-76 (Cohen appointment) Business Insider (fundraising memo
legal confirmed

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.

[ref] FDIC BankFind CERT 59378
[ref] FDIC press release Dec 16 2025
[ref] OCC NR-2025-101 (Oct 15 2025
legal confirmed

Warren March 25 2025 confirmation-letter listed Bitfury alongside Blackrock and Promontory as Gould's prior 'senior roles'; demanded 4-year cooling-off + immediate divestiture commitment

Sen. Warren's pre-confirmation letter to Comptroller-designate Gould (Mar 25 2025, 16pp) explicitly states: 'Previously, you served as Senior Deputy Comptroller and Chief Counsel at the OCC. You have also served in senior roles at Bitfury, the Senate Banking, Housing, and Urban Affairs Committee, Blackrock, and Promontory Financial Group.' Letter posed 100+ questions across Regulation/Supervision, Bank Merger Review, States' Rights, Crypto Assets, CRA, Enforcement, DOGE/Independence, and Ethics. Specific Ethics Q1: 'Do you agree with your former boss [Otting] that banks are the OCC's customers?' Q2: 'do you commit to recusing yourself in all matters related to your former clients for a period of four years?' Q3: 'In the past 12 months, have you advised any clients on any matters related to national bank chartering, licensing, mergers, permissible activities, regulation, supervision, or enforcement? If so, please list the client and the relevant matters.' Q4: 'will you commit to immediately divesting from owning securities, such as stock, stock options, and bonds, of banks or savings associations or their affiliates?' Q6: 'Do you commit to a 4-year cooling off period from representing any national banks, or their affiliates or holding companies, following the conclusion of your service as Comptroller?' Q5: 'Would you approve a merger transaction if so directed to by the White House, including after the applicant made a payment to the President, a member of his family, or to his related business interests?' Crypto Assets Q7-8 raised Anchorage Digital and Paxos/Protego conditional charters. Gould's prior law-firm clients per public reporting: JPMorgan Chase, Goldman Sachs, Circle (the stablecoin issuer). Erebor approval Oct 15 2025 was first major chartering action under Gould — application reviewer was Cohen (ex-Skadden, former Erebor counsel).

intelligence (5)

intelligence medium 2025-07-03

Erebor Bank Columbus-Anduril Arsenal-1 geographic nexus: Erebor Bank HQ at 500 Neil Ave Suite 140, Columbus OH 43215. Anduril Industries building Arsenal-1, a $1B autonomous weapons manufacturing facility in Pickaway County, just south of Columbus, projected 4,000+ jobs (largest single job-creation project in Ohio history). Anduril received $310M grant from Ohio for Arsenal-1. Both entities co-founded by Palmer Luckey. This creates a vertically integrated defense-tech hub: manufacturing (Arsenal-1) + financial services (Erebor) in the same metro area, with the same founder.

[ref] OhioTechNews erebor-columbus-2025
intelligence medium

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.

[ref] FDIC BankFind CERT 59190 (Varo
[ref] FDIC BankFind CERT 59378
[ref] Finding #4754 (fundraising memo Senate Banking Committee (Warren letter Feb 25 2026) OCC NR-2025-76 (Cohen appointment) Business Insider (fundraising memo
+1 more sources
intelligence high

Warren probe found investor memo claimed Luckey political network will get this done and co-founder unique connectivity to banking regulators including Gould.

Senator Elizabeth Warren sent letters on 2026-02-25 to OCC Comptroller Jonathan Gould, FDIC Chairman Travis Hill, and Palmer Luckey regarding Erebor Bank's charter approval. Warren cited a fundraising memo circulated to prospective investors that stated: (1) Palmer Luckeys political network will get this done and (2) an Erebor co-founder had unique connectivity to banking regulators including Comptroller Gould. The memo predicted federal approval in less than six months after June 2025 application - and the actual conditional approval came in 4 months. Warren demanded the complete unredacted charter application and all correspondence, with March 12, 2026 deadline. She stated: If my inquiry reveals that Erebors national bank charter was not granted in accordance with law and regulation and instead represented a corrupt political favor to the Presidents billionaire supporters in Silicon Valley it would have to be terminated. At the Feb 26 hearing, Gould responded: the only political pressure I have felt from any part of the United States government senator is from you.

[ref] Senate Banking Committee press release 2026-02-25 Warren letter to OCC 2026-02-25 CoinDesk 2026-02-26 hearing coverage
intelligence medium

SYNTHESIS: Erebor charter is the structural payoff of the Bitfury->OCC pipeline — three-link revolving door (Cohen/Skadden, Mónica/Anchorage, Gould/Bitfury) operating same Brooks-era IL framework; Warren letter Feb 2026 frames it as 'corrupt political favor'

Round-6 synthesis. Three documented revolving-door links converge on Erebor approval (Oct 15 2025): (1) GOULD: Comptroller is ex-Bitfury Group CLO (2022-2025) and prior OCC Chief Counsel (Brooks tenure 2020-21) — confirmed in Warren confirmation letter and Bitfury 2022 press release. (2) COHEN: OCC Chief Counsel since Aug 11 2025 was the Skadden partner who filed Erebor's June 11 2025 charter app; named recusal subject in Warren Feb 2026 letter Q8-Q10. (3) MÓNICA: Erebor independent director is Anchorage Digital co-founder; Anchorage holds the prototypical Brooks-era OCC crypto charter (Jan 2021), later subject to OCC consent order (Apr 2022, AML deficiencies — exact same risk profile Erebor's 12% Tier-1 condition tries to ring-fence). Erebor's approval letter explicitly cites Brooks-era ILs #1170 and #1174 as legal scaffold — meaning the framework Brooks wrote at OCC, then served at Bitfury, is now used by Bitfury's ex-CLO (now Comptroller) to charter a bank advised by his Chief Counsel's old law firm. Warren Feb 2026 letter frames as: 'whether the OCC's process was contaminated by backroom political manipulation... a corrupt political favor to the President's billionaire supporters in Silicon Valley.' Cited Business Insider Aug 8 2025 fundraising memo: Luckey's 'political network will get this done' and a co-founder had 'unique connectivity to banking regulators,' including Comptroller Gould. Bank approval expected by end of 2025 in fundraising memo — granted within 4 months of application (vs typical multi-year vetting for de novo banks). 'Erebor would serve as the financial hub for an interrelated set of Silicon Valley firms' — Anduril (Luckey weapons), Palantir (Thiel/Lonsdale surveillance), and a 'concentrated set' of crypto/AI/defense companies. Bank opened Feb 8 2026 without a Chief Risk Officer (Rosenberg listed in approval letter; Warren Q12 confirms departure before opening). The Bitfury->OCC pipeline is now Bitfury->OCC->Bitfury-friendly-charter pipeline, with Skadden as the legal hinge.

intelligence medium

META-SYNTHESIS: Seven cross-lens patterns from Round 6 (Agents A-G). (1) Vault-firm regulatory revolving door is a 4-instance pattern: a 3-instance Skadden-or-equivalent->OCC->implementation pipeline (Brooks 2020 Coinbase->OCC->Bitfury; Gould 2025 Bitfury/BlackRock/Promontory->OCC; Cohen 2025 Skadden->OCC->Erebor approval — Cohen's 65-day window the tightest), plus a parallel vault-firm->OMB->Schaerr Jaffe->OMB pattern via Paoletta (2018+2025) at OMB+CFPB+OIRA — STRUCTURALLY DISTINCT from the OCC pipeline. (2) Brooks-era IL #1170/#1174 + IL #1184 are LIVE OPERATIVE LAW cited in Erebor approval letter — the deregulation framework now scaffolds WLFI/Tahnoon flows. (3) Aryam Investment 1 = Tahnoon vehicle bought 49% WLFI for $500M ($187M to Trump-family entities); G42 Edelman + Xiao seated undisclosed; MGX deployed $2B WLFI USD1 -> Binance May 2025. (4) Round 5 'Mubadala unifies' model UPGRADED to three SCFEA sovereign pillars (ADIA + Mubadala + L'IMAD ~$300B post Jan-2026 consolidation under Khaled bin Mohamed bin Zayed) + regulatory layer (Al Shorafa = ADX + SCA + ADGM Vice Chair) + US-listing layer (Kazim = Nasdaq Inc. director via Borse Dubai). Bridges outlast principals. (5) Pre-positioning trades cluster around Jan 2025 Stargate window: Bitfury $53.9M dividend Dec 23 2024 (38d before Cipher PIPE), AltC closed May 2024 with anomalous $7,457.80 redemption out of ~30M shares (PIPE backstop not triggered), Crusoe started Abilene construction Jun 2024 (7mo before Stargate announcement), SoftBank fully exited Cipher Q3 2025 — Stargate is largely re-bundling of preexisting infrastructure already in motion. (6) Klein-Altman-Oklo and Stargate-MGX are STRUCTURALLY SEPARATE per SEC primary-source level — press treatment merged them. Altman resigned Oklo board Apr 22 2025, 3 months after Stargate announce. (7) bin Sulayem resigned DP World Feb 13 2026 after DOJ Epstein release — first observed VISIBLE LOSS for Tahnoon network on Epstein-related exposure; replacement Kazim maintains/extends US-market access via Nasdaq Inc. board seat. ROUND 5 NAME CORRECTIONS: Stéphane->Bertrand G. des Pallières; Antoine Bremner unverified->likely Christopher Bremner; Compagnie Du Saleve B223232 incorporated 2018 so cannot be 28 Oct 2015 entity (likely closed French SARL #803012046 instead); SKAS = Saker Aviation Services ticker not partners' acronym; Hoffenberg 'Gold shielded Epstein' claim has NO docket support in 1:94-cr-00213.

identity (4)

identity high 2025-07-03

Erebor Bank complete executive team from Business Insider July 2025: Co-CEOs Owen Rapaport (fmr CEO Aer Compliance, fmr Bain & Co consultant, fmr Electrum bitcoin wallet) and Jacob Hirshman (Circle adviser, fmr Sullivan & Cromwell associate, UPenn Law). Co-founders also include Trevor Capozza (head of operations Palmer Luckey family office, fmr Optimozo) and Aaron Pelz (CTO, fmr Pinwheel engineering lead, fmr Quorum software engineer). President: Michael Hagedorn (fmr SVP Valley National Bank, fmr 17yr Wells Fargo veteran leading Midwest banking group 5yr, fmr UMB Financial). CRO: Joshua Rosenberg (22yr Federal Reserve Bank of NY career, fmr United Texas Bank crypto-focused institution, PhD Economics UC San Diego, fmr NYU Stern professor). CFO: Ricky Grant (fmr Customers Bank head of IR and strategic finance, fmr Goldman Sachs MD 2019, fmr JP Morgan investment banking). CCO: Vlad Dubinsky (fmr Bancorp Bank MD credit markets, fmr Blue Foundry Bank).

[ref] BusinessInsider erebor-executives-2025-07
identity high

Erebor founding team: Palmer Luckey, Trevor Capozza, Jacob Hirshman, Aaron Pelz, Owen Rapaport. Key execs: Rapaport (CEO/director), Hirshman (co-CEO), Mike Hagedorn (president).

Erebor Bank officers: Owen Rapaport (CEO, director, formerly Aer Compliance CEO), Jacob Hirshman (co-CEO, former Circle adviser), Mike Hagedorn (president, formerly SVP Valley National Bank NJ). Founders: Palmer Luckey (Anduril/Oculus founder), Trevor Capozzi, Jacob Hirshman, Aaron Pelz, Owen Rapaport. Backers: Peter Thiel (Founders Fund), Joe Lonsdale (8VC), Katie Haun (Haun Ventures), Lux Capital (led $350M round Dec 2025). Erebor Group Inc incorporated in New York. Bank headquarters: Columbus, Ohio. LittleSis entity 459524 describes it as 'Crypto bank by right-wing billionaires'.

[file] PitchBook Erebor profile LittleSis entity 459524 OCC charter application Axios/Bloomberg Dec 2025 reporting
identity confirmed

Adam Cohen — Skadden partner who filed Erebor charter application appointed OCC Chief Counsel 61 days later

Sen. Warren's Feb 25 2026 letter establishes the timeline: Erebor's charter application was submitted by Adam J. Cohen, a Skadden partner, on June 11, 2025. OCC press release nr-occ-2025-76 (July 30, 2025) announced Cohen's appointment as Senior Deputy Comptroller and Chief Counsel effective August 11, 2025 — 61 days after Erebor application. Cohen co-headed Skadden's Financial Institutions Regulatory Group (joined Skadden May 2024). Prior: SoFi General Counsel; Federal Reserve Board; CFTC. Warren letter Q8-Q10 demands Cohen's recusal documentation and asks whether Gould 'discussed Erebor's application with Mr. Cohen either before or after he joined the OCC' and whether Gould 'was aware he served as counsel to Erebor and submitted the company's charter application' when hired. The Erebor charter was approved Oct 15, 2025 — Cohen had been OCC Chief Counsel for 65 days at approval. The OCC approval letter was signed to 'Wendy M. Goldberg, Counsel, Skadden, Arps' — Cohen's former colleague at the same firm.

identity confirmed

Erebor organizers, directors, officers — full roster from OCC approval letter Oct 15 2025

OCC approval letter names: Owen Rapaport (Organizer/CEO/Director/Principal Shareholder; ex-Aer Compliance CEO acquired by StarCompliance); Jacob E. Hirshman (Organizer/CSO/Director/Principal Shareholder; ex-Circle); Michael Hagedorn (Organizer/President/Director); Richard E. Grant (Organizer/CFO); Trevor Capozza (Organizer/Independent Director); Palmer Luckey (Director/Principal Shareholder; Anduril founder); Diogo Mónica (Independent Director; Anchorage Digital co-founder, Haun Ventures GP); Michael Mosier (Independent Director; ex-FinCEN Acting Director); Vlad Dubinsky (Chief Credit Officer); Joshua Rosenberg (Chief Risk Officer — per Warren letter departed before bank opened); Aaron Pelz (CTO). Residency waivers under 12 USC 72 for Capozza, Hagedorn, Hirshman, Luckey, Mosier, Rapaport. Backers per Warren: Luckey, Lonsdale, Thiel — all major Trump/Vance donors. CRITICAL OVERLAP: Diogo Mónica co-founded Anchorage Digital, the OCC's first crypto bank charter (Brooks era 2021); Mosier is ex-FinCEN; structurally, Erebor's 'independence' rests on directors who built/regulated the framework now being applied to them.

location (1)

location confirmed

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.

[ref] FDIC BankFind CERT 59378 locations endpoint

document (1)

document confirmed

OCC Conditional Approval — Erebor Bank N.A. — full charter Oct 15 2025 (Skadden filed, Gould era)

OCC granted preliminary conditional approval Oct 15 2025 (OCC Control 2025-Charter-342076; Charter 25357; Residency Waivers 2025-Waiver-342510). Counsel of record: Wendy M. Goldberg, Skadden Arps Slate Meagher Flom LLP, One Manhattan West, NY. Organizing entity: Erebor Group Inc (Delaware) merges into the bank under 12 USC 215a-3. Existing subsidiary Atticus Digital Inc becomes wholly-owned post-merger. Tier-1 Leverage Ratio condition: 12% for first three years (vs 9% standard CBLR). Bank explicitly cites Brooks-era Interpretive Letters #1170 (Jul 20 2020 — written under Brooks), #1174 (Jan 4 2021 — Brooks's last day), and Hood/Gould-era IL #1184 (May 7 2025) as legal scaffold for holding non-asset-backed virtual currencies on balance sheet to pay 'gas fees' under 12 USC 24(Seventh). Confirms the Brooks-Gould interpretive-letter framework is the live operative legal scaffold for new crypto-bank charters.

negative_result (2)

negative_result confirmed 2026-03-23

NEGATIVE RESULTS: Sources checked with zero results for Erebor Bank: (1) SEC EDGAR full-text search — 0 hits, bank has no SEC filings. (2) CourtListener — 0 results, no federal litigation involving Erebor. (3) Corporate registries (unified, OH, DE) — 0 results, national bank charter not in state corporate registries. (4) USASpending — 0 federal contracts or grants to Erebor. (5) IRS 990 — 0 results, not a nonprofit. (6) FARA — 0 results, no foreign agent registration. (7) SAM.gov — could not query (API key not configured). (8) LDA lobbying under 'Erebor Bank' name — 0 results (lobbying filed under 'Erebor Group Inc.' parent).

[ref] multiple-sources
negative_result confirmed

No Erebor Bank entry in EDGAR as a bank (only investment fund SPVs). No RSSD/NIC found. No SAM.gov registration. No CourtListener cases.

EDGAR search for 'Erebor' returned 43 filings but all relate to investment fund SPVs (Erebor LP, series of VUVP Fund, CGF2021 LLC, etc.) and unrelated companies - no filings from Erebor Bank or Erebor Group Inc as a bank entity. FDIC confirms the bank exists (CERT 59378) but it is newly chartered with no financial statements yet. SAM.gov search failed (no API key configured). CourtListener search returned only unrelated cases (Erebor Resources LLC Ch 7 bankruptcy in E.D. Texas 2019). No Federal Reserve NIC/RSSD entry was findable via web search. This suggests the bank is too new for most regulatory databases.

[ref] EDGAR EFTS search for Erebor FDIC BankFind CERT 59378 CourtListener search

Full Timeline

19 events
Palmer Luckey co-founded Erebor Bank. Investor memo cited his political network for charter approval
2025 to present
Thiel/Founders Fund is a backer of Erebor Bank
2025 to present
Lonsdale co-founded Erebor Bank with Palmer Luckey. Also 8VC founder
2025 to present
Founders Fund is a backer/investor in Erebor Bank. Peter Thiel (FF co-founder) is named as investor. FF portfolio company Anduril's founder Palmer Luckey co-founded Erebor.
2025 to present
Howery is Founders Fund co-founder. FF invests in Erebor. Howery's potential carry interest in FF creates indirect financial exposure to Erebor's success.
2025 to present
Cohen filed Erebor OCC charter application as Skadden partner (Jun 2025), then became OCC Chief Counsel (Aug 2025) that approved Erebor (Oct 2025)
2025-06 to 2025-10
Erebor Group Inc retained Rich Feuer Anderson for banking/financial lobbying effective 2025-06-01, $60K Q2 2025
2025-06 to present
Erebor Group Inc. (NY) lobbied Congress on Banking and Financial Institutions issues through Rich Feuer Anderson (DC firm, 1133 Connecticut Ave NW Ste 620). 4 LDA filings: Registration (Q2 2025), Q2 report ($60K), Q3 report ($80K), plus Q4. Lobbying effective date 2025-06-01 — same month as OCC charter application (June 11, 2025). Lobbyists: Andrew Carr Palmer (fmr LA for Rep. Fleischmann/Fincher), Jared Cody Sawyer (fmr Deputy Asst Secretary Treasury; fmr Senior Counsel Senate Banking Committee), Matthew Kellogg (fmr Deputy Asst Sec Legislative Affairs Treasury 2017-18; fmr Sr Policy Adviser House Majority Leader McCarthy), Jennifer Rust (fmr Deputy Chief Counsel House Financial Services Committee), John A. Anderson (fmr Sr Policy Adviser Sen. Crapo). All lobbyists have revolving-door Congressional/Treasury backgrounds.
2025-06-01
Rich Feuer Anderson lobbying firm retained by Erebor Group Inc. also lobbies for Coinbase, JPMorgan Chase, American Express, Amazon, London Stock Exchange, SoFi, and FINRA — total $7.6M in 2025 lobbying across 56 clients. The SoFi connection is notable: Adam Cohen (Erebor's OCC application lawyer who became OCC Chief Counsel) previously served as general counsel at SoFi per Banking Dive. The lobbying team targeting Congress on banking issues included 5 lobbyists, all with revolving-door backgrounds from Treasury Department, Senate Banking Committee, House Financial Services Committee, and House Majority Leader's office.
2025-06-01
Erebor Bank complete executive team from Business Insider July 2025: Co-CEOs Owen Rapaport (fmr CEO Aer Compliance, fmr Bain & Co consultant, fmr Electrum bitcoin wallet) and Jacob Hirshman (Circle adviser, fmr Sullivan & Cromwell associate, UPenn Law). Co-founders also include Trevor Capozza (head of operations Palmer Luckey family office, fmr Optimozo) and Aaron Pelz (CTO, fmr Pinwheel engineering lead, fmr Quorum software engineer). President: Michael Hagedorn (fmr SVP Valley National Bank, fmr 17yr Wells Fargo veteran leading Midwest banking group 5yr, fmr UMB Financial). CRO: Joshua Rosenberg (22yr Federal Reserve Bank of NY career, fmr United Texas Bank crypto-focused institution, PhD Economics UC San Diego, fmr NYU Stern professor). CFO: Ricky Grant (fmr Customers Bank head of IR and strategic finance, fmr Goldman Sachs MD 2019, fmr JP Morgan investment banking). CCO: Vlad Dubinsky (fmr Bancorp Bank MD credit markets, fmr Blue Foundry Bank).
2025-07-03
Erebor Bank Columbus-Anduril Arsenal-1 geographic nexus: Erebor Bank HQ at 500 Neil Ave Suite 140, Columbus OH 43215. Anduril Industries building Arsenal-1, a $1B autonomous weapons manufacturing facility in Pickaway County, just south of Columbus, projected 4,000+ jobs (largest single job-creation project in Ohio history). Anduril received $310M grant from Ohio for Arsenal-1. Both entities co-founded by Palmer Luckey. This creates a vertically integrated defense-tech hub: manufacturing (Arsenal-1) + financial services (Erebor) in the same metro area, with the same founder.
2025-07-03
Adam Cohen revolving door: Skadden Arps partner who co-headed Financial Institutions Regulatory Group and submitted Erebor Bank's OCC charter application on June 11, 2025. Named OCC Chief Counsel and Senior Deputy Comptroller in August 2025 — less than 2 months after filing Erebor's application. In his OCC role, he oversees the Law Department including licensing actions (bank charter approvals). OCC bio omits Skadden by name, describing him as co-head of Financial Institutions Regulatory Group at 'a major international law firm.' Prior government: Board of Governors Federal Reserve System, CFTC. Education: Duke BA political science, Columbia Law. Also served as general counsel for unnamed financial institution (reported as SoFi by Banking Dive).
2025-08-01
FDIC approval conditions for Erebor Bank (Dec 16, 2025): Must maintain minimum 12% tier 1 leverage ratio during first 3 years of operation (above standard requirement). Must implement protocols for processing deposit accounts in event of bank failure. Must exercise Capital Call Agreement rights to obtain capital if it ceases to meet 'well capitalized' status. Approval expires if bank not established within 12 months. Business model explicitly stated as serving 'technology, payment systems, investment, and defense industries, including virtual currency market participants.'
2025-12-16
Erebor Bank complete investor map and defense-tech network integration: $635M total capital. $350M round led by Lux Capital at $4.35B valuation. Full investor list: Andreessen Horowitz (a16z, also American Dynamism defense fund), Founders Fund (Peter Thiel), Lux Capital, 8VC (Joe Lonsdale), Haun Ventures, Elad Gil. Every major investor has significant defense-tech portfolio: Founders Fund (Anduril, Palantir, SpaceX), 8VC (Palantir, Anduril, Saronic, Epirus), a16z (Anduril, Shield AI, ACS). Planned services directly serve defense ecosystem: compute loans for AI chips/GPU clusters, underwriting for defense contractors/robotics firms/advanced manufacturers, crypto-collateralized loans, stablecoin integration, credit lines backed by private securities. Bank explicitly designed to fill SVB gap for startups and VC-backed companies.
2025-12-22
Led Erebor Bank $350M round at $4.35B valuation. Co-investors: Founders Fund, 8VC, a16z, Haun Ventures. Erebor is defense-tech banking infrastructure.
2025-present
Erebor Bank regulatory timeline confirms record speed for de novo national bank: Application filed June 11, 2025 (public notice Columbus Dispatch June 12). OCC conditional approval October 15, 2025 (~4 months). FDIC deposit insurance approved December 16, 2025 (~6 months from application). Full OCC charter granted February 6, 2026 (~8 months from application). This is the first de novo national bank chartered under the second Trump administration, and the first new national bank charter in years (fewer than 6 charters annually 2010-2023 vs ~130 annually pre-2008). Typical de novo bank process takes 12-18 months. Comptroller Gould publicly promoted the approval on X. The bank's investor memo had predicted approval by end of 2025.
2026-02-06
Erebor Bank GLEIF record: LEI 254900S59ZHI2UFM9J76, legal name 'Erebor Bank, National Association', registered at 500 Neil Ave Suite 140, Columbus OH 43215, US-OH jurisdiction, GLEIF entity creation date 2025-11-05, LEI registration date 2026-02-13, status ACTIVE, registered as FDIC CERT 59378, S&P Global ID 1949686530, NON_CONFORMING conformity flag, no parent entity reported (reporting exception)
2026-02-13
Senator Elizabeth Warren probe of Erebor Bank charter (Feb 25-26, 2026): Sent letters to OCC Comptroller Jonathan Gould, FDIC Chairman Travis Hill, and Palmer Luckey. Cited investor memo predicting approval by end of 2025 with language 'Palmer's political network will get this done' and touting co-founder's 'unique connectivity to banking regulators.' Warren alleged charter approval was potentially a 'corrupt political favor.' Requested unredacted charter applications and all correspondence related to Erebor's approval process. Response deadline: March 12, 2026.
2026-02-26
NEGATIVE RESULTS: Sources checked with zero results for Erebor Bank: (1) SEC EDGAR full-text search — 0 hits, bank has no SEC filings. (2) CourtListener — 0 results, no federal litigation involving Erebor. (3) Corporate registries (unified, OH, DE) — 0 results, national bank charter not in state corporate registries. (4) USASpending — 0 federal contracts or grants to Erebor. (5) IRS 990 — 0 results, not a nonprofit. (6) FARA — 0 results, no foreign agent registration. (7) SAM.gov — could not query (API key not configured). (8) LDA lobbying under 'Erebor Bank' name — 0 results (lobbying filed under 'Erebor Group Inc.' parent).
2026-03-23
Sources
  1. 1.Finding #4684
    Sources: CNBC July 2025 Fortune July 2025 PYMNTS.com Benzinga The Block WebProNewsSource record
  2. 2.Finding #4753
    Sources: Yahoo Finance Axios (2025-10-15) OCC NR-2025-101 Banking DiveSource record
  3. 3.Finding #11180
  4. 4.Finding #4945
    Sources: FDIC BankFind CERT 59378Source record, FDIC press release Dec 16 2025Source record, OCC NR-2025-101 (Oct 15 2025Source record
  5. 5.Finding #11184
  6. 6.Finding #11181
  7. 7.Finding #11198
  8. 8.Finding #7029
    Sources: FDIC erebor-deposit-insurance-2025-12-16Source record
  9. 9.Finding #11236
  10. 10.Finding #7021
    Sources: BusinessInsider erebor-executives-2025-07Source record
  11. 11.Finding #7030
    Sources: OhioTechNews erebor-columbus-2025Source record
  12. 12.Finding #7033
    Sources: Axios erebor-valuation-2025-12Source record
  13. 13.Finding #7273
    Sources: PitchBook Erebor profile LittleSis entity 459524 OCC charter application Axios/Bloomberg Dec 2025 reportingSource record
  14. 14.Finding #11204
  15. 15.Finding #7023
    Sources: OCC nr-occ-2025-76Source record
  16. 16.Finding #7019
    Sources: LDA:e1b7b759-e1d1-424c-8cc5-7323a6eed981Open artifactSource record
  17. 17.Finding #7261
    Sources: LDA Senate filing e1b7b759-e1d1-424c-8cc5-7323a6eed981 (registration) LDA filing 839d4bfe-e1fb-43de-b692-81233ef32600 (Q2 reportSource record
  18. 18.Finding #7028
    Sources: Senate-Banking Warren-Erebor-2026-02-25Source record
  19. 19.Finding #4944
    Sources: FDIC BankFind API CERT 59378Source record
  20. 20.Finding #4946
    Sources: FDIC BankFind CERT 59378 locations endpointSource record
  21. 21.Finding #7014
    Sources: GLEIF 254900S59ZHI2UFM9J76Source record