James, are some of these players looking to buy banks instead of chartering new ones? And I have to ask, is buying a bank easier or quicker than chartering?

Absolutely.

The uptick in charters has also been mirrored with an uptick in change of control transactions where non-banks are trying to buy typically a smaller bank and then convert the business plan, maybe eliminate offices or certainly change locations.

Those transactions are really not easier from a regulatory standpoint.

The statutory factors are slightly different, but essentially the regulators are going to underwrite fully the business plan, management, financials, and the risk and compliance management framework, whether it's a de novo or buying a charter.

I think the real benefit is almost in the cost.

It just takes a really long time to start from scratch and create a new bank.

Whether or not a point of sale finance company decides to partner with an existing bank, acquire an existing bank charter, or do a de novo bank charter, ultimately depends on factors like their timeline, their capital needs, what their management team looks like, and their regulatory risk appetite.