Stabledash Live · · 26 min
MoneyLion's Founder on Chartering a National Bank With Blockchain in the Core
Dee Choubey
Dee Choubey discusses his transition from MoneyLion, the direct-to-consumer fintech super app he founded in 2012 and took public in 2021 before selling to Gen Digital in 2025, to Open Reserve, a newly chartered national bank. Open Reserve received conditional approval from the OCC in September to operate as a national bank, positioning it to modernize banking infrastructure by integrating blockchain and digital assets within regulatory frameworks. Choubey explains that traditional neobanks face structural limitations from relying on partner banks and multiple regulatory layers, whereas Open Reserve as a chartered bank can build end-to-end infrastructure combining traditional banking with on-chain capabilities, stablecoins, and continuous underwriting powered by AI agents.
Key takeaways
- Open Reserve Bank received conditional OCC approval to charter as a national bank in September 2024 after filing in April, targeting market entry in early 2027.
- Neobanks like Chime and SoFi are constrained by dependence on partner banks and three-layer regulatory governance; Open Reserve avoids this by directly controlling core banking infrastructure and integrating blockchain.
- The concept of agentic banking involves continuous underwriting and permissioned real-time data access to provide continuous credit lines, plus tokenization of restricted cash and collateral to unlock lower-cost capital.
- Open Reserve is building a common tech stack combining a national bank and broker-dealer to enable stablecoins as a transport mode for borrowing, lending, and deposit yields across both traditional and digital asset substrates.
- Choubey advises first-time neobank founders to ensure proper capitalization, avoid cutting corners on compliance and product quality, and recognize that founder-led innovation can outpace incumbents but mistakes in regulated finance cause rapid deterioration.
Transcript
2 turns, about 4600 words. Straight from the recording, so it reads like speech.
Zach Fowler
host0:01
Dee, how's it going? Happy, Tuesday, kinda like a Monday. Thank you. Nice to be here.
Dee Choubey
guest0:07
Yeah. Good to good to good to have you here. How was your Labor Day, Labor Day weekend? Labor Day was great. You know, this is one of the better weather times of the year here in the Northeast Of America, so can't can't complain. How was it, was there some tension there with enjoying the weekend after coming off a pretty pretty big announcement? I imagine it was a pretty pretty busy week for you last week. Really busy week, really exciting.
You know, think the the team's hard at work, so, you always have to have balance in life. Right? You gotta enjoy the rest and then you gotta get back to work. So you're getting back to work. Maybe give give us give the people who maybe didn't see the I don't know if how they missed it last week, but maybe if they did, maybe a quick background on yourself, what you were previously building with MoneyLion, and then now where where your new focus is at with Open Reserve. Yeah. Great. Hey, everyone. My name is D.
Chowbei. So prior to Open Reserve, I started my career as an investment banker. I used to cover banks for the for for the first ten years of my life. Banks, asset managers, insurance companies at Goldman Sachs, at Citadel. I had a front row seat to the evolution of consumer finance. O eight, o nine were a form of really kind of years where I learned a lot about the banking system and how important it is to societies.
And then in 2012, I started MoneyLion, which was a direct to con it is a direct to consumer, now very scaled super app, stratified in a lot of ways, but, you know, we were one of the first to integrate Bitcoin rewards through debit cards. You could swipe your money on a debit card and get, rounded up into Bitcoin. This was 2017, so we're fairly early to that game. We scaled Moneyline. We took it public in '21.
I ran it as a public company CEO for four and a half years, and we decided to sell the business to Gen Digital. Industrial logic was they had a 100,000,000 consumers globally and oh, sorry, in The US. And they all would get the benefit of MoneyLion superpowers, was borrow, save, invest. And 2025, we closed that deal, after taking a little bit of time off, you know, taking pictures of zebras and lions in Africa.
You know, I came back to the genius act, and it reminded me in a lot of ways of what I saw in 2012, where it was a once in a lifetime opportunity to go challenge the incumbent infrastructure, the financial services infrastructure. In 2012, it was you can compete with the banks and marketing. I think this time around, the entire substrate or the backbone infrastructure of banking is ripe for rebuilding. And the Genius Act allows that by bringing digital assets inside of the regulatory perimeter.
So, you know, I I after a lot lot of thinking, long and hard conversations with friends, families, relatives, you know, we decided to really to look at building that core ourselves. And, you know, we decided to charter a national bank open reserve in April of this year. April 14 was when we filed our bank charter application.
And after a lot of, back and forth, rigorous review by the OCC last week, we were granted conditional approval to form, open reserve bank, which is, you know, super exciting for us, so we don't take it lightly. You know, national banks are, you know, they're quite rare, and Yeah. I think it's a great opportunity to go build and work with some amazing people. You know, you kinda beat me to it with your, what you alluded to in in 2012 and Yeah. Seen the marketing.
It's it's kinda interesting too because, you know, we talked to a ton of neobanks, neobanks that have raised a ton of money, like CASK. And it's like as they're on the way in, you're on your way out of of the consumer finance space. So can you unpack a little bit more of like what you saw behind the scenes? Imagine you got a front row seat to it as you're building money line with like this kind of this this disconnect between what you want to do and what's possible, mainly driven by, you know, the infrastructure.
Like, help help us understand, like, what are the big differences and what is the goal Yeah. Of Open Reserve with powering what I imagine you wanted to do in 2017, 2016, 2015. Yeah. Look. I think you alluded to it. Right? I think the market structure in The United States is interesting. Right? You have three layers of, governance. You've got state regulators. You've got, federal regulators.
You've got, and then a whole sort of, you know, the public companies that then are gatekeepers that also act as a regulatory layer. Right? So you have to go through these partner banks to be able to offer, demand deposit accounts, DDA accounts commonly known, or some some will do prepaid accounts, even kind of to go into Visa, Mastercard. You need a bank to sponsor you. Right? So, there are a lot of great banks out there that do that business.
You know, we always found that that really kind of made us beholden to, two or three layers of governance. Right? So the bank's roadmap, hey. You know, are we going to, really, know, facilitate a certain type of lending or a certain type of savings account or a certain type of credit card account? Then you have the issuing third party, processor who sits in the middle. Give the card networks, that you have to placate. So, yeah, it's it is challenging.
It can be done, but, you know, we we we had some hard fought wins and hard fought learnings doing that. Right? So, you know, getting getting kind of organization across those three verticals is tough. Then, of course, you have DeFi where you have, you know, with permissionless wallets, you can do a lot of things differently. You don't necessarily need a lot of that stack. But, ultimately, you have pain points around on ramps, off ramps.
But, you know, I always say this to people is that there's only two ways to make money as a bank. Right? You gotta lend and you gotta provide advice. So if you look at the biggest market caps out there, right, there are they're either lenders or they are asset managers. Right? And the biggest ones do both of them very well, and they diversify themselves around that, and they have fee fee income businesses that support those too. It's hard to do that with as as a fintech.
Now we were part of the cohort of folks like SoFi and Chime, and and and those folks. And MoneyLion today is super scaled, it does a great job for a certain segment of the population.
But, you know, this time around with the blockchain now finally becoming a tool that you can use in that banking technology spine, there is just an incredible opportunity to modernize that three or four layered stack into, really, the bank operating it all from the core to the analytics, to the orchestration, to the underwriting, and giving a much more modern AI ready, agent ready, you know, product back to folks that are ultimately building direct to consumer products too.
So we're excited to be partnering with both direct to consumer and b to b use cases, and, we'll be bringing together twelve years of really kind of alligator bikes as we call it. Yeah. From a from a personal perspective, does either one of those routes get you more excited than than the other?
I think especially we've seen in the past few months, a a few other, banks get charters that seem to be much more skewed on the on the b to b side, and it and I'd say a lot of our conversations have started to drift more of, you know, what's actually being built, what do these consumer apps look like, especially what do these consumer apps look like with the Genetic infrastructure?
Is there any any route that you're, I'm sure you're gonna serve both, but if, like, maybe you even had to, like, pick one, which one are you maybe more more confident in? Well, look. My past was I was a direct to consumer guy. Right? I mean, MoneyLion was the number one finance app for many weeks and months. It was, you know, 25,000,000 plus downloads. Right? So we know how to market to consumers. We've done things with MrBeast. We we were, you know, the the bank for the NASCAR affinity consumers.
So we've done a lot of the b to c playbooks. But I think this time around, the excitement that I get is actually on the technology side of integrating, you know, on chain capital markets, decentralized technologies, blockchain technologies. We're going to be as native to fiat federal we're we're building close to the Federal Reserve capabilities or an RTP and Fed now as we will to a lot of the permissioned l ones as well as the public l l ones.
So, you know, I think that bringing that technology together is probably the the the new challenge, the new adventure. And, you know, we can't even imagine some of the products that are going to be built in. The consumer sentiment has changed. Their preferences have changed.
The consumer just like the consumer got trained on using Google as an operating system, I think the consumer broadly in The United States and increasingly globally is getting trained on the the first kind of entry point to their managing their life to be agentic through either ChatGPT or Anthropic or Perplexity. You you see the rise of products like Instinct and RockBot. Right? People are going to expect their financial services capabilities to follow.
And that we know from just kind of seeing the last the twenty tens adoption. Right? When when I started Moneyline, people it was it was still close to impossible to get a loan fully underwritten online. Right? I mean, the fact that I'm even saying that is is gonna seem quite antidiluviate. The fact of the matter is is that that that was only fifteen years ago. So if you imagine what's going to be built in fifteen years, there will be no product. Everything will be probably behind the scenes.
And the bank's cores today cannot necessarily be doing that parallel processing, the compute the way that the LLMs are, you know, designed to do. And I think the opportunity for us is to build the bank core to be fully aligned with Agenza Commerce to then, of course, enable incredible user experiences. Yeah. When you think about this agent to commerce, like, what is what is your view of that of that term?
Because I think right now, there's a lot of misunderstandings on what that would be, and there's a lot of, obviously, discussion on, like, what is that form factor when we talk about agent to commerce? Is it people going through ChatGPT and, like, that's the new front end of Amazon, or is this actual, you know, agents and micropayments? Is your kind of view right now and you're kinda impartial to the form it takes, or is this actually, no, where you just need agents to build user experience or actual Look.
I think, you know, if it's if it's a if this and that rule set, that's been around for a while, right, where you can say that, hey. If my account balance dips to here, go, you know, use ACH to bring more money into it. Right? That those are those sweep account capabilities we've been building for many years. I think the when we say agentic, you know, we like we like to think of ourselves as continuous, like the continuous bank. So continuous underwriting. Right? So that how does that happen?
All of it has to be permissioned. But if a CFO or treasurer or individual permissions us to have more and more data on them in real time, we can then as a bank be providing a continuous line of credit, a continuous borrowing power. AgenTech also means that, you know, all of the billions of dollars that are sitting in restricted cash and public balance sheets, they're restricted because they have covenants around it or there's they're they're opaque.
They they're they're tied up in, escrow accounts, lock boxes, collateral. But if those can now be tokenized, we, the bank, can underwrite that. Right? So Okay. As consumers and businesses get more and more comfortable with this idea of tokenizing elements that are in the real world, I think now you have an opportunity to go unlock lower cost of capital, lower credit charges, just kind of a better better access to the capital markets.
We always say The United States' biggest superpower right now is its capital markets, and be making that available more broadly is something that we wanna really kind of pie or we really really stand for. And then, of course, all the things tactically that you said matter as well. Right? Can the core underwrite an agent? Can it verify that there is a human or business owner somewhere up the funnel? Can you make sure that you've got your security and your fraud? Right?
I mean, you can just imagine the the the the many elements of fraud vectors that you have. I mean, we'll sure that our first many engineers are some of the best cybersecurity and sort of infrastructure personnel out there. Right? So I think that really, I think that harness then makes it, from a business model perspective, credible for agents to actually be, introduced into the ecosystem. I don't think we're there yet, by the way, but I think Yeah. And next few That that that's definitely the the consensus.
And I think if one thing that the kind of the rise of stablecoins thought has taught us is that it can happen infinitely faster than a lot of us can can imagine. I'm kind of scanning this, the continuous bank blog that you wrote. And, I I would love what you called out with this plan because I think a lot of our conversations tend to kind of, you know, branch away from The US and get overly indexed towards the emerging markets and and what, fintechs in those markets need to build.
You said you're aiming to build the de facto unified ledger for American companies where credit access to real time underwriting is continuous, access to capital is continuous, and connectivity to the overall American capital markets is real time. Can we unpack that a little bit more? I know we've we've kinda it feels like we've kind of gotten little little bits and pieces of it throughout this conversation, but maybe why the American centric approach, and what has even been the reception like to this?
I imagine you have people in your network that you've done for ten, fifteen years, and everybody's on the spectrum of of blockchain and on chain finance. Like, what is their what what are your conversations like when you're catching up with them and and really pitching them on this on this vision? Yeah. Look. I I think that this idea of continuous it's not that, you know, businesses that already exist in the public markets can't piece together various payment systems to make things available twenty four seven.
Right? There are payment there there are very, very advanced payment systems out there. But the blockchain gives you interesting primitives. Right? So it gives you a stable coin. It gives you the ability to do a tokenized deposit to have different KYC requirements. You know, one is, of course, KYC at Mint and Burn and then can travel in the middle across permissionless wallets. The other one, the tokenized deposit, has to be anyone who holds it has to be KYC ed by the bank.
But if you're a treasurer, if you're a consumer who's fine with that, now you've got your your your store value earning and streaming yield for a portion of time, and it turns into a stable coin where it needs to travel and back into a yield bearing instrument, that potentially has FDIC insurance as well when it comes back. Right? So those primitives then allow, just kind of a different way to think about your workflows. It's much more twenty four seven native.
It's much more, you know, kind of easier access to capital markets. The the American part, right, is look. The the backing of the stablecoin with less than ninety three day treasury reserves as well as cash is, again, you know, for for for different use cases, a pretty interesting value proposition. So someone holds holding, you know, hundreds of millions of dollars may want to elect to have treasuries backing that balance versus FDIC insurance and vice versa.
There may be use cases where the FDIC insurance is a better value proposition. So the ability for us to create a technology product that sits on a regulated bank that allows that interoperability plus with other Genius compliance stablecoins, like, again, as a national bank, we'll have the ability to custody other Genius Act compliance stablecoins, hold it as collateral, lend against it. That lending element, the the ability to form capital, the the ability to form credit really underpins our business model.
And then it goes to any legitimate business, of course, in The States, but across the world, we're working hard to be able to say that you should have access to US denominated currency products, whether it's a Genusact compliant stablecoin or our tokenized deposit. I wanna go into what happens next now because this line really, really jumped out to me. You said we will pioneer forward deployed banking. Now this isn't a this is you know, the idea before forward deployed engineers is is very common to a lot of people.
And, you know, I remember talking to Sinclair from MuralPay. This was a big part of their go to market roadmap, which was deploying these, you know, forward deployed engineers. Unpack, though, what do you mean by forward deployed banking? Is this some is this a new is this a novel concept? Has this a concept that people have tried, but they've kind of failed? It seems like you obviously have the resources with your recent raise led by a 16 z. What do you mean by pioneering forward deployed banking? Yeah. Look.
I think I think everything is a forward deployed something or another, so I I do kind of take the the the tongue in cheek on that one. But look, when we say forward deployed banker, we we think of a solutions team that is multifaceted. Right? Of course, engineers are super important to integrations, to APIs, to making sure, you know, our 600 endpoints and our APIs are understood by our clients.
But but but that team, again, is where, like, you know, you know, Ben Yaff was talking about this at Salesforce is that when you have agents involved, a client of ours can very quickly get ramped up to our full superpower set as opposed to using one API for a month, another API for the second month, the third API the sixth month. You're only using 5% of our capabilities.
But if there was a four deployed banking team that consisted, of course, of an engineer who wonder who is very fast in APIs, but also of, you know, a tax person who wonder who who who helped our capital markets clients really understand the tax implications. A legal person who got all of the legal paperwork because, at the end of the day, it it it is banking. Right? So there will be counterparty risk. There will be multi party tripartite agreements in place.
So you do need kind of, you know, a a full team, compliance, legal, product, operations. So instead of doing that sequentially, when we say forward deployed bankers, we wanna make that atomic using d five parlance. Right? So as soon as one of our clients get introduced to us, we wanna kind of bring that swarm of capabilities of Open Reserve. We think we're building a API set that's quite unique and it's quite full.
And we wanna basically use that for deployed banking banking team to help our clients get integrated and using all of our capabilities as soon as possible. Right? So it's again client success, Delivery becomes the KPI there in terms of, hey. Can we get are you are are are clients using our products faster? And why this is lacking value for them, of course. So what's your timeline? Right? Like, you know, wanna move fast, go to market. It's exciting.
I mean, you've been sitting on this for, you know, a few few months now, though. Yeah. Like, what's your what's your timeline for success? I think I saw in a few posts kind of forward looking the the bank of 2030. You know, 2030 is now now four years away. What are what are your some of your expectations for yourself? Obviously, this isn't your first rodeo, so I imagine you there there's this balance of being patient and having conviction while wanting to hit the ground. Where do you kinda land right now?
It's a good question. Look. So Open Reserve Bank is an organization, so we've just gotten the first milestone with the OCC. We have a a preopening exam that we have to conduct with them, so we'll go through that process. We, you know, have to make sure we get through the approval process with the FDIC, the Federal Reserve. So there's a bunch more work to do on the regulatory side. Our team is working very hard to go get that done. We've got we put a great team together around this.
And, look, we're we we look to be 11, you know, as soon as we can, but, you know, think of it as as, you know, 2027. Early twenty twenty seven is kind of like we're targeting in terms of being in market and taking clients. And then after that, we're we're also getting a broker dealer. Right? So that's also in process. When we say when we say continuous banking, we believe that broker dealer is an important regulatory perimeter. There are things that the broker dealer ought to do that the bank can and cannot do.
And the interconnectivity of that, in a very kind of regulatory copacetic way, we think give significant superpowers to treasurers, CFOs, capital markets participants. And, of course, all of that is being built on one common tech stack, which is I think the coolest and most exciting part of it is because in that stablecoin becomes a mode of transport that's really, really, you know, native to borrowing, lending, deposit yield, you know, kind of producing features across, the the two substrates.
So we look to have all of that, kind of legal and regulatory work done by the end of the year and then, really kind of getting into market in 2027. Awesome. Mark, sorry. The last question here before we we wrap up. We interview a ton of neobank founders. What would you say to that first time founder that's building a neobank, you know, in 2026 after, you know, going through the gambit, you know, scaling MoneyLion to what it is today? Maybe two part question. What would you say to them personally as a founder?
And and then two, how how should they work with openers or mean, get on your get on your wait list? Yeah. Look. I I think that, it's a very novel, and noble endeavor. What I have learned is that, just to say that, hey. That already exists because some incumbent is doing it or some public company is doing it, is the wrong way to look at it. I think you should be incredibly excited to build, in fintech and in financial services right now because companies have evolutions. They have, innovator's dilemma.
They have arcs of, you know, a lot of the founder led ones have a lot of passion that I I I I truly believe in, you know, visionary founders, and they have, really kind of unequal or very differentiated ways to motivate people, especially the visionary ones. And what I've seen with public companies is sometimes when the founders leave and you've got a different kind of, class of folks that are running those businesses, they lose their innovation edge. Right?
So the number of products you're releasing, the number of things you're bringing to market, are really important, and I think that's a superpower. Niavete is a superpower. Right? So bringing new ways to market in an industry that only markets a single way is a superpower. We brought when when I started Moneyline, people only used to do direct mark direct mail for acquiring loan customers.
We started doing, you know, ads on Facebook and then Instagram and then so on and so forth, and, you know, we were able to undercut. So so so kinda like bringing, you know, modes of, customer acquisition or SOPs from other industries into financial services always sometimes leads to outsized growth, which is which is great. But that said, look, you know, it is highly competitive. There's a lot of compliance and regulations.
You have to be able to spend the money on the best team around product and tech and compliance. The consumers, either consumers or businesses have very low tolerance for mistakes. Right?
So I I would never discourage anyone to build a neobank, but I would the one piece of advice I would give is make sure you're properly capitalized and make sure that, you know, you're not necessarily taking shortcuts or cutting corners on, you know, being at least parity at least parity with the middle with the median bank, if you will, out there.
Because, you know, when when you have, those types of hiccups, it creates you know, just like you have, founders have undue influence in these companies in a a positive way, it's high it's it's it's the same on the way down. Right? It's you you have your best people starting to leave, and it just creates these death spirals as well. So I think that that that's probably what I would say for my thirteen years now of, building in this space. Awesome. Well, we appreciate it, D. A.
We love, getting into the more personal side of building scaling companies, especially passing the torch off to the, the next generation. So, we'd love to catch up with you in the next We'll We'll we'll be open for, business, soon, but, you know, happy to have conversations with anyone on just kind of, really, just thinking through products. Awesome. Thanks, Dee. Appreciate you coming. Thanks, man. Great to meet you. Appreciate it. Bye.




