Erebor Bank: Peter Thiel and Palmer Luckey's bank under the mountain

Erebor Bank, N.A. is a U.S. national bank that opened in February 2026 — the first American bank in years chartered from scratch for the technology sector, and the first whose stablecoin operations are written into a regulator-approved business plan. Behind it stand Palmer Luckey, Peter Thiel's Founders Fund and Joe Lonsdale's 8VC; by mid-2026 the bank holds roughly $4B in deposits and, per Bloomberg, is discussing a new round at a valuation of $8B or more. For international business, Erebor matters less for its shareholders than for its function: a new settlement institution in the dollar system with an explicit digital-asset mandate — including as the SWIFT correspondent behind HEVN, the fintech platform we curate.

The niche after SVB

The collapse of Silicon Valley Bank in March 2023 left the technology sector without a dedicated settlement bank. In parallel, mainstream banks had spent years de-risking crypto clients: accounts were closed under internal risk policies, and even a sound business with digital assets in its payment history remained an unwelcome client for compliance. New banking licences, meanwhile, had become rare: a de novo charter approval was an exception, and the path to one was measured in years.

By 2025 all three factors had reversed. The new administration appointed Jonathan Gould as Comptroller of the Currency with a course set on chartering new banks, and in July 2025 the GENIUS Act — the first federal stablecoin statute — established the framework for their issuance and circulation. Erebor's application, filed in June 2025, landed precisely on that turn and became its most visible test.

What Erebor is

Erebor Bank, N.A. is a fully digital, branchless national bank: headquartered in Columbus, Ohio, with administrative offices in New York and Newport Beach, California. The name is Tolkien's: Erebor, the Lonely Mountain, the dwarven kingdom and its treasure hoard. For the founders' circle this is an established naming tradition — Palantir, Anduril, Mithril Capital, Valar Ventures.

Shareholders and governance

The capital came from Palmer Luckey (founder of defense company Anduril, previously Oculus), Peter Thiel's Founders Fund and Joe Lonsdale's 8VC; Alexis Ohanian's Seven Seven Six invested pre-launch. The late-2025 round was led by Lux Capital, with Founders Fund, 8VC and Haun Ventures participating; Bloomberg also names Andreessen Horowitz among the bank's investors.

Day-to-day management is separated from the shareholders. The co-CEOs are Owen Rapaport (co-founder of compliance platform Aer Compliance) and Jacob Hirshman (previously an adviser to Circle, the USDC issuer); the president is Michael Hagedorn, a banker with a career at Wells Fargo, UMB Financial and Valley National Bank; Trevor Capozza acted as organizer and serves as an independent director. The combination of stablecoin expertise and classical banking management in the leadership mirrors the bank's model itself.

Business model and clientele

Erebor defines its segment as the "innovation economy": companies in digital assets, AI, defense and aerospace, advanced manufacturing, their founders and investors — and, as a separate line in the application, non-US companies that need access to the U.S. banking system. In substance the bank took over SVB's niche as the technology sector's settlement house, but with a fundamentally different risk model.

The stated model is deliberately conservative. Palmer Luckey put it plainly: "we'll have the most conservative loan-to-deposit ratios of any bank in history." The first call report bore this out: $1.1B of deposits in the first seven weeks, only about 23% of them uninsured — against ~90% at SVB on the eve of its collapse. A low share of uninsured deposits is the key structural argument against the run scenario that destroyed SVB.

What distinguishes Erebor from a conventional bank is the stablecoin block of its business plan: the bank takes deposits and settles in stablecoins, plans to hold them on its own balance sheet, to mint and burn them, to provide fiat ↔ stablecoin conversion, and to lend against digital-asset collateral. The publicly stated goal is to become "the most regulated entity conducting and facilitating stablecoin transactions."

Regulatory trajectory

The application moved at a pace without recent precedent: filed with the OCC in June 2025; preliminary conditional approval on October 15, 2025 — the first de novo bank approved under Comptroller Gould; FDIC insurance approval in December 2025; full national charter and start of operations in early February 2026. From filing to a working bank took about eight months, against the multi-year timelines typical of the previous decade.

The conditional approval came with heightened requirements. Erebor must maintain a Tier 1 leverage ratio of at least 12% for its first three years — well above standard supervisory expectations — obtain the regulator's written non-objection for senior executive appointments and material deviations from the business plan, appoint an external auditor and stand up BSA/AML and cybersecurity risk frameworks; launch was preceded by a pre-opening examination. One detail matters for practice: the OCC allowed the bank to hold small amounts of crypto assets on its balance sheet to pay network (gas) fees as "incidental" to banking — a precedent the market already cites.

Erebor also stands apart from the broader wave of crypto charters. In December 2025 the OCC conditionally approved five national trust banks at once (Circle's and Ripple's entities de novo; BitGo, Fidelity Digital Assets and Paxos as conversions), followed by Coinbase's trust charter in April 2026. But a trust charter is a limited licence: custody and fiduciary services, without insured deposits or lending. Erebor is a full-service insured bank — and in that capacity it has, for now, no direct peer in the crypto segment.

Key metrics

Criticism and supervisory questions

The pace of licensing did not escape Congress. In late February 2026 Senator Elizabeth Warren — ranking member of the Senate Banking Committee — sent letters to Comptroller Jonathan Gould, FDIC Chairman Travis Hill and Palmer Luckey. She requested the full unredacted application and related correspondence, citing among other things Erebor's fundraising memo, which listed the project's "political network" and "unique connectivity to banking regulators" as advantages. Her position: if the charter was granted in violation of law and procedure, it should be terminated.

The bank and its supporters respond that the process was public and the conditions heightened rather than relaxed: the 12% leverage requirement, non-objection rights over key decisions, a conservative deposit structure. The dispute has no effect on operating status: the charter is in force, the bank operates and continues to raise capital. For a client this is above all a supervisory and political storyline, not a question of settlement reliability.

Investor access

Erebor is a private company: no public shares, no announced IPO. Qualified investors have a secondary market: shares from early investors and employees trade on Forge, EquityZen, Hiive and Nasdaq Private Market.

Indirect public exposure appeared in March 2026, when the Fundrise Innovation Fund (NYSE: VCX) — a listed closed-end venture fund holding Anthropic, Databricks, OpenAI and SpaceX — announced an investment in Erebor. Through VCX even a non-accredited investor can buy into that basket; Destiny Tech100 (DXYZ) follows a similar logic. The structure deserves sober assessment: closed-end funds of this type trade at a substantial premium to NAV — after short-seller Citron's March report VCX fell roughly by half intraday — and Erebor is in any case a small position in the portfolio rather than a direct bet on the bank.

Erebor in private.law practice

For our clients Erebor is not a headline but a working correspondent: it holds the SWIFT corridor of HEVN, the fintech platform we curate. Behind the global dollar account opened on the private.hevn tier stands a well-capitalized U.S. bank with a national charter, FDIC insurance and a dedicated digital-asset mandate. We handle access to this infrastructure — including onboarding with a reliance opinion from our solicitor; the starting point is private.law/hevn.