The single most useful fact about US neobanks is that they split into two structurally distinct categories, and the category your provider sits in decides how your money is protected if the fintech itself fails. Chartered neobanks hold their own bank licence — usually a national bank charter granted by the Office of the Comptroller of the Currency (OCC), or in some cases a state-bank charter from a state banking department such as the New York DFS or California DFPI. Partner-bank neobanks (also called sponsor-bank or BaaS-model neobanks) do not hold a charter themselves; they operate as fintechs that route customer deposits to one or more FDIC-insured partner banks under a Banking-as-a-Service contract.
Of the five providers in this ranking, two are chartered: SoFi received its OCC national bank charter on 18 January 2022 by acquiring the small California community bank Golden Pacific Bancorp and folding its operations into a new entity, SoFi Bank, N.A. Varo went the harder route — a de-novo OCC charter granted in 2020, the first time a US consumer fintech had received one. Both can offer FDIC coverage directly, on their own balance sheet, with the same legal mechanics that apply at Chase, Wells Fargo, or any traditional national bank.
The other three operate the partner-bank model. Chime routes deposits to The Bancorp Bank, N.A. and Stride Bank, N.A. Cash App uses Sutton Bank for its debit-card sponsor and Wells Fargo for ACH and brokerage cash. Mercury uses Choice Financial, Evolve Bank & Trust, and Patriot Bank, layering an IntraFi Cash Sweep network on top to extend coverage past the standard $250,000 ceiling.
In day-to-day usage the two models look identical — same app, same debit card, same FDIC logo on the website. The differences surface in three places. First, the legal counterparty on your account agreement: at SoFi or Varo it is the chartered bank itself; at Chime or Cash App it is the fintech, with the partner bank named as the depository institution. Second, the failure mode: if SoFi Bank, N.A. were to fail, the FDIC would pay out directly on its records; if a partner-bank neobank failed but its sponsor banks were healthy, customer funds would remain at the partner bank and the FDIC would not need to step in at all (assuming beneficial-ownership records were correctly kept — which is itself a regulated process under FDIC Part 370). Third, the aggregation rule: the $250,000 ceiling applies per depositor per insured bank, which means if you hold balances at two different fintechs that share the same partner bank (say, two Bancorp-sponsored fintechs), the limits combine into a single $250,000 cap.
The Consumer Financial Protection Bureau (CFPB) does not draw the chartered-vs-partner distinction in its consumer-facing guidance — it regulates conduct (Reg E error-resolution, Reg DD truth-in-savings, Reg Z lending disclosures) at every provider equally. The Federal Reserve supervises bank holding companies but does not directly licence consumer fintechs. The OCC supervises national banks, including SoFi Bank and Varo Bank. The FDIC insures deposits at both, on a per-bank basis. The result is a multi-regulator stack where readers benefit from knowing which regulator does what — a reality we take pains to surface in every per-bank review rather than wave the generic "FDIC-insured" badge.