Florida Banking April/May 2026

Built From the Ground Up A Decade of De Novo Leadership in Florida Banking By Suellen Wilkins, Director of Marketing & Communications

I n the years following the financial crisis, the idea of launching a new community bank bordered on the improbable. The Administration has recognized that “a Main Street revival starts with a community bank comeback,” in Secretary of the Treasury Scott Bessent’s words — and Florida is leading the way! Over the past decade, Florida has emerged as one of the nation’s leaders in post-crisis de novo bank formation. These institutions were built in one of the most highly regulated and capital-intensive banking environments in modern history. Their founders navigated lengthy charter processes, rigorous supervisory expectations and demanding capital thresholds — all while convincing investors, regulators and communities that a new bank could not only survive, but thrive. For this cover story, Florida Banking magazine spoke with the organizers, CEOs, legal advisors and policy experts who have shaped Florida’s de novo resurgence. Their stories reveal a consistent truth: successful de novo banks are not born of opportunity alone. They are built on disciplined capital planning, patient execution, experienced leadership and an unwavering commitment to community. A Post-Crisis Landscape Florida was among the states hardest hit by the Great Recession, losing 70 bank charters from 2008 to 2013. As consolidation accelerated, the absence of locally focused institutions left noticeable gaps in many markets. “The formation of new banks is essential to maintaining a competitive marketplace,” says Terry Hughes, FBA Senior Vice President of Membership. “As consolidation through mergers and acquisitions continues, de novos help ensure consumers and small business owners continue to have access to locally focused financial services.” Nationally, however, the path to forming a new bank became more difficult than ever. In his remarks before the Fed Community Bank Conference on Oct. 9, 2025, Secretary Bessent said, “The post-crisis framework has left a trail of destruction in its wake by reinforcing the larger economic dynamics that have hollowed out

the American heartland while enriching the money centers in coastal cities. To be clear, the financial crisis underscored the need for new regulations. The purpose of Dodd-Frank was to end ‘too big to fail.’ But it ended up creating ‘too small to succeed.’ These new regulations entrenched the dominance of the largest banks by rewarding economies of scale and necessitating effective lobbying operations in Washington. What followed was a community bank bottleneck that left America’s hometowns reeling.” Since 2010, the United States has lost 3,600 community banks, a reduction of over 45 percent. Further, new bank formations have slowed to a trickle — averaging just six new banks per year since 2010 as compared to over 100 a year prior to 2008. Regulators tightened expectations, capital requirements climbed, and the industry absorbed wave after wave of consolidation. Mickey Marshall, VP & Regulatory Counsel at ICBA, notes the slowdown reflects both economic and regulatory realities. “The process of applying for a charter remains costly and time consuming,” Marshall explains. “Banks in formation can wait months or even years for approval, during which time market conditions can materially change.” Capital requirements represent the most significant barrier. Regulators expect new banks to raise significant capital all up front before opening, along with maintaining elevated capital levels during their early years. At the same time, de novos must demonstrate compliance — before they can be approved to open — with the full spectrum of banking laws from BSA/AML and fair lending to the Community Reinvestment Act. To get a charter requires significant capital outlay. “One of the main challenges,” Marshall adds, “is that regulators have taken the view that the acceptable failure rate for banks is zero. That has driven higher capital expectations and increased supervisory focus.” The result is a paradox: fewer banks are formed, and those that make it through the process must be incredibly conservative. They tend to be exceptionally well capitalized, carefully structured and strategically disciplined.

Mickey Marshall

Terry Hughes

6 | FLORIDA BANKING