Diligence report Financial Services / de novo national bank / digital-asset-adjacent banking Private unicorn; newly chartered FDIC-insured de novo national bank

Erebor Bank, N.A.

Erebor Startup Diligence Research Report

Erebor could become a regulated banking platform for AI, defense, payment, investment, and virtual-currency-adjacent customers after the post-SVB startup-banking gap; public support rests on regulatory approvals and investor backing, not disclosed operating traction.

Company profile

Erebor Startup Diligence Research Report

Eligible public-source unicorn report: CB Insights lists Erebor at a $4.35B valuation and public OCC/FDIC/company records show an active, federally insured de novo bank. Investment diligence should remain gated on private financial, customer, regulatory, and legal data.

Website: erebor.bank
Sector: Financial Services / de novo national bank / digital-asset-adjacent banking
Geography: United States; main office Columbus, Ohio; CB Insights city San Francisco; administrative offices New York, New York and Newport Beach, California
Stage: Private unicorn; newly chartered FDIC-insured de novo national bank
Known aliases: Erebor, Erebor Bank, Erebor Bank, NA, Erebor Bank, N.A., Erebor Group, Inc., EGI, Atticus Digital, Inc.
Report version: 1.0
Timezone: America/New_York

Executive summary

Strengths

CB Insights lists Erebor as a $4.35B U.S. Financial Services unicorn.
OCC and FDIC public documents verify national-bank charter/deposit-insurance approvals subject to conditions.
Regulator documents verify the intended deposit/lending and innovation-economy/virtual-currency target-market strategy.

Risks

No public financials or operating metrics.
De novo bank launch and capital-condition execution risk.
Political/regulatory-process scrutiny from Senate oversight letter.
Digital-asset compliance and operational risk.
High valuation without public traction proof.

Gaps

Audited financials, projections, cap table, and regulatory capital model.
Customer/deposit/loan concentration, pipeline, churn, and references.
Product pricing, security architecture, vendor stack, and usage metrics.
Regulator correspondence, conditions tracker, counsel letters, and litigation/IP searches.
Formal org chart, compensation, turnover, and background checks.

Recommended next steps

Do not rely on public valuation alone; request full financing and operating data room.
Prioritize regulator/counsel review of OCC/FDIC conditions and Senate inquiry.
Run customer-reference diligence and deposit/loan concentration analysis.
Complete bank-grade cyber/vendor/BSA/AML/CRA diligence.
Benchmark valuation against deposits, NIM/fee revenue, credit quality, and comparable fintech/bank metrics.

Risk register

high high likelihood

R-001: Public financial opacity

No public audited financials, deposits, loans, revenue, unit economics, backlog, AR aging, burn, or projections.

Diligence request: Require audited financials, management accounts, deposit/loan balances, revenue by product, burn, runway, and projections.

high medium likelihood

R-002: De novo bank execution and capital-condition risk

Erebor must execute a regulated de novo bank launch while satisfying OCC/FDIC conditions and capital requirements.

Diligence request: Review conditions tracker, capital-call agreement, regulatory correspondence, and launch milestones.

high medium likelihood

R-003: Digital-asset compliance and operational risk

Virtual-currency market participants and gas-fee holdings heighten BSA/AML, sanctions, custody, fraud, and operational-control risk.

Diligence request: Request BSA/AML, sanctions, digital-asset, custody/vendor, and transaction-monitoring controls.

high medium likelihood

R-006: Political and regulatory-process scrutiny

Senate oversight allegations could create reputational, legal, and supervisory burden even if not substantiated.

Diligence request: Request counsel analysis, OCC response, congressional correspondence, and board discussion materials.

high medium likelihood

R-009: Bank-grade privacy, cyber, and data-security exposure

Terms indicate sensitive financial, identity, transaction, and employment data collection.

Diligence request: Request SOC/ISO evidence, FFIEC cyber assessment, pen tests, vendor-risk inventory, incident history, and cyber insurance.

high unknown likelihood

R-004: Valuation versus unproven operating traction

$4.35B valuation is public, but revenue, deposits, credit performance, and customer adoption are not.

Diligence request: Benchmark valuation against verified operating metrics and comparable fintech/bank multiples.

medium high likelihood

R-005: Unverified demand and customer concentration

Target segments are public but named customers, concentration, churn, and references are not.

Diligence request: Request customer ledger, pipeline, concentration, churn, affiliated-customer flags, and reference calls.

medium high likelihood

R-008: Product and pricing opacity

Public sources disclose categories but not live SKUs, pricing, rates, underwriting, SLAs, or product usage.

Diligence request: Request product catalog, pricing, customer contracts, usage, and win/loss analysis.

Chapter 01

01Financial Information

Erebor meets public unicorn eligibility, but financial diligence is sparse beyond financing reports and regulatory capital conditions.

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I.A Annual and quarterly financial information for the past three years

not publicly verifiable confidence: high

No public income statements, balance sheets, cash flows, sales breakdown, backlog, or AR aging were found.

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Evidence gaps

Audited statements, management accounts, KPI dashboards, AR aging, backlog.

Hidden risks

No audited financials or operating metrics; valuation cannot be underwritten publicly.

Follow-up questions

Provide audited financials, monthly accounts, KPI dashboard, deposits, loan tape, AR and backlog.

Public financial and unit-economic signals
Metric	Public value	Status	Why it matters	Private request
Revenue/ARR	Not disclosed	not_publicly_verifiable	Valuation support	Revenue by product/customer
Deposits/loans	Not disclosed	not_publicly_verifiable	Bank scale/risk	Daily balances and loan tape
Burn/runway	Not disclosed	not_publicly_verifiable	Financing risk	Cash, burn, runway
Tier 1 leverage condition	Minimum 12% first three years	verified	Growth constraint	Current ratio model
Backlog/AR aging	Not disclosed	not_publicly_verifiable	Demand/working capital	Backlog and AR schedules

I.B Financial Projections

not publicly verifiable confidence: high

No public projections, scenario assumptions, pricing policies, capex, working capital, or financing assumptions were found.

Evidence gaps

Three-year plan, regulatory capital model, scenarios.

Hidden risks

Forecast risk is high due new bank launch and capital requirements.

Follow-up questions

Provide quarterly projections by product/customer/channel, balance sheet, cash flow, and scenarios.

I.C Capital Structure

partially verified confidence: medium

Public sources identify some investors and regulatory capital conditions, but not share counts, full cap table, options, warrants, debt, or liabilities.

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Evidence gaps

Cap table, option ledger, debt/warrant/SAFE schedule.

Hidden risks

Unverified cap table, preferences, and capital-call obligations.

Follow-up questions

Provide pro forma cap table, financing documents, investor rights, debt instruments, option ledger.

Capital structure and ownership snapshot
Stakeholder/Instrument	Public position	Evidence	Diligence caveat
Lux Capital	Lead/select investor	CB and OhioTech	Rights and ownership unknown
8VC	Select/participant investor	CB and OhioTech	Ownership unknown
Founders Fund	Reported backer	OhioTech and BI	Verify in cap table
Haun Ventures	Reported participant	OhioTech	Verify amount/rights
Equity incentive/options	OCC references employee stock options	OCC letter	Plan size and dilution unknown
Debt/bank lines	Not public	Public gap	Request debt and off-balance-sheet liabilities

I.D Other financial information

partially verified confidence: medium

Financing history and valuation are partly public; tax, accounting policies, revenue recognition, and financing ledgers are not.

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Evidence gaps

Tax positions, accounting policies, financing ledgers.

Hidden risks

Reported valuation may not reflect operating fundamentals.

Follow-up questions

Provide financing history, tax memos, revenue-recognition policy, current basis by round.

Public funding-round and valuation history
Date	Event/Round	Amount	Valuation	Investors	Status	Source
2025-07	BI reported raise in process	$225M target	$2.0B	Founders Fund, 8VC	partially_verified	BI
2025-12-22	CB unicorn row	not disclosed	$4.35B	Lux Capital, 8VC	verified	CB Insights
2025-12-23	Reported financing	$350M	$4.35B	Lux led; Founders Fund, 8VC, Haun, others	partially_verified	OhioTech/Axios

Financing documents not public.

Funding and regulatory milestone timeline Known financing, charter, insurance, and active-site milestones.

Public valuation trajectory Bar chart of public valuation anchors.

Chapter 02

02Products

Public records verify planned bank product categories and account workflow signals; maturity, pricing, and economics remain private.

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II.A Description of each product

partially verified confidence: medium

Regulators verify intended deposits, lending, related services, and virtual-currency-adjacent activity; SKUs, pricing, usage, and roadmap remain private.

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Evidence gaps

Product catalog, pricing, roadmap, security evidence, usage metrics.

Hidden risks

Product maturity, pricing, cyber controls, and gross margins are opaque.

Follow-up questions

Provide demos, SKU matrix, fee schedule, lending/deposit terms, roadmap, SOC/security evidence.

Product and service matrix
Product/Capability	Audience	Public evidence	Status	Gap
Deposit accounts	Tech/payment/investment/defense/virtual-currency customers	FDIC/OCC/homepage	partially_verified	Terms, balances, concentration
Lending products	Target businesses and individuals	FDIC/OCC	partially_verified	Underwriting, pricing, loan tape
Virtual-currency gas fees	Virtual-currency users	OCC gas-fee discussion	verified	Controls and custody scope
Account notifications	Account holders	Messaging terms	partially_verified	Workflow demos and usage
Branchless model	National innovation economy	CRA plan	verified	CRA implementation

Pricing comparison and visibility
Provider	Public signal	Erebor comparison	Status	Request
Erebor	No public pricing page; sign-in only	Unknown pricing	not_publicly_verifiable	Fee/rate sheets
Mercury	Startup business banking, treasury, cards, payments	Startup-banking alternative	verified	Win/loss comparison
Brex	Cards, banking, expenses, treasury	Finance-stack alternative	verified	Compare yields/limits
Arc	Cash, yield, debt, AI finance	Treasury/capital alternative	verified	Compare treasury/debt economics
Anchorage	Federally chartered crypto bank	Digital-asset alternative	verified	Compare custody/crypto scope

Public product and dependency architecture High-level product/dependency map from public documents.

Chapter 03

03Customer Information

Target customer segments are clear, but named customers, revenue concentration, churn, and supplier concentration are not public.

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III.A Top customers by application

not publicly verifiable confidence: high

Target segments are public but no named customers or top-15 schedule is public.

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Evidence gaps

Top-15 customers by application, deposits, loans, revenue, references.

Hidden risks

Customer adoption and concentration cannot be assessed publicly.

Follow-up questions

Provide named/anonymized top customer list, contracts, balances, and references.

Public customers and target segments
Customer/Segment	Public evidence	Use case	Status	Request
Named customers	None found on public site/news reviewed	Unknown	not_publicly_verifiable	Top-15 customer list
Technology companies	OCC/FDIC target	Deposits/lending	verified	Signed customers
Payment systems	FDIC target	Banking/payments	verified	Volumes/compliance
Defense/manufacturing	FDIC/OhioTech target	Credit/treasury	partially_verified	Pipeline
Virtual currency/UHNWI	OCC/FDIC target	Crypto-adjacent banking	verified	BSA/AML files

III.B Strategic relationships

partially verified confidence: medium

Regulators and investors are public strategic dependencies; commercial partner economics are not.

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Evidence gaps

Revenue contribution, marketing agreements, intercompany and related-party terms.

Hidden risks

Related-party and regulatory dependencies may be material.

Follow-up questions

Provide strategic partner agreements, related-party schedule, vendor contracts, regulatory correspondence.

Strategic relationships and partnerships
Relationship	Nature	Evidence	Gap
OCC	Primary charter regulator	Approval and CRA documents	Conditions/correspondence
FDIC	Deposit insurance	FDIC release	Approval-order compliance
Federal Reserve	Stock/application expectation	OCC letter	Membership/account status
Atticus Digital	Wholly owned subsidiary after merger per OCC	OCC letter	Intercompany/IP docs
Venture investors	Lux, 8VC, Founders Fund, Haun reported	CB/Ohiotech/BI	Related-party controls

III.C Revenue by customer

not publicly verifiable confidence: high

No revenue/deposit/loan concentration or 5%+ customer schedule is public.

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Evidence gaps

Revenue/deposit/loan concentration, affiliated-customer exposure, churn.

Hidden risks

Early revenue/deposit base may be concentrated.

Follow-up questions

Provide concentration schedule with related-party flags and retention cohorts.

Public customer and partner evidence coverage Bar chart showing customer evidence categories.

III.D Significant relationships severed within the last two years

not publicly verifiable confidence: low

No severed customer, partner, or supplier relationship was public.

Evidence gaps

Terminated customers/suppliers, default notices, dispute history.

Hidden risks

Hidden terminations could signal product or compliance issues.

Follow-up questions

Provide severed relationship log, termination notices, and impact analysis.

III.E Top suppliers

partially verified confidence: low

Privacy notice identifies vendor categories and Google Analytics; critical core vendors are not named.

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Evidence gaps

Top supplier spend, critical vendors, contracts, SOC reports, exit plans.

Hidden risks

Unknown core banking, cloud, payment, fraud, and security dependencies.

Follow-up questions

Provide vendor inventory, top-supplier spend, SOC reports, SLAs, exit plans.

Supplier and infrastructure dependency snapshot
Supplier/Dependency	Role	Evidence	Risk	Request
Google Analytics	Web analytics	Privacy notice	Privacy/vendor dependency	DPA/vendor file
Service providers	Hosting, analytics, marketing, payments, fraud	Privacy notice	Potentially material	Vendor inventory
Atticus Digital	Subsidiary/technology dependency	OCC letter	Unknown criticality	Merger/IP docs
Core banking/payment processors	Not identified	Public gap	Potentially critical	Contracts/SOC/exit plan
Cloud infrastructure	Not identified	Public gap	Potentially critical	Architecture/resilience

Chapter 04

04Competition

Erebor enters a crowded innovation-finance market with startup banking, treasury, finance-software, and crypto-bank alternatives.

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IV.A Competitive landscape by market segment

partially verified confidence: medium

Erebor competes across startup banking, treasury, finance software, and institutional crypto banking; market share and win/loss are not public.

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Evidence gaps

Market share, win/loss, pricing, switching costs, customer overlap.

Hidden risks

Incumbents may own stronger mindshare and broader product breadth.

Follow-up questions

Provide competitive win/loss, pricing benchmarks, market share, and customer overlap.

Competitor comparison matrix
Company	Segment	Positioning	Overlap	Differentiator	Source
Erebor	De novo national bank	Full-service insured innovation bank	Target	Charter plus digital-asset focus	OCC/FDIC
Mercury	Startup banking	Business banking for startups	Deposits/treasury	Established startup brand	Mercury
Brex	Finance software/cards/banking	Modern cards, banking, expenses	Cards/treasury	Global finance software	Brex
Arc	Cash management/debt	Cash, yield, debt, AI finance	Treasury/capital	AI/debt focus	Arc
Anchorage	Crypto bank/custody	Federally chartered crypto bank	Digital assets	Custody/qualified custodian	Anchorage

Basis-of-competition scoring
Axis	Erebor position	Benchmark	Implication	Evidence
Regulated-bank status	Strong public approvals	Anchorage also chartered; others often platform-led	Moat and burden	OCC/FDIC
Startup mindshare	Early LinkedIn signal	Mercury/Brex broader public brands	Need references	LinkedIn/competitors
Digital-asset focus	Explicit virtual-currency participants	Anchorage deep crypto; Mercury web3	Differentiate carefully	OCC/competitors
Product breadth	Categories only	Competitors market broad stacks	Product gap risk	Websites
Pricing transparency	Low	Competitors disclose product benefits	Hard to underwrite conversion	Public pages

Competitive positioning market map Positioning of Erebor and competitors.

Chapter 05

05Marketing, Sales, and Distribution

GTM appears built around regulatory trust, branchless digital access, investor networks, and awareness; funnel economics are undisclosed.

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V.A Strategy and implementation

partially verified confidence: medium

GTM evidence consists of digital access, regulatory credibility, LinkedIn, news, and investor networks; channel economics are private.

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Evidence gaps

Channel mix, CAC, marketing budget, territories, conversion.

Hidden risks

Trust signals may not convert to scalable acquisition.

Follow-up questions

Provide GTM plan, channel attribution, CAC/payback, marketing budget, launch calendar.

Distribution channels and GTM motions
Channel	Public evidence	Likely role	Status	Gap
Digital portal	Homepage sign-in	Customer access	partially_verified	Conversion metrics
Regulatory credibility	OCC/FDIC/Member FDIC	Trust signal	verified	Pipeline effect
Investor network	Lux/8VC/Founders Fund/Haun reported	Portfolio access	partially_verified	Conflicts/concentration
LinkedIn/social	7,280 followers and final-approval post	Awareness	verified	Engagement quality
Branches	No physical branches	Digital model	verified	CRA access

Public marketing-signal summary
Signal	Value	Interpretation	Status	Follow-up
LinkedIn followers	7,280	Awareness signal	verified	Growth and lead attribution
LinkedIn employees	78; size 51-200	Early operating scale	verified	HRIS roster
Open roles	0 LinkedIn/Ashby	Hiring signal ambiguous	verified	Hiring plan
Website	Minimal homepage/sign-in	Stealth/limited launch	verified	Launch calendar
News/PR	OCC, FDIC, OhioTech, BI	Regulatory/investor narrative	partially_verified	Owned PR plan

V.B Major Customers

not publicly verifiable confidence: high

Major customer status, growth prospects, and pipeline are not disclosed.

Evidence gaps

Major-customer status, pipeline, references, expansion plans.

Hidden risks

Demand, retention, and upsell are unverified.

Follow-up questions

Provide pipeline by stage, signed LOIs/contracts, expansion plans, references.

V.C Principal avenues for generating new business

partially verified confidence: medium

Likely channels include investor networks, direct onboarding, regulatory trust, and sector outreach; quantitative mix is not public.

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Evidence gaps

Lead sources, affiliated customer percentage, conversion, sales cycle.

Hidden risks

Overdependence on affiliated networks could create concentration/conflicts.

Follow-up questions

Provide lead-source report, channel conversion, affiliated-party controls, partner agreements.

Public GTM funnel coverage Funnel with public anchors and unknown conversion stages.

V.D Sales force productivity model

not publicly verifiable confidence: high

Sales compensation, quotas, cycle, productivity, and hiring plan are not public.

Evidence gaps

Sales roster, quotas, comp, cycle length, win rates.

Hidden risks

Unknown productivity and onboarding cycle challenge forecasts.

Follow-up questions

Provide sales model, quotas, comp plan, CRM extract, hiring plan.

V.E Ability to implement marketing plan with current and projected budgets

not publicly verifiable confidence: high

Marketing budget is not public; reported financing gives resources but not allocation.

Evidence gaps

Marketing budget, CAC/payback, vendor spend, campaign ROI.

Hidden risks

Large funding may mask inefficient acquisition or compliance-heavy onboarding.

Follow-up questions

Provide budget-to-actual marketing spend, channel ROI, CAC/payback, GTM headcount plan.

Chapter 06

06Research and Development

Leadership signals show technology/product/risk/credit roles, but R&D organization, roadmap, architecture, and controls need data-room review.

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VI.A Description of R&D organization

partially verified confidence: medium

Public leadership signals identify CTO/product/risk/credit leaders; engineering org, architecture, velocity, and controls are private.

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Evidence gaps

Engineering org chart, roadmap, SDLC, architecture, security controls.

Hidden risks

Complex regulated products require mature engineering and controls.

Follow-up questions

Provide R&D org, roadmap, SDLC/security controls, architecture, incident history.

Key R&D/product personnel
Name	Role	Background signal	Source	Caveat
Aaron Pelz	Co-founder/CTO	CTO reported	BI	IP/architecture ownership unknown
Owen Rapaport	Co-founder/co-CEO	Product, credit, customer success focus; Aer Compliance background	BI	Confirm scope
Jacob Hirshman	Co-founder/co-CEO	Sales, marketing, regulatory focus	BI	Confirm governance
Joshua Rosenberg	CRO	Banking/regulatory background	BI	Risk authority needed
Vlad Dubinsky	Chief Credit Officer	Credit role reported	BI	Credit policy needed

R&D and control-function operating model Publicly visible product, risk, credit, and technology functions.

VI.B New Product Pipeline

partially verified confidence: medium

Pipeline categories are public; timing, cost, critical technology, and risks are private.

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Evidence gaps

Roadmap, launch dates, development budget, testing, risk signoffs.

Hidden risks

Roadmap may depend on undisclosed core banking, compliance, and security vendors.

Follow-up questions

Provide pipeline, launch gates, tech dependencies, QA/security results, risk signoffs.

Public product/R&D pipeline
Capability	Public status	Timing	Evidence	Verification
Deposit products	Regulator-approved category; homepage Member FDIC/sign-in	2026 rollout reported	FDIC/OCC/homepage/OhioTech	partially_verified
Lending products	Regulator-approved category	Not public	OCC/FDIC	partially_verified
Gas-fee virtual currency	OCC discusses limited balance-sheet holdings	First three years projection	OCC	verified
Account notifications	Payment/security/compliance reminders	Terms live	Messaging terms	partially_verified
Core portal	Sign-in suggests portal	Not tested	Homepage	partially_verified

Chapter 07

07Management and Personnel

A public management roster and LinkedIn headcount signals exist, while formal org chart, compensation, turnover, and retention remain private.

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VII.A Organization Chart

partially verified confidence: medium

Public leadership roster exists; formal reporting lines, board committees, and control-function independence are not public.

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Evidence gaps

Formal org chart, board/committee charters, delegated authorities.

Hidden risks

Role ambiguity between founders/co-CEOs and control functions could slow decisions.

Follow-up questions

Provide org chart, board composition, committees, delegations, control independence.

Public management org chart Public leadership roles from BI and LinkedIn.

Reporting lines are schematic, not company-confirmed.

VII.B Historical and projected headcount by function and location

partially verified confidence: medium

LinkedIn provides directional headcount; function/location history and projections are private.

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Evidence gaps

Payroll roster, function/location split, hiring plan, contractors.

Hidden risks

Staffing may be insufficient or inefficient for regulated launch.

Follow-up questions

Provide HRIS export, hiring plan, vacancies, contractors, budgeted headcount.

Headcount and hiring signals
Signal	Value	Detail	Source	Implication
LinkedIn employees	78	No verified function/location split	LinkedIn	Early scale
Company-size band	51-200	Self-reported range	LinkedIn	Reconcile to payroll
Followers	7,280	Not headcount	LinkedIn	Awareness
Ashby open roles	0	No roles listed	Ashby	Hiring plan unknown
LinkedIn jobs	0	No jobs posted	LinkedIn	Recruiting ambiguity

Public headcount and hiring signals Bar chart of staffing indicators.

VII.C Senior management biographies

partially verified confidence: medium

Names and selected backgrounds are public; full bios, references, conflicts, and background checks are private.

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Evidence gaps

Bios, references, background checks, outside interests, conflicts.

Hidden risks

Key-person, reputational, and regulatory-fit issues require direct diligence.

Follow-up questions

Provide management bios, references, background checks, conflict questionnaires.

Senior management roster
Name	Role	Public date	Background	Status	Source
Palmer Luckey	Founder/backer	2025	Anduril/Oculus founder per BI	partially_verified	BI/LinkedIn
Trevor Capozza	Co-founder	2025	BI-reported cofounder	partially_verified	BI
Owen Rapaport	Co-founder/co-CEO	2025	Aer Compliance/Electrum/Bain per BI	partially_verified	BI
Jacob Hirshman	Co-founder/co-CEO	2025	Sales/marketing/regulatory focus per BI	partially_verified	BI
Aaron Pelz	Co-founder/CTO	2025	CTO per BI	partially_verified	BI
Michael Hagedorn	President	2025	President per BI/LinkedIn	partially_verified	BI
Ricky Grant	CFO	2025	Customers Bank background per BI	partially_verified	BI
Joshua Rosenberg	CRO	2025	FRBNY/United Texas Bank background per BI	partially_verified	BI
Vlad Dubinsky	Chief Credit Officer	2025	Role reported by BI	partially_verified	BI

VII.D Compensation arrangements

not publicly verifiable confidence: high

Employment agreements, compensation, benefits, severance, and retention arrangements are not public.

Evidence gaps

Employment agreements, compensation tables, benefits, severance.

Hidden risks

Retention and incentive alignment unknown.

Follow-up questions

Provide executive agreements, compensation, bonuses, benefits, severance, retention plans.

VII.E Incentive stock plans

partially verified confidence: medium

OCC references employee stock options/equity incentive plan; plan size/grants are private.

Evidence gaps

Equity plan, option ledger, vesting, exercise prices, 409A.

Hidden risks

Option dilution and retention economics unknown.

Follow-up questions

Provide incentive plan, option ledger, grant agreements, vesting schedules, 409A reports.

VII.F Significant employee relations problems, past or present

not publicly verifiable confidence: low

No public employee-relations problems were identified; absence from web search is not clearance.

Evidence gaps

HR complaints, investigations, employment litigation, culture surveys.

Hidden risks

Unknown disputes, whistleblower complaints, or culture issues.

Follow-up questions

Provide HR/legal incident log, claims, whistleblower reports, culture survey summaries.

VII.G Personnel Turnover

not publicly verifiable confidence: high

Turnover metrics and retention/benefit plan details are not public.

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Evidence gaps

Turnover by function/location, regretted attrition, benefit/retention plans.

Hidden risks

Turnover in regulated control roles could impair launch/compliance.

Follow-up questions

Provide 24-month attrition, regretted attrition, roles, benefits, retention agreements.

Departures and turnover signals
Category	Public evidence	Status	Risk	Follow-up
Executive departures	None identified	unverified	Continuity unknown	Request resignation log
Employee attrition	Not public	not_publicly_verifiable	Retention unknown	Request HRIS attrition
Control roles	CRO/CFO/CCO public, retention unknown	partially_verified	Control-function key person risk	Request retention/succession
Hiring demand	0 public openings	verified	Could be pause or stealth hiring	Request hiring plan

Chapter 08

08Legal and Related Matters

OCC/FDIC approvals are strong evidence, but conditions, digital-asset compliance, CRA obligations, and Senate scrutiny require follow-up.

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VIII.A Pending lawsuits against the Company

unverified confidence: low

No specific pending lawsuit was identified in scoped public searches; Senate letter is scrutiny but not litigation.

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Evidence gaps

PACER/state docket searches, demand letters, legal reserves, counsel letters.

Hidden risks

Public search is not legal clearance; oversight can increase cost and reputational risk.

Follow-up questions

Provide litigation schedule, counsel letters, demand letters, regulatory inquiries, OCC/Senate response.

Pending lawsuits or external scrutiny against Erebor
Matter	Forum	Date	Status	Evidence	Diligence action
Pending civil lawsuits	No court identified	Not public	unverified	No obvious result captured	Run docket/counsel searches
Senate oversight letter	Senate/OCC	2026-02-25	Public inquiry/allegation	Letter requests documents and alleges concerns	Request OCC/company response
Regulatory conditions	OCC/FDIC	2025-10/12	Ongoing	Capital/no-deviation/failure-processing conditions	Request tracker

VIII.B Pending lawsuits initiated by Company

unverified confidence: low

No public lawsuits initiated by Erebor were identified.

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Evidence gaps

Initiated lawsuits, threatened claims, IP enforcement, collections disputes.

Hidden risks

Unknown IP, contract, or employment disputes could be non-public.

Follow-up questions

Provide litigation docket, dispute register, outside counsel confirmation.

Pending lawsuits initiated by Erebor
Matter	Defendant	Court/Docket	Filed date	Status	Follow-up
Company-initiated litigation	None public	No docket found	Not public	unverified	Request litigation schedule
IP enforcement	None public	No docket found	Not public	unverified	Run IP/court searches
Contract disputes	None public	No docket found	Not public	unverified	Request dispute log

VIII.C Environmental and employee safety issues and liabilities

partially verified confidence: medium

Branchless model reduces branch environmental exposure; employee safety, leases, and CRA/community obligations require review.

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Evidence gaps

Workplace safety, remote work, office leases, insurance, CRA implementation.

Hidden risks

Branchless model shifts exposure to cyber, employee safety, and CRA/community compliance.

Follow-up questions

Provide safety policies, leases, insurance, CRA implementation, environmental/OSHA disclosures.

VIII.D Material patents, copyrights, licenses, and trademarks

unverified confidence: low

No public IP portfolio was identified; brand, software ownership, licenses, and Atticus Digital IP require diligence.

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Evidence gaps

USPTO/WIPO searches, IP assignments, open-source inventory, licenses.

Hidden risks

Unclear software ownership, vendor licenses, open-source compliance.

Follow-up questions

Provide IP schedule, trademark filings, software assignments, open-source scan, vendor licenses.

Material IP, contracts, and insurance visibility
Asset/Contract/Policy	Public status	Evidence	Status	Request
Erebor brand/domain	erebor.bank in use; unrelated erebor.com observed	Homepage/public review	partially_verified	Trademark/domain clearance
Patents/trademarks	No records identified in scoped web search	Negative search only	unverified	USPTO/WIPO scan
Atticus Digital	Wholly owned subsidiary after merger per OCC	OCC letter	verified	Merger/IP docs
Capital commitments	Committed equity line referenced	OCC letter	verified	Capital-call agreement
Insurance	Corporate coverage not public	Public gap	not_publicly_verifiable	Policies/claims history

VIII.E Insurance coverage and material exposures

not publicly verifiable confidence: high

FDIC deposit insurance is public; D&O, E&O, cyber, fidelity, and banker's blanket coverage are private.

Evidence gaps

Policies, limits, exclusions, claims history, fidelity bond, cyber/D&O/E&O.

Hidden risks

Cyber, D&O, fidelity, credit, and operational exposures may be underinsured.

Follow-up questions

Provide insurance schedule, policies, claims history, broker letter, gap analysis.

VIII.F Material contracts

not publicly verifiable confidence: high

Material customer, vendor, investor, regulatory, intercompany, and capital-call contracts are private.

Evidence gaps

Material contract schedule, investor rights, customer/vendor/intercompany agreements.

Hidden risks

Unknown obligations, termination rights, and related-party economics.

Follow-up questions

Provide material contracts with change-of-control and termination provisions.

VIII.G Regulatory agency problems

partially verified confidence: high

Approvals are verified and conditioned; no enforcement action found, but oversight letter and digital-asset/CRA obligations require follow-up.

EC-003 EC-006 EC-014 EC-005 EC-007 EC-018 EC-016 EC-001 EC-004 EC-012 EC-020

Evidence gaps

Regulatory correspondence, exam findings, conditions tracker, BSA/AML and CRA materials.

Hidden risks

Failure to satisfy conditions or adverse scrutiny could constrain launch and valuation.

Follow-up questions

Provide regulator correspondence, conditions tracker, exam findings, BSA/AML/CRA materials, counsel assessment.

Regulatory and agency action summary
Agency/Body	Action	Date	Status	Conditions/notes	Risk
OCC	Preliminary conditional charter approval	2025-10-15	Approved subject to conditions	No material deviation; 12% Tier 1	Execution/regulatory
FDIC	Deposit insurance approval	2025-12-16	Approved subject to conditions	Failure-processing protocols; capital requirements	Capital/regulatory
OCC/CRA	CRA strategic plan/branchless status	2026 public doc	Applicable	Main office Columbus; no branches	CRA/community
Senate Banking Committee	Oversight letter to OCC	2026-02-25	Public inquiry/allegation	Questions about approval process; no finding identified	Reputational/regulatory

Legal and regulatory timeline Timeline of approvals and oversight.

Diligence risk heatmap Severity/likelihood heatmap for full risk register.

Evidence

Evidence claims
ID	Claim	Status	Sources
EC-001	CB Insights lists Erebor as a $4.35B private unicorn.	verified high	SRC-001
EC-002	Ohio Tech News, citing Axios, reported a $350M round valuing Erebor at $4.35B led by Lux Capital with Founders Fund, 8VC, Haun Ventures, and others participating.	partially verified medium	SRC-007
EC-003	The OCC conditionally approved Erebor Bank, N.A.'s de novo national bank charter application on 2025-10-15.	verified high	SRC-003 SRC-004
EC-004	OCC described Erebor as a planned full-service insured national bank targeting technology companies and ultra-high-net-worth individuals using virtual currencies.	verified high	SRC-004
EC-005	OCC imposed early operating constraints including no material business-plan deviation without OCC no-objection and a 12% minimum Tier 1 leverage ratio.	verified high	SRC-004
EC-006	The FDIC approved Erebor's deposit insurance application to establish a newly chartered national bank headquartered in Columbus, Ohio, subject to conditions.	verified high	SRC-005
EC-007	OCC-hosted CRA documentation states Erebor is chartered by OCC, granted FDIC insurance on 2026-02-06, branchless, with main office in Columbus and administrative offices in New York and Newport Beach.	verified high	SRC-006
EC-008	Erebor's website was live and represented the company as FDIC-insured and Member FDIC with a sign-in link.	verified medium	SRC-002
EC-009	Erebor privacy and messaging terms indicate account, transaction, identity, payment approval, security alert, document signature, statement, and compliance-reminder workflows.	verified medium	SRC-016 SRC-017
EC-010	Public reports identify Palmer Luckey and cofounders Trevor Capozza, Jacob Hirshman, Aaron Pelz, and Owen Rapaport, with Hirshman and Rapaport listed as co-CEOs and Pelz as CTO.	partially verified medium	SRC-008 SRC-009
EC-011	LinkedIn showed 7,280 followers, company size 51-200, and 78 employees; LinkedIn/Ashby showed no open jobs.	verified medium	SRC-009 SRC-010
EC-012	Public sources do not disclose named customers, revenue by customer, churn, backlog, AR aging, audited financials, deposits, loan book, or unit economics.	not publicly verifiable high	SRC-002 SRC-004 SRC-005 SRC-006
EC-013	Mercury, Brex, Arc, and Anchorage publicly position around startup banking, treasury, finance software, or institutional crypto banking, overlapping Erebor's target markets.	verified medium	SRC-011 SRC-012 SRC-013 SRC-014
EC-014	A Senate Banking Committee letter requested OCC documents and alleged serious questions about legal legitimacy and political handling of Erebor's charter; these are allegations, not findings.	verified medium	SRC-015
EC-015	Public pricing, fee schedules, loan terms, deposit rates, and unit economics are not disclosed.	not publicly verifiable high	SRC-002 SRC-004 SRC-005
EC-016	No pending lawsuits by or against Erebor were identified in scoped public web searches, but this is weak negative evidence.	unverified low	SRC-018
EC-017	Erebor appears active and not shut down based on its live website, regulator records, and LinkedIn profile; no IPO/acquisition/shutdown evidence was found in scoped searches.	verified medium	SRC-001 SRC-002 SRC-006 SRC-009 SRC-018
EC-018	Erebor's branchless model and CRA obligations require future public-performance evidence.	partially verified medium	SRC-006
EC-019	Erebor's public go-to-market evidence consists mainly of regulatory approvals, a minimal website, LinkedIn presence, and investor/news amplification rather than channel economics.	not publicly verifiable high	SRC-002 SRC-007 SRC-009 SRC-010
EC-020	Private data-room materials are required for investment-grade diligence across financials, cap table, customer contracts, vendor contracts, IP, employment, insurance, and regulatory correspondence.	not publicly verifiable high	SRC-001 SRC-002 SRC-003 SRC-004 SRC-005 SRC-006 SRC-007 SRC-008 SRC-009 SRC-010 SRC-011 SRC-012 SRC-013 SRC-014 SRC-015 SRC-016 SRC-017 SRC-018

Sources
ID	Publisher	Title	Accessed
SRC-001	CB Insights	The Complete List Of Unicorn Companies	2026-06-13
SRC-002	Erebor Bank, NA	Erebor homepage	2026-06-13
SRC-003	Office of the Comptroller of the Currency	OCC Announces Conditional Approval for Chartering Erebor Bank	2026-06-13
SRC-004	Office of the Comptroller of the Currency	Conditional Approval Letter - Application to Charter Erebor Bank, N.A.	2026-06-13
SRC-005	Federal Deposit Insurance Corporation	FDIC Approves the Deposit Insurance Application for Erebor Bank, N.A., Columbus, Ohio	2026-06-13
SRC-006	Office of the Comptroller of the Currency	Erebor Bank Columbus Ohio - Community Reinvestment Act Strategic Plan	2026-06-13
SRC-007	Ohio Tech News	Palmer Luckey’s Columbus-based bank hits $4.35 billion valuation: Report	2026-06-13
SRC-008	Business Insider	The executives behind Palmer Luckey's new digital banking startup Erebor include banking, Big Law, and tech vets	2026-06-13
SRC-009	LinkedIn	Erebor LinkedIn company profile	2026-06-13
SRC-010	Ashby / Erebor	Erebor Ashby jobs page	2026-06-13
SRC-011	Mercury	Online Business Banking For Startups, Small Businesses & Scaling Companies	2026-06-13
SRC-012	Brex	Brex: The Modern Finance Software Platform	2026-06-13
SRC-013	Arc	Arc homepage	2026-06-13
SRC-014	Anchorage Digital	Crypto Bank for Institutions	2026-06-13
SRC-015	U.S. Senate Committee on Banking, Housing, and Urban Affairs	Letter to OCC re Erebor Approval	2026-06-13
SRC-016	Erebor Bank, NA	Erebor Online Privacy Notice	2026-06-13
SRC-017	Erebor Bank, NA	Erebor Bank, N.A. Phone Calls and Text Messages Terms of Service	2026-06-13
SRC-018	DuckDuckGo Lite search results	Scoped public web searches for Erebor Bank IPO, acquisition, shutdown, litigation, enforcement, and IP	2026-06-13

Disclaimer

This report is a public-evidence diligence snapshot, not investment advice. Important financial, legal, technical, and contractual facts remain non-public and should be verified directly with management and primary documents before any investment decision.