US rejects bunq and Wise bank bids

The Office of the Comptroller of the Currency (OCC) recently rejected the national bank charter applications of two major fintech companies, bunq and Wise, serving as a reminder that regulatory appetite does not equal a free pass. The OCC’s decisions provide a detailed playbook on what federal regulators expect when evaluating non-bank financial institutions.

The rejections of bunq and Wise illustrate two completely different operational failure modes during the chartering process. Bunq, a European neobank, sought a full-service national bank charter in New York to issue deposit accounts and unsecured credit cards under a subscription model.

The OCC’s refusal centered on fundamental structural weaknesses, including inadequate and unsupported capital, misaligned management experience, and unrealistic financial assumptions. Bunq initially proposed $50 million in capital, later revising it to $58.3 million without providing verified source documentation or explaining how the funding would withstand loss projections.

The OCC noted that bunq’s proposed leadership lacked experience in US unsecured credit, demonstrated little knowledge of US banking laws, and proposed a part-time executive model. Additionally, the OCC found bunq’s marketing plan and credit loss allowances unrealistic given the intense competition in the US credit market.

Wise Denial Highlights AML Concerns

In contrast, Wise’s denial for a national trust bank charter in Austin had little to do with capital or market modeling; it was sunk by historical supervisory baggage. Wise US entered a $4.2 million multistate consent order with six state regulators to resolve severe Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) failures.

The OCC ruled that it could not trust the proposed bank to operate a clean AML program when the parent entity was actively struggling with systemic AML compliance deficiencies. The consent order was executed less than a month after Wise submitted its trust charter filing.

The OCC’s rulings establish a firm boundary between balance-sheet banking and dedicated payment rails. While deposit-taking charters that touch the Deposit Insurance Fund trigger intense regulatory scrutiny over credit underwriting and loss buffers, direct infrastructure access via specialized trust charters remains open.

Digital asset infrastructure providers like Circle—which successfully secured an OCC national trust charter by strictly isolating reserve management, custody, and settlement from consumer lending—demonstrate that federal charters are attainable when product scope directly matches risk controls.

Regulatory Readiness Is Key

For cross-border payment firms expanding into the US, Washington’s message is clear: the regulatory door is open, but proving operational and compliance readiness remains non-negotiable. The OCC’s decisions highlight the importance of fully documented, binding capital commitments tied to stress-tested loss models, as well as executives with direct, US-market regulatory experience in the exact asset class being underwritten.

The rejections of bunq and Wise serve as a warning to other fintech companies seeking to secure national bank or trust charters. To succeed, these companies must demonstrate a deep understanding of US banking laws and regulations, as well as a commitment to operational and compliance readiness.

As the fintech industry continues to evolve, it is likely that we will see more companies seeking to secure federal charters. However, as the OCC’s decisions make clear, these companies will need to be prepared to meet the regulator’s high standards for capital, management, and compliance.

In this regulatory environment, one thing is certain: the OCC will continue to play a critical role in shaping the future of the fintech industry. Companies seeking to secure federal charters must be prepared to meet the regulator‘s expectations and requirements, which may involve a cautious and measured approach to expansion and growth.

The OCC’s decisions will likely have a significant impact on the fintech industry, and companies seeking to secure federal charters must be prepared to adapt to the regulator’s evolving expectations and requirements. The OCC’s rulings may also lead to increased scrutiny of fintech companies’ operational and compliance readiness, which could result in a more stable and secure financial system.

Strict Regulatory Requirements

Regulatory requirements are strict.

The OCC’s rulings provide guidance for companies seeking federal charters. They must demonstrate a deep understanding of US banking laws and regulations. Companies must also show a commitment to operational and compliance readiness.

Companies like Circle have successfully secured federal charters. They have done so by isolating reserve management, custody, and settlement from consumer lending. This approach allows them to match product scope with risk controls.

Fintech companies must be prepared to meet the OCC’s high standards. They must have fully documented, binding capital commitments. They must also have executives with direct, US-market regulatory experience in the exact asset class being underwritten.

The OCC’s decisions highlight the importance of operational and compliance readiness. Companies seeking federal charters must be prepared to adapt to the regulator’s evolving expectations and requirements. This will help ensure a more stable and secure financial system.

The regulatory door is open to cross-border payment firms. However, these companies must prove their operational and compliance readiness. They must demonstrate a deep understanding of US banking laws and regulations.

The OCC will continue to play a critical role in shaping the future of the fintech industry. Companies seeking federal charters must be prepared to meet the regulator’s expectations and requirements. This will involve a cautious and measured approach to expansion and growth.

The OCC’s rulings establish a firm boundary between balance-sheet banking and dedicated payment rails. Deposit-taking charters trigger intense regulatory scrutiny. Direct infrastructure access via specialized trust charters remains open.