A national bank charter promises FinTechs a more direct route into U.S. financial services. But the Office of the Comptroller of the Currency (OCC) is making clear that getting one requires more than transplanting an existing technology or overseas banking model into a federally regulated bank. Two recent rejection letters make that point.
As reported here in July, the OCC denied Wise’s proposed national trust bank because of compliance and management shortcomings, particularly around anti-money laundering controls. And this month, the OCC rejected Bunq’s proposed national bank over a set of several concerns including capital, credit risk, management experience, profitability assumptions and familiarity with U.S. banking rules.
The decisions do not establish a trend against FinTech charters. Just two days after the Wise decision, the OCC granted Upstart Bank preliminary conditional approval. The contrast may be more instructive for companies still waiting for decisions than the number of approvals or denials itself.
For Wise, the central issue was whether a company whose U.S. payments operation already had acknowledged AML/CFT deficiencies could demonstrate that a new bank would meet the more demanding standards imposed on federally chartered institutions.
Wise US became subject in July 2025 to a multistate consent order involving suspicious-activity investigations, transaction-monitoring data, late suspicious activity reports, independent testing and remediation of earlier deficiencies. The OCC said Wise’s proposed bank relied heavily on Wise US and global affiliates for AML/CFT compliance, yet the application did not persuade regulators that those enterprise-level problems had been sufficiently addressed.
The agency also faulted the proposed directors and executives for insufficient AML/CFT and fiduciary experience. Wise US itself had no historical fiduciary business, the OCC said.
Wise has not abandoned the effort. In a July 24 regulatory announcement filed through the London Stock Exchange, the company said it intends to submit a new national trust bank application, this time under a framework that takes account of the GENIUS Act. The OCC decision explicitly allows Wise to file again.
OCC’s Rejection of Bunq Challenges European Assumptions
The Bunq decision adds a second set of warning signs.
Bunq proposed bringing its European digital-bank model to the United States with deposit accounts, unsecured credit cards and subscription tiers for consumers and businesses. But the OCC questioned basic elements of the proposed bank’s capitalization. Bunq cited different sources and amounts during the review without providing sufficient evidence that the funds would be available.
More important for other applicants, the OCC challenged assumptions imported from Europe.
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The regulator said Bunq relied on European delinquency projections when estimating losses on a U.S. unsecured credit-card portfolio. Its allowance for credit losses fell below those of OCC-supervised credit-card banks, and revised projections did not come with analysis sufficient to persuade the agency. The OCC also questioned whether Bunq had budgeted enough to acquire customers in the competitive U.S. card market.
Management also has come under scrutiny. The OCC found insufficient U.S. unsecured-card experience among management and directors and said organizers lacked adequate familiarity with U.S. banking laws. The OCC specifically said the denial does not prevent a future filing.
Another FinTech just demonstrated the other side of the OCC process.
Upstart received preliminary conditional approval July 23 for a fully digital national bank offering personal, home-secured and auto-secured lending. But approval came with a 12% minimum Tier 1 leverage ratio and 15% total risk-based capital ratio for its first three years, restrictions on significant departures from its approved business plan, and extensive requirements covering BSA/AML, OFAC, credit, liquidity, model risk, cybersecurity and management.
The message is less “no FinTechs” than “show your work.”
That matters for applicants still on the runway. The OCC currently lists Revolut Bank US among pending applications. Revolut is seeking to become an insured, full-service digital bank serving consumers and businesses nationwide, with deposits, consumer and business credit, foreign exchange, payments and digital-asset services.
Payoneer’s proposed PAYO Digital Bank is also pending. Its application would use a national trust bank to issue and manage a dollar stablecoin and provide stablecoin custody and payment services tied to Payoneer’s cross-border SMB network. “Payoneer believes that issuing a U.S. dollar denominated payment stablecoin for use with its existing global network of customers and facilitating greater use of third-party U.S. dollar denominated stablecoins will help accelerate the use of the U.S. dollar for global transactions,” the application said.
The OCC’s pending digital-assets roster also includes EDX Trust, Payward National Trust Company, Agora National Trust Bank, Catena Trust Bank and several others. EDX, for example, proposes putting digital-asset custody, asset management and settlement inside a national trust bank.
Those companies need not assume Wise or Bunq predicts their outcome. But the recent decisions provide a useful checklist before the OCC reaches one: Can management demonstrate experience with the specific U.S. products it wants to offer? Are capital and loss assumptions documented rather than merely revised? Are existing compliance weaknesses fixed at the enterprise level? And does the proposed bank have the people and controls to operate as a bank from day one?
For applicants that cannot yet answer those questions cleanly, another month spent tightening the application may look considerably cheaper than finding the weaknesses spelled out later in an OCC denial.
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