OCC Rejects Bunq’s US Bank Charter Application
The Office of the Comptroller of the Currency (OCC) rejected Bunq’s application for a national bank charter, citing “significant supervisory and compliance concerns”. This decision highlights the challenges foreign fintechs face when trying to enter the US market.
Bunq, a Dutch digital challenger bank, had successfully secured a FINRA-approved broker-dealer license in 2025 to offer investment products to US retail investors. However, federal banking regulators made it clear that capital markets permissions do not translate to full-scale banking rights.
Lessons for European Fintechs
The rejection of Bunq’s application highlights several key lessons for European fintechs attempting to enter the US market. A FINRA license grants distribution rights for investments, but national bank charters require thorough balance-sheet scrutiny, consumer protection mechanisms, and deposit safety standards under the OCC.
The OCC also highlighted serious gaps in Bunq’s capital planning, including a lack of transparency regarding the source of additional funds. Initially, Bunq proposed $50 million sourced from CEO Ali Niknam’s personal funds, later modifying the structure to a corporate dividend and revising the figure to $58.3 million.
The State of Play in the US Market
Foreign fintechs face a high regulatory bar in the US market, with the OCC maintaining stringent standards regarding capital strength, credit risk modelling, and local governance. Key criteria include unambiguous, fully verified capital sources and peer-tested credit loss provisions.
Dedicated local executives with deep expertise in US federal banking laws and fiduciary standards are also required. Additionally, demonstrated BSA/AML compliance frameworks alongside defensible acquisition costs for the US credit market are necessary.
In comparison to other foreign fintechs, Bunq‘s rejection mirrors a similar decision by the OCC involving UK cross-border payments provider Wise. Both companies faced regulatory scrutiny over capitalisation transparency, credit risk modeling, and US-specific market experience.
Both Bunq and Wise have indicated plans to address the regulator’s feedback and submit updated applications. For fintech leaders on both sides of the Atlantic, the core takeaway is clear: expanding into the US market requires establishing a ground-up risk and compliance infrastructure built specifically for federal oversight.
They must ensure that their capital planning, governance, and compliance frameworks meet the OCC’s stringent standards. By doing so, they can increase their chances of success in the US market.
