OCC Rejects bunq, Wise Charters Over Compliance, Operational Flaws
The Office of the Comptroller of the Currency (OCC) has sent a clear message to fintech firms seeking national bank charters: regulatory openness doesn’t guarantee approval. In August 2026, the OCC rejected applications from Dutch neobank bunq and cross-border payment giant Wise, citing significant operational and compliance shortcomings. These rejections arrived despite OCC Comptroller Jonathan Gould reiterating that the agency is “open for business” after receiving 40 de novo applications over an 18-month span.
These decisions highlight the OCC’s rigorous evaluation process for non-bank financial institutions. Despite Gould’s assurances, the rejections of bunq and Wise demonstrate that meeting regulatory expectations remains a high bar. The cases illustrate two distinct operational failure modes during the chartering process, emphasizing the need for applicants to address specific regulatory concerns meticulously.
bunq’s Missteps: Unrealistic Projections and Leadership Gaps
bunq, with 20 million EU users, 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 under 12 C.F.R. § 5.20 centered on three critical issues. First, bunq’s proposed $58.3 million in capital, revised from an initial $50 million, lacked verified documentation and a clear plan to withstand projected losses. Second, its leadership team’s European digital banking experience was deemed insufficient for US credit card underwriting, with the OCC noting a part-time executive model and limited knowledge of US banking laws. Finally, bunq’s financial assumptions were considered unrealistic, given the competitive US credit market and its recent stabilization in Europe amid high interest rates.
The OCC’s decision shows the importance of aligning international success with US-specific market and regulatory demands. bunq’s rejection serves as a cautionary tale for fintechs assuming their global expertise automatically translates to US market readiness, particularly in credit underwriting and compliance.
Wise’s Downfall: A Legacy of Compliance Issues
Wise’s denial for a national trust bank charter in Austin stemmed from a different set of problems. The OCC pointed to a $4.2 million multistate consent order Wise US entered in July 2025 to resolve Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) violations. This order, issued just a month after Wise’s charter application, raised serious concerns about the company’s ability to maintain a robust AML program. The OCC ruled that Wise’s unresolved compliance issues disqualified it from operating a federal charter, emphasizing the need for a clean supervisory record before seeking federal approval.
While bunq and Wise faced different challenges, their rejections share a common thread: a failure to meet the OCC’s stringent standards for operational and compliance readiness. These cases suggest that fintechs seeking charters must meticulously address capital adequacy, leadership expertise, market understanding, and compliance history. The OCC’s rulings also draw a clear line between balance-sheet banking and specialized trust charters. While deposit-taking charters face intense scrutiny over credit risk, specialized charters focused on infrastructure, like Circle’s successful trust charter, demonstrate that a focused approach aligned with risk controls can be viable.
