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Fintechs want to become banks. Bunq just found out what the OCC expects in return.

  • For fintechs seeking U.S. bank charters, the OCC is asking: Do the management, capital, risk, and compliance infrastructure hold up? And is the institution ready to operate as a bank, not just alongside one?
  • The OCC may be widening the path to a charter, but it’s also raising the bar for proving readiness.
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Fintechs want to become banks. Bunq just found out what the OCC expects in return.

The fintech bargain with banks is getting harder to maintain. Companies that built the customer experience while leaving deposits, lending, and regulatory oversight to a partner bank increasingly want the charter themselves.

Bunq just ran into the reality of what that requires. The Dutch neobank, which has 20 million users across more than 30 European markets, had already secured a U.S. broker-dealer license and was positioning its U.S. bank around consumers who live and work between America and Europe. But on August 7, the Office of the Comptroller of the Currency (OCC) rejected its application for a national bank charter, saying Bunq needed a U.S.-specific plan, more demonstrated experience with the products it planned to offer, and greater clarity around its financial structure.

Bunq CEO Ali Niknam explained the reason behind the rejection: “The OCC wants to see a plan more specifically built for the US market, with greater demonstrated experience in the products we want to offer, and detail on our financial structure,” he told Bloomberg. “So we’ll do what we always do: listen, adapt, and keep moving forwards.”

Bunq wasn’t the only fintech to hear no from the OCC this summer. In July, the agency rejected Wise’s proposed national trust bank, citing shortcomings around AML/CFT controls and management experience. Wise’s existing U.S. operation had been under a multistate consent order since 2025 over suspicious-activity monitoring, reporting and other compliance deficiencies. The OCC questioned whether those problems had been sufficiently addressed before being carried into a new bank.

The two rejections offer a useful picture of what the OCC is looking for as a growing number of fintechs pursue bank charters.


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