Posted on

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.

…

Posted on

Why fintechs are transitioning from partners to principals in banking

Fintech’s core value proposition was that financial services could be delivered without owning a bank charter. That model produced an entire generation of financial companies. But it also created a structural dependency: fintechs could innovate quickly and focus on software, distribution, and user experience, yet the underlying regulatory authority, lending licenses, deposit insurance, and access to the financial system, remained largely with partner banks.

By early 2026, signs of a shift in that architecture have started to emerge. Within the last three months, three prominent fintechs have applied for bank charters. Buy-now-pay-later provider Affirm applied to establish a bank subsidiary, followed by cross-border payments platform Payoneer, which filed for a national trust bank to support stablecoin infrastructure. And this month, AI lending platform Upstart applied to become a national bank.

One quarter, three charters

These charter applications are fueled by different objectives.

Affirm: Owning the lending stack

In January, Affirm applied to establish Affirm Bank, a Nevada-chartered industrial loan company regulated by state authorities and the Federal Deposit Insurance Corporation (FDIC).

Industrial loan companies (ILCs) can be owned by commercial companies while still operating as FDIC-insured banks, allowing non-bank firms to enter banking without becoming traditional bank holding companies.

For Affirm, the charter could change the economics and structure of its lending platform. The firm can reduce reliance on partners and take greater control over the credit lifecycle, better manage funding costs, expand the scope of its products, and align underwriting, funding, and servicing under a single roof.

…

Tearsheet Pro