OCC denies charters to bunq and Wise

The Office of the Comptroller of the Currency (OCC) has rejected the national bank charter applications of two major fintech companies, bunq and Wise. This decision serves as a reminder that regulatory appetite does not guarantee approval. Despite Jonathan Gould, OCC Comptroller, stating that the agency is “open for business”, the rejections highlight the strict standards that non-bank financial institutions must meet.

The OCC received 40 de novo applications over an 18-month period, but the rejections of bunq and Wise provide valuable insights into what federal regulators expect from applicants. The denial letters outline the operational failures that led to the rejections, which can be used as a playbook for future applicants.

Operational Failure Modes

The rejections of bunq and Wise illustrate two different operational failure modes. Bunq, a European neobank, was rejected due to inadequate and unsupported capital, misaligned management experience, and unrealistic financial assumptions. The OCC noted that bunq’s proposed leadership lacked experience in US unsecured credit and demonstrated little knowledge of US banking laws.

Wise, on the other hand, was rejected due to inherited compliance deficiencies. The company had entered a $4.2 million multistate consent order with six state regulators to resolve severe Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) failures. The OCC ruled that it could not trust Wise to operate a clean AML program given its history of compliance deficiencies.

Regulatory Expectations

The OCC’s rulings establish a firm boundary between balance-sheet banking and dedicated payment rails. While deposit-taking charters trigger intense regulatory scrutiny, direct infrastructure access via specialized trust charters remains open. Digital asset infrastructure providers like Circle have successfully secured OCC national trust charters by isolating reserve management, custody, and settlement from consumer lending.

For cross-border payment firms expanding into the US, the regulatory door is open, but proving operational and compliance readiness is non-negotiable. Applicants must demonstrate fully documented, binding capital commitments tied to stress-tested loss models, as well as executives with direct US-market regulatory experience. A clean supervisory record and tailored US market go-to-market strategies are also essential.

Implications for Fintech Companies

The OCC’s rulings have significant implications for fintech companies seeking to expand into the US. They must be prepared to demonstrate their operational and compliance readiness, as well as their ability to meet the regulatory expectations. The OCC is taking a cautious approach to approving new charters, driven by the need to protect consumers and maintain the stability of the US financial system.