U.S. regulators reject bunq and Wise banking charter bids
The Office of the Comptroller of the Currency (OCC) turned down two prominent fintech firms seeking national banking charters in August 2026, proving that regulatory approval is far from guaranteed even for well-established companies. Dutch digital bank bunq and international payments leader Wise both faced denials, despite the OCC’s previous statements welcoming new applicants. These rejections highlight the specific concerns federal regulators focus on when assessing non-bank financial institutions applying for direct access to the U.S. banking system.
Why bunq’s application was rejected
bunq, which operates across the European Union with over 20 million customers, applied for a full-service national bank charter in New York. The charter would have allowed the company to offer deposit accounts and unsecured credit cards through a subscription-based model. The OCC’s refusal cited three major issues: insufficient capital reserves, leadership inexperience in U.S. credit markets, and unrealistic financial projections.
The regulator questioned bunq’s initial capital plan of $50 million, later adjusted to $58.3 million, because the company lacked verified funding documentation and failed to demonstrate how the capital would cover projected credit losses. Additionally, the OCC noted that bunq’s proposed executive team had no direct experience in U.S. unsecured credit underwriting and limited familiarity with American banking regulations. The regulator also criticized the company’s marketing strategy and credit loss allowances as impractical, given the competitive U.S. credit environment and recent declines in European profitability.
Unlike the stable European markets where bunq operates, U.S. regulators required evidence that the company’s growth assumptions matched local risk conditions. The denial made clear that federal oversight becomes stricter when foreign firms attempt to replicate their international business models in new markets without accounting for higher operational costs and credit risks.
Wise’s compliance failures blocked its trust charter
Wise’s application for a national trust bank charter in Austin faced a different obstacle: a July 2025 enforcement action from six state regulators over serious anti-money laundering (AML) and counter-terrorism financing (CFT) violations. The OCC ruled that Wise’s ongoing compliance issues—including delayed suspicious activity reports (SARs) and weak transaction monitoring—made it unsuitable for a federal charter.
The timing of the rejection was significant. The consent order was issued less than a month before Wise submitted its charter application, leaving the OCC with no confidence in the company’s ability to maintain a compliant AML program. Federal regulators typically require applicants to show a consistent history of compliance before approving new charters, and Wise’s unresolved enforcement actions created an insurmountable barrier.
OCC’s focus on risk and compliance
The OCC’s decisions reveal a clear distinction between traditional banking and specialized financial services. While deposit-taking charters face intense scrutiny over credit risk and loss reserves, trust charters, such as the one obtained by digital asset firm Circle, remain more accessible if the applicant’s operations align with risk management controls. Circle’s success in separating reserve management, custody, and settlement from consumer lending demonstrates that federal charters are achievable when operational risks are tightly controlled.
