Two of the most ambitious regulatory bets in recent fintech history came undone this summer, as the Office of the Comptroller of the Currency rejected national bank charter applications from Dutch neobank bunq and denied cross-border payments giant Wise its proposed national trust bank charter. The decisions carry weight far beyond the two companies involved: they define, with unusual clarity, the precise conditions under which a fintech firm can — and cannot — graduate from sponsor-bank dependency to full federal recognition in the United States.
The irony runs deep. OCC Comptroller Jonathan Gould has made a public point of signaling regulatory openness, noting that the agency received 40 de novo charter applications over an 18-month period and characterising the OCC as "open for business." Yet the dual rejections demonstrate that enthusiasm from regulators and readiness from applicants are entirely separate matters. What the OCC's denial letters collectively provide is something arguably more valuable than approvals: a granular, authoritative blueprint of what federal regulators actually require when evaluating a non-bank financial institution seeking the privileges — and obligations — of a federally chartered bank.
bunq's Blueprint Problem
bunq's case is one of structural ambition outpacing operational substance. The Amsterdam-headquartered neobank, which counts more than 20 million users across the European Union, applied for a full-service national bank charter in New York, seeking to offer deposit accounts and unsecured credit cards under a subscription model. The OCC's refusal, issued under 12 C.F.R. § 5.20, identified failures across multiple foundational dimensions simultaneously — which is precisely what makes it so instructive.
On capital, bunq initially proposed $50 million, a figure it later revised upward to $58.3 million. Neither iteration satisfied the OCC because neither was accompanied by verified source documentation or a credible explanation of how that capital base would withstand the firm's own loss projections under stress. A moving capital figure without binding commitments tied to stress-tested models signals to regulators not prudence, but improvisation. On governance, the OCC found that bunq's proposed executive team lacked hands-on experience in US unsecured credit underwriting — a meaningfully different discipline from managing a European digital deposit franchise — and that several proposed leadership roles were structured on a part-time basis, an arrangement the agency deemed inadequate for a full-service bank. On product economics, the OCC concluded that bunq's marketing assumptions and credit-loss allowances were unrealistic given the competitive density of the US credit card market. The regulator also noted that bunq's European profitability had only recently stabilised amid the elevated interest rate environment, making its US projections appear optimistic rather than grounded.
The aggregate picture is of a company that translated its European success story directly onto a US regulatory filing without adequately localising the credit risk framework, governance architecture, or capital documentation to American standards. European profitability is a credential; it is not a substitute for demonstrated US credit expertise.
Wise's Compliance Inheritance
Wise's denial tells a different story — one about sequencing and supervisory history rather than financial modelling. The company sought a national trust bank charter for an Austin, Texas-based entity, with a product scope centred on fiduciary custody, reserve management, and asset conversion rather than consumer lending. In theory, this narrower mandate should have presented a cleaner path to approval.
The problem was timing and baggage. In July 2025, Wise US entered into a $4.2 million multistate consent order with six state regulators to resolve serious Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) deficiencies, including the late filing of Suspicious Activity Reports and inadequate transaction monitoring systems. That consent order was executed less than one month after Wise had submitted its trust charter application to the OCC. The regulator concluded it could not grant federal charter status to a proposed bank entity whose parent was simultaneously working through unresolved, systemic AML compliance failures. The logic is straightforward, even if the outcome is painful: a federal trust charter carries an implicit promise of supervisory reliability, and that promise cannot coexist with active enforcement remediation at the group level.
The Circle Contrast and the Strategic Lesson
The contrasting example embedded in the OCC's own framework is illuminating. Circle, the digital asset infrastructure firm, successfully secured an OCC national trust charter by rigorously confining its proposed activities to reserve management, custody, and settlement — and by presenting a supervisory record free of enforcement encumbrances. Circle's success did not happen by accident; it was the product of deliberate product-scope calibration and a clean regulatory slate at the moment of application.
That contrast surfaces the operating principle embedded across both denial letters: the OCC will extend federal charter privileges to fintech entrants, but only when product scope, governance structure, capital documentation, and compliance history are all simultaneously aligned. Strength in two or three dimensions is insufficient if a fourth is materially deficient. bunq failed on capital, governance, and product modelling. Wise failed on compliance history alone — but that single deficiency was enough.
What This Means for the Industry
For the fintech sector broadly, these decisions recalibrate expectations without closing the door. The OCC's 40-application pipeline confirms genuine regulatory appetite for new entrants. But the bunq and Wise outcomes make clear that applicants must arrive with fully documented and binding capital commitments stress-tested against realistic US loss scenarios, executive teams whose experience is product-specific rather than generically technological, a supervisory record that is not only clean but verifiably resolved well before the filing date, and US market financial models built from local acquisition costs and loss dynamics rather than ported from foreign unit economics.
For cross-border payment firms specifically — a category that has long chafed under sponsor-bank dependency — Washington's message is precise: the infrastructure door is open, access to payment rails and central bank clearing is achievable through federal charter, but the compliance ledger must be settled before that conversation begins. Regulators will not approve tomorrow's ambition while today's enforcement order remains active. The OCC is open for business; the question is whether applicants are ready to meet it on those terms.
Written by the editorial team — independent journalism powered by Codego Press.