What Bunq and Wise’s Rejections Teach Fintechs About Applying for a U.S. Bank Charter

Washington has opened the door to a new generation of banks. But the recent rejections of foreign fintechs Bunq and Wise show that while the velvet rope may be unhooked, the bouncer is still very much checking IDs.

The Office of the Comptroller of the Currency has made clear that it wants more companies to apply for national bank charters, while reminding applicants of their standards. Since 2025, the agency says it has received 40 de novo applications and approved 21. That’s a receptive pace, but one that’s still weeding out nearly half the applicants. The FDIC, too, recently updated its review process for deposit insurance to encourage new bank formation.

Recent applications have been heavily focused on digital assets, an area where the OCC has historically been more skeptical, said Molly Swartz, a partner at Paul Hastings. While the agency is more open to novel products, it is still examining filings with a fine-tooth comb, she added.

“Until recently, some fintechs have misread the OCC’s receptivity to new banks as permissiveness,” said Michele Alt, a former OCC lawyer and now a partner at Klaros. “I think those fintechs are realizing their mistake” after the OCC rejected Wise and Bunq, and returned another application.

So if regulators are encouraging new entrants, what does it actually take to get across the finish line? The denial orders for Bunq and Wise provide some answers, laying out what regulators expect from non-U.S. and nontraditional fintechs seeking an American banking charter.

Amsterdam-based digital bank Bunq sought to export its European digital banking playbook to the U.S., combining deposit accounts with unsecured credit cards. But in rejecting the application, the OCC shredded the company’s core assumptions.

The regulator’s primary critique was Bunq’s reliance on European consumer behavior to forecast U.S. performance. European consumers tend to be more comfortable using debit for everyday spending, while Americans are much more accustomed to putting those purchases on credit. That difference affects delinquencies, repayment and loss provisioning. The agency said Bunq’s allowance for credit losses was below those of other OCC-supervised credit-card banks.

“A model that does not adequately account for these differences will not be predictive,” said Andy Kampf, a former Klarna executive who is now a partner at Klaros. Kampf spent years navigating this exact divide at Klarna, where he spent considerable time explaining to colleagues in Stockholm why U.S. credit-loss and repayment models differed so materially from European ones.

In addition to the credit risk, the OCC also challenged Bunq’s financial projections, questioning whether the company had adequately accounted for the cost of acquiring customers and competing in the U.S. market.

“Banking experience is certainly a plus, but not a substitute for U.S. banking expertise,” Alt said. Without modeling calibrated to U.S. credit bureaus, fair-lending rules, and American default curves, an applicant's financial projections read to regulators as wishful thinking rather than a viable bank.

Bunq said at the time that it understood the OCC’s concerns and plans to “listen, adapt, and keep moving forwards.” Its CEO, Ali Niknam, struck a similar tone on LinkedIn, saying the company had “heard ‘no’ soooooo many times before” and would try again.

Management may be one of the easiest requirements for a fintech to underestimate.

Alt said the OCC’s initial review asks whether a proposed bank’s business plan has a reasonable likelihood of success and whether its management team can execute it.

Fintechs are often led by technology or payments executives rather than traditional bankers. That’s not inherently a problem. But if a fintech founder wants to run the bank, Alt said, the OCC needs to see experienced banking executives around that person.

AI lending platform Upstart provides a useful contrast. In granting preliminary conditional approval to the San Mateo, California-based company, the OCC said it had considered the proposed management team and identified executives responsible for credit, risk and compliance.

For a foreign fintech, that can mean adding expertise that may not have been necessary in its home market.

“Show the regulators the money,” Alt said, describing the first thing she would tell a foreign fintech preparing an application.

The OCC wants to know how much capital the bank will have, where it is coming from and whether it is sufficient for the risks in the proposed business.

Bunq’s application illustrates how closely the OCC can scrutinize those details. The company initially proposed $50 million in capital and later revised the figure to $58.3 million. The OCC said Bunq did not adequately establish the source and availability of the proposed capital.

The FDIC’s new application process similarly requires a capital-raising plan, the proposed amount of capital needed to support the business plan and information about anticipated investor commitments.

UK-based payments company Wise had its national trust bank charter rejected in July after its application ran into concerns around anti-money-laundering and counter-terrorist-financing controls, as well as the experience of its proposed management and board.

The rejection came a little more than a year after Wise agreed to a consent order with regulators from six states over AML deficiencies.

Wise said in a statement at the time of the rejection that its compliance program had “evolved significantly” since it submitted the application, and that it had already been addressing the historical issues cited by the agency. The company said it plans to reapply.

“If an applicant has significant regulatory or legal history, the regulators wonder if that past will be prologue,” Alt said.

The OCC said Wise’s proposed bank would rely significantly on Wise US and global affiliates for AML/CFT compliance. The agency said it could not determine that the proposed bank would have an effective AML/CFT program until existing deficiencies were addressed and an enhanced enterprise-wide program was developed.

A past enforcement action isn’t necessarily an automatic disqualifier. But regulators need to be persuaded that the underlying problems have been fixed and that the new bank won’t inherit them.

Kampf said Wise’s regulatory history appeared to matter, particularly given the timing and nature of the enforcement action.

A typical OCC de novo application takes about 12 to 18 months from submission to the opening of the bank, Swartz said. Applications can be delayed by issues including identifying qualified management, preparing policies and responding to additional information requests from the OCC.

The strongest applicants tend to arrive with the fundamentals already worked out: adequate capital, experienced management and a detailed plan for how the bank’s products and services will actually operate, she said. Much of the application can be developed during the review process, but the proposed bank should be fully built out, or very close to it, before the pre-opening exam.

Clear and consistent communication with the OCC is key. Substantial and detailed planning before an application is submitted can help identify problems earlier and set an applicant up for success, Swartz said.

Even for applicants that clear that pre-opening hurdle, winning the charter isn't the finish line. Ongoing supervisory exams ensure the bank operates strictly within the bounds of its approved plan.

“The US is a huge market, so it’s the ultimate prize,” Kampf said. Regulators may be more open to financial innovators than they have been in years, he said. But that doesn’t mean they’re willing to overlook the basics.

Fintechs need a business model built for US customers, executives who understand US banking, enough capital to support the risks they’re taking and regulatory systems that can withstand scrutiny.

“Too often, we see companies focus too little and too late on these factors because they’re so excited by the potential revenue and volumes the US could produce,” Kampf said.