Three European fintechs walked through the same door this summer. Wise applied for a national trust bank charter and was denied on 21 July. bunq applied for a full national bank charter and was denied on 4 August. Revolut applied for a full national bank charter in March and received preliminary conditional approval on 2 September. The comptroller, Jonathan Gould, says the agency has received 40 charter applications in the 18 months since the administration changed, 23 of them involving digital assets, and the agency said in an August release that “America and the OCC are once again open for business.” The two denial letters are the most useful documents the agency has published this year, because they say what open means.
What the letters scored
Wise applied in June 2025 for an uninsured national trust bank in Austin, with $35m of capital and one purpose the application stated plainly: direct access to a Federal Reserve master account, which in the UK had cut Wise’s transfer prices in sterling by 20% and payout times from 15 minutes to under 20 seconds. Less than a month after the filing, six state regulators put Wise under a multistate consent order over its anti-money-laundering programme, with a $4.2m penalty and a two-year lookback. The OCC’s letter said the application “does not demonstrate that WNT will be operated in compliance with laws and regulations,” that proposed management “have demonstrated a persistent inability to sufficiently manage” money-laundering risk, and that the organisers “collectively failed to demonstrate sufficient experience with relevant banking laws and regulations related to fiduciary activities.”
bunq’s letter is shorter and harsher. The organisers “as a whole lacked sufficient background and experience in banking.” The proposed chief executive “has little knowledge of national banking laws and regulations, proposes to be part-time, and plans to allot a large portion of his time to entities other than bunq USB.” The directors “did not demonstrate an understanding of the differences between the US and European markets.” The capital plan moved from $50m to $58.3m without support, and the business plan, subscription accounts plus unsecured credit cards, was “inadequately supported and unrealistic given competition for the unsecured credit cards in the U.S. market.” This was bunq’s second attempt; it withdrew its first in early 2024 citing a difference of views between US and Dutch regulators.
Revolut’s approval letter, by contrast, waived the board residency requirements. It set minimum paid-in capital at $95m and a Tier 1 leverage ratio of at least 10% for the first three years, and left the FDIC application pending. Residency was never the issue. The OCC is scoring whether the people who will run the US bank know US banking law, whether the compliance function was built for US expectations before the filing, and whether the capital plan survives contact with the market the applicant is entering. Revolut named a US chief executive when it filed. bunq proposed a part-time one who would spend most of the year outside the country.
The agency is also fast. The median time from filing to a conditional decision under the current administration is 126 days and Gould has set a target of 120. bunq’s denial came 212 days after it filed. Wise’s took 13 months, though the consent order that decided it arrived in the first of them. The OCC is deciding quickly in both directions.
Four routes, and what each now costs
For a foreign fintech, the United States now offers four ways in, and the summer’s decisions have priced each of them.
Route one is a charter from the OCC. A full national bank, insured and deposit-taking, is what Revolut and Nubank have conditional approval for and what bunq was refused. Nubank’s took 121 days; Revolut’s took just under six months. Both still need the FDIC. A national trust bank, uninsured and non-depository, is what Circle now has, what Bridge, Coinbase, Paxos and Ripple have conditional approval for, and what Wise wanted. Neither carries an automatic master account, and that matters more than it did a year ago. The Federal Reserve proposed in May a limited “payment account” for institutions that are legally eligible but sit outside federal supervision, with no intraday credit, no interest and balance caps, and it asked the reserve banks to pause decisions on that tier of access requests while it writes the policy. Wise said in July that direct access, “a condition of the original application,” was no longer available on the terms it applied for. Kraken became the first crypto firm with a master account in March, on a one-year initial term through its Wyoming charter. A trust charter without the account is half the prize.
Route two is the GENIUS Act. Gould has said the OCC will publish its final rule by November and start processing permitted-issuer applications in the new year. Under the proposal, a complete application is deemed approved after 120 days unless the OCC denies it, capital is set case by case with a $5m floor, and reserves are one-to-one. Wise has already said it will refile “under a GENIUS Act framework.” That route buys the right to issue a dollar stablecoin and to hold reserves; it does not by itself buy deposits, lending or Fed access. Treasury’s own rule sets the deadline: from 18 January 2027 it becomes unlawful to issue a payment stablecoin in the US except as a permitted issuer or a qualifying foreign one, and Treasury has yet to determine that any foreign regime qualifies.
State money-transmitter licences are route three, and they are where Wise operates today, with licences in 48 states. A national footprint needs 40 or more licences, each taking anywhere from three months to two years, and the Money Transmission Modernization Act that was meant to harmonise them has been adopted in 31 states. It works, it takes years, and it leaves the fintech settling through someone else’s bank account.
A partner bank is route four. Lead Bank in Kansas City sponsors Revolut, Ramp and Affirm and is in Visa’s stablecoin settlement pilot alongside Cross River. This is the fastest route and the one regulators have spent two years tightening: the Fed’s 2024 enforcement action against Evolve Bank followed the Synapse collapse, which left as much as $95m of customer funds unaccounted for, and the three agencies’ joint statement that summer reminded banks that using a fintech “does not diminish its responsibility” for the accounts. A partner bank is a landlord. It can raise the rent, and it can be told by its supervisor to evict.
What to build before filing
The applicants who succeeded this year share a profile. They arrived with a US board and a US chief executive, capital well above the minimum, a compliance function already sized for US expectations, and a business plan for one product they could defend. The applicants who failed arrived with a European management team, a compliance record the OCC could read in a state consent order, and a plan to compete in unsecured cards against issuers spending billions on rewards.
A second decision is which prize the charter is for. Revolut and Nubank want deposits and are taking the long route through the FDIC. Circle and Bridge wanted the right to issue and took trust charters. Wise wanted the payment rail, and the payment rail turned out to be a Fed policy question that no charter resolves on its own. Since the OCC now says yes or no within about four months, the cost of applying before the answer to that question is known has fallen. The cost of applying with the wrong team has not, and the two letters explain, in the agency’s own words, what it looks like when a firm does.