The Office of the Comptroller of the Currency (OCC), the federal regulator of nationally chartered banks in the United States, signed Corporate Decision #1390 on 2 September 2026. It grants preliminary conditional approval to Revolut Bank US, National Association, a full-service bank planned for Stamford, Connecticut, with no branches. The trade press reported it the following day. Approval of this kind opens the organisation phase, during which the organisers raise the capital, hire the management team and build the systems. Permission to open comes later.
What a preliminary approval allows
A de novo charter is the route through which an organising group asks to create a US national bank, under 12 USC 21 to 27 and the chartering rule at 12 CFR 5.20. The organising group filed on 10 March 2026, and the OCC ruled less than six months later. The bank then becomes a body corporate in organisation, and the words In Organization must follow its name in its official documents until it opens. No banking business may start before final approval, which requires a preopening examination.
The four conditions
| CONDITION | What it requires | Duration |
|---|---|---|
| Business plan | Sixty days' prior written notice to the supervisory office, then a written determination of no objection from the OCC, before any significant deviation from the business plan or operations, including material changes to products or to risk limits | Organisation, then the first three years |
| Capital | Capital levels commensurate with the risk in the business plan, with a tier 1 leverage ratio of no less than 10% | First three years of operation |
| Officers and directors | A filing to the OCC and a letter of no objection before appointing any senior executive officer within the meaning of 12 CFR 5.51(c)(4) or any director, with the definition extended to the compliance, Bank Secrecy Act, technology and information security officers | Organisation, then the first three years |
| Three reserved activities | A written determination of no objection from the OCC before the bank offers, markets, issues or otherwise makes available foreign exchange forward, merchant acquiring or foreign non-affiliate correspondent bank products | No duration stated |
The fourth condition reaches straight into the payments business. Merchant acquiring is the activity of contracting with merchants to accept their card payments, settling the funds to them and carrying the risk of their failure. The decision does not prohibit it. It places the activity behind a written no-objection, alongside forward foreign exchange and services provided to non-affiliated foreign banks. All three expose the bank to counterparty risk that does not come from its own depositors.
Retail foreign exchange sits under a further regime of its own. The decision states that the preliminary conditional approval does not include the proposed retail foreign exchange business, and that the bank will have to file the required information for the OCC's supervisory non-objection before it starts that business, under 12 CFR 48.4. That rule governs retail foreign exchange transactions offered to non-professional customers. Currency exchange has been part of the Revolut offering from the start, and it remains outside the scope of the approval granted on 2 September.
A branded stablecoin, with no issuance and no reserves
The bank plans to offer Revolut-branded stablecoins through a third party. The decision specifies that it will not be the issuer and will not manage any of the related reserves. Its role is limited to marketing, customer access and custody provided through Revolut Ltd, the group's UK company supervised by the Financial Conduct Authority under the Electronic Money Regulations 2011. The bank represents that it will conduct any stablecoin activity in line with the GENIUS Act and its implementing rules once those take effect.
The same split governs digital assets. Custody runs through that same UK affiliate in a non-fiduciary capacity, and the bank does not intend to hold digital assets on its balance sheet. Revenue from those services is projected at less than 2% of total bank revenue across the three-year de novo period. The decision also lets customers pay cross-border remittances using digital assets, stablecoins included.
The same day, a second application and different numbers
On 2 September the OCC signed a second preliminary conditional approval, Corporate Decision #1389, for OpenReserve Bank, National Association, in Salt Lake City. OpenReserve plans to issue stablecoins, and its first condition requires it to conform its activities, issuance included, to the GENIUS Act, with compliance judged at the OCC's sole discretion. Revolut, which markets stablecoins without issuing them, carries no equivalent condition.
| Revolut Bank US, N.A. | OpenReserve Bank, N.A. | |
|---|---|---|
| Head office | Stamford, Connecticut, no branches | Salt Lake City, Utah, no branches |
| Application filed | 10 March 2026 | 13 April 2026 |
| Minimum initial paid-in capital | $95m | $210m |
| Tier 1 leverage ratio, three years | 10% | 12% |
| Stablecoin | Marketed through a third party, with no issuance and no reserve management | Issuance planned, addressed by the first condition |
After the denials served on Wise and bunq
The OCC denied Wise its national trust bank charter on 21 July 2026, then denied bunq on 4 August, relying on 12 CFR 5.13(b) and on the chartering standards at 12 CFR 5.20(f). The three applications are not directly comparable, because Wise sought a fiduciary charter without deposit insurance, while bunq and Revolut sought an insured full-service bank. Since 2025 the agency has received forty formation applications, approved twenty-one of them and denied two, according to the tally published by The Block.
The clock is now running. The approval lapses if the capital is not raised within twelve months, or if the bank does not open within eighteen months of 2 September 2026. Revolut says it is aiming to open in 2027. The group claims more than 80 million customers worldwide and operates, according to the decision, in more than 39 countries. In the United States it currently distributes prepaid cards, credit and payment services through FDIC-insured partner banks, the arrangement the charter is meant to replace.