The Office of the Comptroller of the Currency (OCC), which charters and supervises national banks in the US, has denied Dutch neobank bunq’s application to open bunq US Bank, National Association. The decision, Corporate Decision #1384 from the agency’s Chartering, Organization and Structure unit, is dated August 4, 2026, and was made public on August 7. The six-page letter, signed by Senior Deputy Comptroller Stephen A. Lybarger, is unusually explicit: it lists five sets of deficiencies and spells out what any future application would need to fix.
bunq planned deposits and unsecured credit cards
The application was sponsored by a proposed holding company, Bunq US Holding LLC, majority-owned by Ali Niknam, the founder and controlling shareholder of bunq B.V., the Dutch bank supervised by De Nederlandsche Bank, the Dutch central bank. The US bank would have offered two products: deposit accounts and unsecured credit cards. The business model copied the parent’s: a four-tier subscription, free at the basic level and rising in price as features are added, plus interchange fees on card payments.
Five grounds, one underlying complaint
The OCC relied on 12 CFR 5.13(b), which lets it deny an application that raises a significant supervisory or compliance concern. It then applied the six factors in its chartering rule, 12 CFR 5.20(f): organizers familiar with national banking law, competent management and board, sufficient capital, a reasonable prospect of profitability, safe and sound operation, and a title that does not misrepresent the institution. The bunq application failed on five of the six.
| Criterion | What the decision found |
|---|---|
| Capital | The source of the funds was never established: at times Ali Niknam’s personal holdings, at others a dividend from bunq B.V. No evidence was provided that the capital was available. |
| Management competence | Neither the proposed management nor the board demonstrated experience with unsecured credit cards, the proposed bank’s principal credit product. |
| Profitability | The delinquency rate was taken from bunq B.V.’s European projections. The allowance for credit losses was below that of credit card banks already supervised by the OCC. |
| Safe and sound operation | Business and marketing plans were inadequately supported, given the competition and the brand’s lack of name recognition in the US. |
| Organizers | Banking experience limited to specialized areas, wealth management and information technology. Ali Niknam’s experience is at an institution not subject to US law. |
The harshest passage concerns the proposed president and CEO. The decision says he “has little knowledge of national banking laws and regulations,” would work part-time, would devote a large share of his time to other group entities whose boards he would remain on, and planned to spend most of the year outside the US. The regulator drew a governance conclusion: management and the board “do not have the ability to effectively oversee bunq USB’s principal product and ensure a safe and sound institution.” bunq had also asked for waivers of the residency and citizenship requirements for national bank directors. The denial makes those requests moot.
The OCC also looked at the parent’s track record. bunq B.V. began commercial operations in 2015 but did not have a full year of profitability until 2023, a result the regulator said “appeared to be largely driven by European Central Bank interest rate changes.” When rates fell in 2024 and 2025, profits fell too. For the OCC, that shows the limits of a subscription model in which cash flow from reserve balances is a core source of income, and it exposes an interest rate risk the organizers did not explain how they would manage in a new market.
A second European fintech turned away in a month
Coming a month after the Wise denial, the decision has fed a political reading: that Washington is closing its banking market to European fintechs. Decision #1384 does not support it. The letter is technical and closely argued, and it ends with a line that leaves the door open: the denial “does not prohibit the filing of a de novo charter application in the future.” bunq can also appeal to the OCC’s Ombudsman under 12 CFR 5.13(f).
Four lessons for European applicants
- Capital has to be traceable, not just announced. An amount raised from $50 million to $58.3 million mid-review, with no explanation or proof of availability, is treated as capital that has not been demonstrated.
- European projections don’t carry over. Delinquency on a secured card portfolio in the Netherlands says nothing about the risk of an unsecured credit portfolio in the US, where issuers on the Visa and Mastercard networks have been entrenched for decades.
- The CEO’s availability is a governance test. Part-time work, other board seats, and living outside the country were read as a failure to oversee the principal product.
- Consistent answers matter as much as their content. The OCC based its character and fitness finding on inconsistencies in what management told it during the review.
bunq is not giving up. “The OCC wants to see a plan more specifically built for the U.S. market, with greater demonstrated experience in the products we want to offer, and detail on our financial structure,” the company said in a statement, adding that it would address those objections. The timeline keeps stretching, though. Between the 2024 withdrawal, the January 2026 application, and the August denial, Europe’s second-largest neobank has now spent more than two years at the door of the US banking system without getting in.