The Office of the Comptroller of the Currency (OCC), which charters and supervises US national banks, has granted preliminary conditional approval to Revolut Bank US, National Association, a proposed full-service bank headquartered in Stamford, Connecticut, with no branches. Corporate Decision #1390, signed September 2, 2026, and reported by the trade press the next day, comes with four conditions. One of them puts merchant acquiring behind a separate written sign-off from the regulator, and the approval leaves out Revolut’s planned retail foreign exchange business altogether.
The approval does not let Revolut open a bank yet. It starts the organizing phase, during which the organizers raise capital, hire management, and build systems. Authorization to open comes later.
Revolut’s application cleared in under six months
A de novo charter is the process by which an organizing group applies to create a new US national bank, under 12 USC 21–27 and 12 CFR 5.20. Revolut’s organizing group filed on March 10, 2026, and the OCC ruled less than six months later. Once the OCC accepts its founding documents, the bank becomes a legal entity in organization, and “In Organization” must follow its name in all official documents until it opens. It cannot begin the business of banking until final approval, which requires a preopening examination.
Merchant acquiring needs a separate OCC sign-off
| Condition | What it requires | Duration |
|---|---|---|
| Business plan | 60 days’ prior written notice to the supervisory office, then the OCC’s written non-objection, before any significant deviation from the business plan or operations, including material changes to products or risk limits | Organizing period and first three years |
| Capital | Capital commensurate with the risk of the business plan, with a Tier 1 leverage ratio of at least 10% | First three years of operation |
| Executives and directors | Filing with the OCC and a letter of no objection before appointing any senior executive officer as defined in 12 CFR 5.51(c)(4) or any director; the definition also covers the chief compliance, Bank Secrecy Act, technology, and information security officers | Organizing period and first three years |
| Three restricted activities | The OCC’s written non-objection before offering, marketing, issuing, or otherwise making available foreign exchange forward, merchant acquiring, or foreign non-affiliate correspondent bank products | No duration stated |
The fourth condition goes straight to the payments business. Merchant acquiring means contracting with merchants to process their card payments, paying out the funds, and carrying the risk if a merchant fails. The decision does not prohibit it. It requires a written non-objection first, just as it does for foreign exchange forwards and services to unaffiliated foreign banks. All three lines expose a bank to counterparty risk that does not come from its own depositors.
Retail foreign exchange falls under yet another regime. The decision states that the preliminary conditional approval does not include the proposed retail foreign exchange business. Before starting it, the bank must submit the information required for the OCC’s supervisory non-objection under 12 CFR 48.4, the rule that governs retail forex transactions with non-professional customers. Currency exchange has been one of Revolut’s services since its early days, and it remains outside the scope of what the OCC approved on September 2.
The bank will market stablecoins, not issue them
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 reserves. Its role is limited to marketing, customer access, and custody, which will be provided by Revolut Ltd, a UK group company regulated by the Financial Conduct Authority under the Electronic Money Regulations 2011. The bank represents that it will conduct any stablecoin activities in compliance with the GENIUS Act and its implementing regulations once they take effect.
Digital assets follow the same split. Custody, provided in a nonfiduciary capacity, runs through the UK affiliate, and the bank does not intend to hold any digital assets on its balance sheet. Revenue from digital asset services is projected at less than 2% of the bank’s total revenue over its first three years. The decision also lets customers pay cross-border remittances in digital assets, including stablecoins.
OpenReserve got a tougher stablecoin condition the same day
On September 2, 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 its activities, issuance included, to comply with the GENIUS Act, with compliance determined at the OCC’s sole discretion. Revolut, which will market stablecoins without issuing them, faces no equivalent condition.
| Revolut Bank US, N.A. | OpenReserve Bank, N.A. | |
|---|---|---|
| Headquarters | Stamford, Connecticut, no branches | Salt Lake City, Utah, no branches |
| Application filed | March 10, 2026 | April 13, 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 or reserve management | Issuance planned, covered by the first condition |
The approval follows denials for Wise and bunq
The OCC denied Wise’s application for a national trust bank charter on July 21, 2026, and bunq’s application on August 4, citing 12 CFR 5.13(b) and the chartering criteria in 12 CFR 5.20(f). The three cases are not directly comparable: Wise sought an uninsured trust charter, while bunq and Revolut sought a full-service insured bank. Since 2025, the agency has received 40 de novo charter applications, approved 21, and denied two, according to a tally published by The Block.
The clock is now running. The approval expires if the capital is not raised within 12 months or if the bank does not open within 18 months of September 2, 2026. Revolut says it is aiming to open in 2027, and founder and CEO Nik Storonsky called the approval “an important first step towards establishing the proposed Revolut Bank US.” The group claims more than 80 million customers worldwide and, according to the decision, operates in more than 39 countries. In the US, it currently offers prepaid cards, credit, and payment services through FDIC-insured partner banks, an arrangement the charter is meant to replace.