OCC Rejects Bunq’s US Bank Bid Over Capital And Market-Plan Gaps
PYMNTS, citing Bloomberg and an OCC letter, detailed why Bunq's US bank-charter application was denied, including capital, governance, credit-risk and market-plan concerns.

A US bank-charter denial has put Bunq's American expansion plan back before regulators.
PYMNTS, citing Bloomberg News and an Office of the Comptroller of the Currency (OCC) letter, detailed capital, governance, and market-planning gaps behind the decision.
The rejected application would have supported a proposed American bank.
A broker-dealer licence approved last October remains separate, allowing users to invest in US stocks while deposit and lending permissions stay outside the company's approved US footprint.
OCC Letter Targets The US Plan
The OCC denied the application on Aug. 7 after seeking a more specific American expansion plan.
Product scope, financial structure, and US-market experience were central parts of the regulator's request for more detail.
Bunq founder and chief executive Ali Niknam's emailed response to Bloomberg committed the company to adapt.
However, the current filing still fell short of the standard needed for a national bank charter.
Capital And Governance Questions Remain
The proposed bank's initial capital was expected to come from Niknam's personal holdings.
The OCC letter left the availability of those funds unclear and raised concerns about his familiarity with US banking law.
Management attention also became a supervisory issue.
Niknam planned to spend significant time outside the United States while holding other roles, raising questions about whether the proposed bank had sufficient local oversight.
Credit Forecasts Face A US-Market Test
Future credit quality assumptions were based on European-market forecasts, although credit cards were expected to be one of the American bank's main products.
The proposed directors had not demonstrated enough understanding of differences between the US and European markets, including credit and credit-risk conditions, the OCC letter concluded.
The marketing plan drew a separate challenge.
US expectations were described as unrealistic given the competitive market the fintech would face, adding another barrier beyond capital and governance.
Charter Race Continues Without Approval
The January filing followed an earlier US bank-charter request that was withdrawn at the beginning of 2024, during a period when few similar applications were being approved.
The latest bid was pitched around digital nomads who live and work between the US and Europe.
A national charter can give fintech firms a single federal supervisory framework and wider product authority.
The public details cited by PYMNTS do not include a revised filing date, leaving the next step dependent on a more US-specific plan, clearer capital evidence, and stronger local governance answers.




















