The Office of the Comptroller of the Currency has rejected an application from Dutch fintech bunq to launch a national bank in the U.S., citing capital, management, and safety-and-soundness concerns that spanned nearly every factor regulators weigh in chartering decisions.
The application, filed under the proposed name bunq US Bank, was sponsored by Bunq US Holding, a company that would be majority owned by Ali Niknam, who also holds majority ownership of bunq B.V. The U.S. entity planned to offer deposit accounts and unsecured credit cards through a subscription model with four tiers, ranging from a free basic plan to pricier options with added features, generating revenue mainly from subscription fees and card network interchange.
The OCC’s denial laid out deficiencies across capital adequacy, management experience, profitability prospects, safety and soundness, and organizer qualifications — the core factors the agency evaluates under its chartering regulations.
The application proposed an initial $50 million capital injection, which the filing said would come from Niknam’s personal holdings. But additional data provided to the OCC indicated the capital would actually come from a dividend paid by bunq B.V. to Niknam, and despite repeated written questions and interviews, bunq USB never clearly articulated how it would be initially capitalized or supported the capital’s availability.
Bunq later revised its projections to raise the initial capitalization to $58.3 million, but did not explain the changes or the assumptions behind the revised projections, and provided no information on the source or availability of the additional capital.
The OCC also found the proposed capital levels insufficient for the business itself, noting that even after the increase, no analysis was provided showing how the revised capital would match bunq USB’s risk profile, particularly given loan-loss assumptions and a proposed allowance for credit losses that examiners did not consider credible based on peer analysis.
Regulators found the proposed leadership team lacking in the specific area central to the business plan. Proposed management and the board, including the proposed president and CEO, did not demonstrate knowledge, experience, or sufficient competence in unsecured credit cards, bunq USB’s principal lending product. The proposed president and CEO had little knowledge of national banking laws and regulations, planned to work part-time while continuing to serve on the boards of other related entities, and intended to spend a majority of the year outside the United States.
The OCC noted that despite bunq USB’s business plan closely mirroring bunq B.V.’s, the proposed directors did not demonstrate an understanding of the differences between U.S. and European markets or the differences in credit and credit risk between the two.
The agency questioned whether bunq USB could reasonably be expected to turn a profit, pointing to a delinquency rate based on bunq B.V.’s European projections rather than U.S. data, and a loan-loss allowance that was below levels held by other OCC-supervised credit card banks. Examiners flagged the marketing plan as unrealistic given competitive dynamics in the U.S. unsecured credit card market and bunq’s lack of brand recognition domestically.
On safety and soundness, the OCC looked to bunq B.V.’s track record: although the Dutch bank began commercial operations in 2015, it did not post a full year of profitability until 2023 and profits declined again as rates fell in 2024-2025, a pattern the OCC said exposed the limits of a fee-based subscription model and highlighted interest rate risk baked into the business.
The denial doesn’t close the door permanently — the OCC noted it does not prohibit bunq from filing a new de novo charter application in the future, provided it addresses the reasons for this denial. bunq has the right to appeal the decision to the OCC’s Ombudsman.