Bunq's second US bank charter bid was rejected over capital, management and profit plans

Dutch neobank Bunq filed an application in January 2026 for a US national bank charter. It was at least the second try: Bunq first applied to the OCC in April 2023 for a licence aimed at digital nomads, then withdrew after 301 days, citing a 'difference of views' between US and Dutch regulators. In a 4 August 2026 letter reported by Banking Dive, the OCC rejected the new application as presenting 'significant supervisory and compliance concerns'.

The OCC said the proposed US bank would be inadequately capitalised. Bunq first proposed $50 million from CEO Ali Niknam's personal holdings, then said it would come from a dividend, then revised the figure to $58.3 million without detailing its source. The regulator also found loan-loss assumptions unsupported, the proposed US CEO part-time and with little knowledge of national banking law, and directors who did not understand differences between US and European credit risk.

It called the business and marketing plans unrealistic for the unsecured credit card market given Bunq's lack of name recognition, and noted that European profitability only arrived in fiscal 2023 with ECB rate changes and fell when rates declined in 2024 and 2025. Bunq said it would 'listen, adapt and keep moving forwards'.

The capital plan shifted between $50M and $58.3M and its funding source was not adequately explained.

The OCC judged the proposed management inexperienced with unsecured credit cards, the core US product, and the CEO part-time.

Projections lacked support: credit-loss allowances were not credible against peers and marketing costs ignored Bunq's lack of US brand recognition.

The OCC saw Bunq's European profits as tied to interest-rate conditions rather than a durable model.

A regulator reads a licence application as a test of the plan. Capital that keeps changing, a part-time local chief and unproven economics sink even a profitable foreign bank.

The OCC said any new application would have to address the shortcomings it listed. Bunq had meanwhile obtained a FINRA broker-dealer licence in October 2025. The rejection came a month after the OCC denied Wise's national trust bank charter, and Banking Dive noted charter applications had spiked under OCC chief Jonathan Gould even though not all are approved.