Here is the OCC Letter to bunq Denying Bank Charter Application

This past week, it was reported that Netherlands-based digital bank bunq had been denied a US charter by the Office of the Comptroller of the Currency. The response sent to bunq’s legal representation in the US was uncharacteristically harsh and critical of the Fintech’s attempt to offer bank services in the US under a federal regime. Typically, applying banks spend years preparing for the rigorous requirements demanded to operate as a bank in the US.

The OCC slammed bunq as not demonstrating it had sufficient capital to support its business ambitions.

Even more damning was the statement that bunq does not have, or has not demonstrated, “competent management.”

The bank was criticized for its inability to prove it could operate in a safe and sound manner.

The OCC also said bunq did not show it could achieve and maintain profitability.

To quote the letter:

“The Application did not demonstrate that bunq USB would have organizers who are aware of and understand national banking laws and regulations, and safe and sound banking operations.”

Apparently so.

One has to wonder who was advising bunq in regard to its application for a federal bank charter. Perhaps the company needs a change in legal guidance.

The letter is shared below.




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Disclosure Quest

Reg A - Form 1-A Filings Beta

Beta. Initial Form 1-A only. Target raise is the stated Amount to be Raised, totaled. Compared with the same dates one year earlier.

YTD: Jan 1, 2026 - Nov 4, 2026 vs Jan 1, 2025 - Nov 4, 2025

Share this graph
Number of Filings134Prior 129 +3.9%
Target Raise, Total$3.45BPrior $3.59B -3.8%
This YTDYear priorChange
Filings 134 129 +3.9%
Target raise $3.45B $3.59B -3.8%

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Source: DisclosureQuest. Initial Form 1-A only.

Created by Crowded Media Group

This display counts initial Form 1-A filings only. It does not represent subsequent filings, including Form 1-A/A amendments or Form 1-A POS post-qualification updates filed by the issuer. Amounts are the stated Amount to be Raised on the initial filing, not capital raised and not amounts revised in later filings.

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