The Office of the Comptroller of the Currency (OCC) has rejected an application from Amsterdam-based digital bank Bunq to establish a new national bank in the United States.
In a decision letter dated August 4, 2026, and made public shortly thereafter, the regulator determined that the proposal for bunq US Bank, N.A., based in New York, raised significant supervisory and compliance issues that made approval inconsistent with agency policies.
bunq, a European challenger bank founded by Ali Niknam in 2012, first sought a U.S. charter several years earlier before withdrawing that filing in early 2024 amid differences between Dutch and American supervisors. Niknam fully self-funded the company for years, investing roughly €100 to €150 million of his own money.
It refiled in early 2026 through a proposed holding company, bunq US Holding LLC, majority-owned by Niknam, who also controls the Dutch parent bunq B.V.
The US entity planned to offer deposit accounts and unsecured credit cards under a subscription model featuring several tiers, generating income mainly from monthly fees and card interchange.
The OCC identified multiple shortcomings after reviewing the application materials, conducting field investigations, and examining related supervisory information.
Capital adequacy has been the apparent issue. Organizers initially proposed a $50 million injection, later revised upward to about $58.3 million, with funds said to come from Niknam’s personal resources or a dividend from the Dutch bank.
Loan loss assumptions and the proposed allowance for credit losses were judged unsupported and below levels maintained by peer credit-card banks supervised by the agency.
As well, proposed directors and executives reportedly lacked demonstrated knowledge of unsecured credit cards—the intended primary lending product—and showed limited familiarity with US national banking laws and regulations.
The prospective president and CEO was described as having little background in those rules, planning only a part-time role while continuing other board duties and spending most of the year outside the United States.
Organizers as a group did not convince regulators they understood key differences between European and American credit markets and risk profiles.
Delinquency projections relied on European data rather than US-specific evidence, the marketing plan understated the costs of building brand recognition in a crowded market, and overall expenses appeared underfunded.
The agency further noted that the Dutch parent itself reached sustained profitability only recently and saw earnings decline when interest rates fell, underscoring limitations of a fee-driven subscription model and interest-rate sensitivity that organizers had not adequately addressed for the US context.
Taken together, these gaps led the OCC to conclude the proposed bank could not be expected to operate in a safe and sound manner, achieve and maintain profitability, or meet statutory factors related to capital structure, management fitness, and protection of the Deposit Insurance Fund.
The denial does not bar a future de novo application, provided the identified deficiencies are resolved. Bunq has indicated it will review the feedback, refine its US-specific plans, and continue pursuing a presence in the American market.