For years, the fintech playbook was elegant in its simplicity: build a frictionless customer experience, attract millions of users, and let a licensed partner bank absorb the regulatory burden of holding deposits and issuing credit. That arrangement is now fraying at its edges, and Bunq's encounter with the Office of the Comptroller of the Currency illustrates precisely why the next chapter for ambitious neobanks will be considerably harder to write than the last.
The Dutch neobank, which has built a customer base of 20 million users spread across more than 30 European countries, has set its sights on the United States — not merely as a distribution market, but as a jurisdiction in which it intends to operate as a fully chartered bank. That ambition has brought Bunq face to face with the OCC's expectations, and what the regulator demands in return for granting that privilege is reshaping the company's understanding of what American banking entry truly requires.
The Partner-Bank Model and Its Limits
The structural logic that underpinned fintech's first decade was sound enough. By partnering with chartered institutions, companies could offer bank-like products — current accounts, debit cards, payment rails — without assuming the capital requirements, examination schedules, and compliance infrastructure that a charter imposes. The partner bank held the license; the fintech held the customer relationship. Revenues were shared; regulatory burdens were not.
That model delivered scale efficiently. Bunq's own European trajectory demonstrates as much: 20 million users across three dozen-plus markets is a meaningful achievement, and it was accomplished under a banking license that Bunq holds in the Netherlands — a regime built on European Union frameworks that, while demanding, differ substantially from the patchwork of federal and state oversight that governs American banking. The leap from European licensed neobank to U.S. nationally chartered institution is not a lateral move. It is, in regulatory terms, a category change.
What the OCC Actually Requires
The OCC does not issue national bank charters as a commercial convenience. The charter is a grant of considerable privilege — access to the Federal Reserve payment system, federal preemption of many state consumer-protection laws, the ability to accept federally insured deposits — and the regulator treats applications accordingly. For a foreign-headquartered neobank like Bunq, the scrutiny is likely to be more granular still.
The OCC's requirements in a charter application typically encompass a credible business plan demonstrating long-term viability, demonstrated capital adequacy, a fully staffed compliance and risk management infrastructure, anti-money laundering frameworks aligned with U.S. Bank Secrecy Act obligations, and a management team with verifiable experience in U.S. banking regulation. For a company whose identity was forged in the European digital-banking environment, assembling that architecture — not just on paper but in operational reality — represents a structural undertaking that dwarfs the challenge of launching in a new European country.
Bunq's experience illustrates a broader dynamic that every fintech eyeing a U.S. charter must eventually confront: regulators at the OCC are not simply evaluating a product. They are evaluating an institution. The distinction is consequential. Products can be iterated quickly; institutions must be built deliberately, with governance structures, board compositions, and risk frameworks that reflect the weight of holding public deposits and participating in the national payments infrastructure.
A Sector-Wide Reckoning
Bunq is not alone in navigating this transition. Across the fintech landscape, companies that rode partner-bank arrangements to scale are now weighing whether the economics of that model — and the strategic dependency it creates — justify the ongoing cost. When a partner bank exits a relationship, as has occurred with notable frequency in recent years, the fintech faces an existential scramble. Owning the charter eliminates that vulnerability, but it introduces a different order of obligation entirely.
The appeal is real. A nationally chartered bank can operate across all fifty states under a single federal framework, eliminating the need to obtain and maintain money-transmission licenses in individual states — a compliance burden that consumes considerable resources for fintechs operating at scale. For a company of Bunq's size and European pedigree, federal preemption is not merely convenient; it is strategically essential to any serious U.S. market entry plan.
Yet the OCC's posture makes clear that the charter is not a shortcut. It is a commitment — to capitalization levels, to supervisory examinations, to community reinvestment obligations, and to a degree of transparency with federal regulators that many growth-stage fintechs have never previously experienced. Bunq's current position in the application process signals that the regulator is engaging seriously with the application while also communicating, clearly, what institutional readiness must look like before approval can follow.
What This Means for the Fintech-to-Bank Transition
Bunq's OCC experience should be read as a reference point for every European neobank — and every domestic fintech — entertaining U.S. charter ambitions. The regulatory cost of becoming a bank is not merely financial; it is organizational, cultural, and temporal. Building the compliance infrastructure, hiring the risk talent, and demonstrating to the OCC that a digital-first company can meet the governance standards of a nationally chartered institution takes time that growth-focused boards are often reluctant to allocate.
That does not make the pursuit unwise. It makes it difficult in ways that demand honest internal assessment before an application is filed. For Bunq, with 20 million European users and demonstrated product capability, the underlying franchise is credible. The question the OCC is asking — as it asks of every applicant — is whether the institution behind the product is equally so. Answering that question satisfactorily is the real work of becoming a bank.
Written by the editorial team — independent journalism powered by Codego Press.
