With recent bank charter application denials, the Office of the Comptroller of the Currency is sending a message about the importance of having a strong management team.

In the past three weeks, the OCC has denied two applications: London-based fintech Wise Group PLC's national trust bank charter application to establish Texas-based Wise National Trust and Dutch fintech bunq BV's national bank charter application to establish New York-based bunq US Bank NA.

The moves are unusual, experts said, as the federal agencies almost always communicate privately if an application is insufficient, to allow a company to withdraw on its own. The agencies do this to avoid reputational and market fallout for companies, partners at the law firm Katten Muchin Rosenman wrote in an Aug. 6 blog post. On the day Wise's denial was announced, its US-listed shares declined by about 6% while its London-listed shares fell as much as 11% in intraday trading.

The OCC likely deviated from its normal course of action to send a deliberate message about the standards to which it holds charter applications, bank advisers said. In both denials, management experience was a major factor.

"Every pending applicant just received a very clear signal," Jon Glass, partner at the consulting firm SolomonEdwards, said in an interview. "Firms seeking a charter should expect the OCC to scrutinize not only their compliance readiness, but their leadership [and] their regulatory track record, just as closely as business model and growth prospects."

The denials show that while the OCC is welcoming fintechs and nonbanks to apply for national bank and trust bank charters, "it's not going to be a rubber stamp approval," said Prescott Ford, principal of banking & financial services at SolomonEdwards and a former OCC supervisory national bank examiner.

This is a "wake-up call, not a stop sign," Glass said. "It shows the OCC will say no when they feel the fundamentals are missing."

"A bank charter is a compliance test as much as a business plan test," he added. "The OCC remains open to fintech charters, but this denial shows that openness to innovation does not mean a lower regulatory bar."

The Wise decision

In Wise's denial letter, the OCC cited deficient Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) controls and management's lack of experience in that area.

While the decision is a "stark warning" that applicants must have strong AML programs, it also "underscores that the OCC's assessment extends well beyond the existence of compliance policies and procedures," the Katten partners wrote. "It places considerable emphasis on whether an applicant's governance framework, board composition and senior management collectively demonstrate the experience and judgment necessary to oversee a regulated banking organization."

The decision also shows that the OCC will look at more than just what the applicant submits in its application, the partners wrote, pointing out that the OCC said part of its decision was based on information it obtained in "field investigation."

"The decision suggests that the OCC will look beyond written submissions to assess whether an applicant has developed a culture of regulatory compliance throughout the organization," they wrote.

Wise's application pended for more than a year after the company filed it in June 2025. Less than one month later, Wise's US arm was subject to a six-state consent order related to AML/CFT deficiencies.

The role of the multistate consent orders in the denial "serves as a reminder that regulators are likely to consider an applicant within the context of its wider corporate group, rather than viewing the proposed entity in isolation," according to the Katten partners.

In a statement released after the denial, Wise said it plans to resubmit a "viable" application. The company did not reply to S&P Global Market Intelligence's request for further comment in time for publication.

Wise could have a better second chance if it can show strong governance and management, Glass said.

"The message here was clearly about what strength of management, board, governance was being brought forward," Ford added. "If it was an outright, 'There's a consent order, so we're not going to approve it,' I don't think it would have taken over a year to decline it."

The bunq decision

The OCC attributed bunq's denial to unresolved questions about the bank's initial capitalization, inexperienced management and an "unrealistic" business model that did not account for US market competition and assumptions.

In the denial letter, the OCC said bunq's proposed management, organizers and directors did not have enough experience with US banking laws and regulations, specifically pointing to the CEO having "little knowledge," and his plans to be part-time and remain outside the US for the majority of the year.

The agency also said the proposed management team did not have enough experience with and knowledge of the company's proposed primary credit offering, unsecured credit cards.

"The common message between the two denials is on governance and management," Ford said.

In a statement to Market Intelligence, bunq said it is working through the OCC's feedback and will "keep working to bring the full bunq experience to the USA."

The fact that both applicants have non-US-based parent companies is "certainly notable, but I wouldn't read too much into that" because foreign ownership itself was not a factor in either denial, Glass said.

"What I do think matters is that a company that has been successful outside the US can't assume that what worked in another market will satisfy US regulators," he said. "They still have to show that their people, controls, governance, capital planning, and business model are appropriate for the US banking environment. Having a successful fintech business isn't enough. If you want to become a US bank, the OCC is going to expect you to demonstrate that you're ready to operate like one."

Overall, both denials "show why regulatory readiness has to start well before a company files a charter application," Glass added. "You can't build a successful business first and assume you'll figure out the regulatory pieces when you're ready to become a bank."

While applicants with insufficient applications have historically been given the chance to withdraw on their own, the Wise denial suggests the OCC could operate differently from here on, the Katten partners wrote.

"While it is too soon to tell, the publication of the decision may reflect a new process adopted by the OCC in connection with its decisions that should function as a glaring yellow (if not softly red) light to potential applicants," they wrote. "Namely, if the application submission is not fully reflective of all of the components of good banking management, it will be publicly denied and the attendant market impact will be felt."