The US Office of the Comptroller of the Currency has given Revolut Bank US, N.A. preliminary conditional approval to charter a new national bank in Stamford, Connecticut. The September 2 decision is an important regulatory step for the London-founded financial-app group, yet it is deliberately short of permission to begin banking operations. The OCC’s Corporate Decision 1390 says that final approval and authorization to open depend on meeting preopening requirements, securing FDIC deposit insurance, and completing other supervisory steps.
The distinction matters for customers, investors, and counterparties. A charter application can clarify the institution’s intended model and its regulator’s view of that model. It does not make a proposed bank an operating insured depository institution. Revolut’s approval therefore creates a path toward a direct US banking presence while keeping the company in its existing partner-bank framework during the organization period.
What the OCC approved
The OCC granted preliminary conditional approval of Revolut’s application to establish a full-service insured national bank. Its decision also approved the requested waivers of board-residency requirements. The OCC stated clearly that the approval excludes the proposed retail foreign-exchange business unless the bank later submits the required information and obtains a supervisory non-objection under 12 CFR 48.4.
The decision describes a proposed digital bank with no branches, headquartered in Stamford, and owned by Revolut Holdings US Inc. That holding company is itself owned by Revolut Group Holdings Ltd. The public application had described a digital-first platform aimed at US retail and business clients, including consumers, frequent travelers, small and medium-sized businesses, and companies with multicurrency needs. The public filing also says the proposed bank would be a wholly owned subsidiary of the US holding company and would seek federal deposit insurance alongside its charter request. Those details are set out in the interagency charter and deposit-insurance application.
The OCC’s Corporate Applications Search records the submission as a new-bank charter application, identifies it as a charter under a holding company, and shows an approved action dated September 2. The same record gives the proposed bank a charter number of 25420 and names Stamford as the proposed headquarters location. It also records receipt in March and a public-comment period that ran from March 10 to April 9. The regulator’s application-status page provides a concise public chronology of that process.
A route away from the partner-bank model
Revolut already offers certain prepaid-card, credit, and payment services to US retail and business customers through FDIC-insured bank partners, according to the OCC decision. The proposed bank would give the group a different operating structure. The OCC says Revolut seeks to provide services at lower cost and with greater efficiency than under its current partner-bank model, while offering a broader package of services to US customers.
That goal is central to the commercial case. Partner arrangements can give a financial-technology firm distribution and regulated infrastructure without requiring it to build a bank. They can also leave the firm dependent on another institution’s product scope, economics, balance sheet, risk appetite, and compliance controls. A bank charter would place more of those responsibilities inside Revolut’s own regulated subsidiary. It would also bring a much heavier supervisory burden, particularly in the first years of a de novo bank.
The approval places the proposed institution in that transition period. The OCC said Revolut Bank US plans to offer deposit and credit products, payment services, digital-asset services, and lifestyle products through a proprietary application. It also says the bank intends to provide digital-asset custody in a nonfiduciary capacity through an affiliate, while its digital-asset service revenue is projected to account for less than 2 percent of total bank revenue across the three-year de novo period. The bank does not intend to hold digital assets on its balance sheet, the decision states.
For market participants, the document is more useful as a risk map than as a launch notice. It identifies the proposed activities, the legal entity structure, and the controls the OCC expects before opening. Product availability, deposit insurance, pricing, and launch timing remain contingent on subsequent approvals and execution.
FDIC insurance and Federal Reserve steps remain open
The proposed bank’s application for FDIC deposit insurance was still under review when the OCC issued its decision. The OCC made its conditional approval with the understanding that the bank would obtain FDIC insurance and that the relevant holding companies would apply for stock in a Federal Reserve Bank and make financial-holding-company elections. The FDIC’s public list of pending new deposit-insurance applications had previously listed Revolut Bank US, N.A. as received on March 5, 2026, reinforcing that deposit insurance follows a separate review track.
The approval letter also requires the bank to obtain all other necessary regulatory approvals before the OCC will grant final charter approval. It must notify the OCC at least 60 days before the planned opening date that its requirements are complete and that it is operationally ready, then request a preopening examination. A final charter certificate and authority to commence the business of banking arrive only after those conditions are met.
This sequencing protects a basic regulatory principle: a banking license is coupled to operational readiness. Supervisors need evidence on capital, governance, technology, risk systems, and controls before an institution takes deposits or makes loans at scale. The public decision does not establish when Revolut will satisfy those conditions. It does establish the milestones that will determine whether the project advances.
Capital, governance, and technology conditions
The approval imposes a minimum tier 1 leverage ratio of 10.0 percent for the first three years of operation. It also requires minimum capital levels commensurate with the risks of the business plan and sets initial paid-in capital, net of organizational and preopening expenses, at no less than $95 million. The OCC says the approval expires if capital is not raised within 12 months or if the bank does not open within 18 months from the preliminary approval date, absent an extension in exceptional circumstances.
Those provisions matter because a digital bank can grow quickly through an app while depending on vendors, cloud infrastructure, payment networks, and third-party data providers. The decision requires an independent external audit, an accrual-basis financial-statement process, adequate fidelity-bond coverage, and policies covering the Bank Secrecy Act, sanctions compliance, affiliate transactions, credit-risk management, and allowance-for-credit-loss methodology.
Technology controls receive unusually concrete treatment. Before opening, the bank must provide the OCC with a complete description of its final systems and operations architecture, an information-systems risk assessment and management plan, vendor due diligence, electronic-banking security measures, internal controls, audit plans, customer authentication, and business-resumption arrangements. It must also complete an independent security review and test of the electronic banking platform. The review must cover access points, protection against unauthorized access, viruses, denial-of-service attacks, and other forms of electronic intrusion.
The conditions also constrain changes after launch. For the organization period and the first three years of operation, the bank must give 60 days’ written notice before a significant deviation from its business plan or operations and obtain a written OCC non-objection. Additional non-objections are required before offering, marketing, issuing, or making available foreign-exchange forwards, merchant-acquiring products, or foreign non-affiliate correspondent-bank products. This gives the supervisor a formal checkpoint before the proposed bank expands beyond the model evaluated in the application.
Digital assets are included, with defined limits
Revolut’s proposed digital-asset activities are a notable element of the decision. The OCC says the bank may offer custody services through Revolut Ltd., identified as an affiliate regulated by the UK Financial Conduct Authority under the Electronic Money Regulations 2011. It also describes a plan to allow customers to make remittances using digital assets, including stablecoins.
The document narrows the role the bank would play. Revolut-branded stablecoins would be offered through a third party; the proposed bank would neither issue them nor manage their reserves. Its role would be limited to marketing, customer access, and custody through the affiliate, subject to compliance with the GENIUS Act and applicable regulations once effective. The structure separates core deposit-taking and lending risks from some crypto-asset exposure, yet it still leaves the bank accountable for operational, third-party, compliance, cybersecurity, and reputational risks attached to customer access.
For lenders and investors, that division should be tested against the eventual operating architecture. Outsourcing or affiliate delivery can reduce direct balance-sheet exposure, while it can increase dependency on contractual controls, service-level governance, and clear accountability. The OCC’s required vendor-management and information-security work reflects that supervisory concern.
Analyst’s View
The conditional approval improves Revolut’s strategic option set in the United States, but its near-term value is regulatory rather than financial. The clearest credit-risk question is whether the group can fund the required capital, build controls to the OCC’s standard, and move from a partner-bank model without weakening service continuity or compliance discipline. The 10 percent leverage-ratio floor and the $95 million minimum capital requirement give counterparties concrete benchmarks, even though they do not reveal the bank’s eventual asset mix or funding base.
Sovereign and regulatory risk remains limited by the multi-agency sequence. The OCC has signaled preliminary approval, while FDIC insurance and other approvals remain outstanding. Any change in the bank’s business plan, technology design, or product rollout can trigger further supervisory review. That structure makes a rapid commercial launch less certain than the headline alone suggests.
For market positioning, the decision supports the broader trend of established fintech groups seeking bank charters to control more of their US product economics. A charter can reduce dependence on partner banks over time, yet it replaces that dependency with capital, governance, reporting, and examination obligations. Revolut’s next disclosures on FDIC insurance, preopening readiness, and timing will therefore carry more practical weight than the September 2 approval itself.
