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Nubank Wins Conditional OCC Approval for a US National Bank in 121 Days

The Brazilian digital bank, with about 127 million customers, still needs FDIC and Fed sign-off before it can take American deposits.

FinanceJan 29, 20264 min read2 diagrams

Key takeaways

  • The OCC granted Nubank conditional approval 121 days after its Sept. 30, 2025 application.
  • Nubank has 12 months to capitalize the bank and 18 months to open it, pending FDIC and Federal Reserve approvals.
  • Plans include deposits, credit cards, lending and digital-asset custody, with hubs in four US regions.

Nubank, the Brazilian digital bank listed on the NYSE, has received conditional approval from the Office of the Comptroller of the Currency to establish a national bank in the United States. The approval came 121 days after the company filed on September 30, 2025, a fast turn by the historical standards of bank chartering.

What was approved, and what was not

"Conditional" is doing real work in that headline. The OCC's decision lets Nubank organize a de novo national bank, but the company still needs approvals from the FDIC and the Federal Reserve. It has said it will focus on fully capitalizing the institution within 12 months and opening the bank within 18 months. Until those steps finish, Nubank cannot take deposits or lend in the US under the charter.

When it does open, the bank plans to offer deposit accounts, credit cards, lending and digital-asset custody. Nubank said it would establish US hubs in Miami, the San Francisco Bay area, northern Virginia and North Carolina's research triangle. Co-founder Cristina Junqueira will lead US operations, and Roberto Campos Neto, the former president of Brazil's central bank, will chair the board.

Nubank brings scale from elsewhere: about 127 million customers across Brazil, Mexico and Colombia. It built that base by offering low-fee accounts and cards through a mobile app with no branches. The US is a different market, with entrenched card incumbents and thick regulation, but a national charter gives Nubank a route to operate nationwide under one federal supervisor rather than through state-by-state licensing or a partner bank.

Timeline of Nubank's US bank path: application, conditional approval, capitalization, opening Nubank's path to a US bank Sep 30, 2025 Files with the OCC Jan 29, 2026 Conditional approval (121 days) Within 12 months Fully capitalize; FDIC and Fed approvals Within 18 months Open the bank Final OCC approval and regulators' sign-off still required before launch
Source: Banking Dive, Payment Expert. Opening deadlines run from the approval date.

A charter rush, with fast clocks

Nubank is part of a wider wave. S&P Global Market Intelligence counted 13 bank charter applications in the first three months of 2026, on pace to pass the 33 filed in all of 2025. Nonbank applicants dominate, and approvals are coming quickly: among applications approved since 2025, nondepository trust banks had the shortest median timeline at 134 days. Nubank's 121 days for a full-service de novo national bank beat that.

Bar chart of bank charter applications: 33 in all of 2025 versus 13 in Q1 2026 US bank charter applications filed 33 13 Full year 2025 Q1 2026 alone Q1 2026 pace would exceed 2025 if sustained
Source: S&P Global Market Intelligence, April 2026.

Why it matters

For years foreign digital banks reached US customers through partner banks, which hold the deposits and limit what the fintech can do. A national charter ends that dependence. Nubank would hold its own deposits, set its own products and pay the regulatory price: capital requirements, supervision and the compliance costs that go with them. It is the same trade Revolut and others are now weighing, which makes Nubank's timeline a useful benchmark for them.

Nubank's customer base also shows how much capital and credit data a company can accumulate without branches. Whether that translates into the US, where consumers already hold several cards and fintech apps, is uncertain; the company has not published US targets.

The hurdles ahead

The US is a hard market for newcomers. Consumers there already hold multiple cards, rewards programs are entrenched, and the largest banks spend heavily on marketing. Nubank's pitch in Brazil was low fees against expensive incumbents. In the US, where many checking accounts already have no monthly fee, the opening is less obvious, which is why the company's stated lineup, deposits, credit cards, lending and custody, covers the full range rather than a single product.

The regulatory scrutiny will be heavier too. A de novo bank typically operates under tight supervisory conditions for its first years, including limits on growth and requirements to keep capital high. Nubank's 127 million customers elsewhere do not count toward that; regulators will examine the US entity on its own plan. Chair Roberto Campos Neto's central-banking background and Junqueira's role as US chief are the company's attempt to show a credible bench.

What to watch

  • FDIC and Fed decisions. These are the next gates, and their pace will show whether the speed at the OCC carries through the whole system.
  • Capital raise. The 12-month capitalization deadline will reveal how much Nubank is putting behind the US bet.
  • Product launch order. Cards and deposits are the planned lead; digital-asset custody is the regulatory wildcard.
  • Copycats. Further neobank filings would confirm that a charter, not a partner bank, is now the preferred route.

Sources

  1. Nubank gets conditional OCC approval for US bank charter — Banking Dive
  2. Nubank secures US banking charter — Payment Expert
  3. Nonbanks dominate bank charter boom as approval timelines shrink — S&P Global Market Intelligence

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