The Office of the Comptroller of the Currency cleared Revolut to build a national bank in the United States on Wednesday, but held back four products the British fintech wants to sell in the states. The agency approved a full-service national bank while requiring additional sign-offs for leveraged currency trading, foreign exchange forwards, merchant acquiring, and correspondent banking for unaffiliated foreign banks. Each of those four needs its own supervisory non-objection before Revolut can launch it, and the decision letter does not say why the OCC held them back.
The approval is preliminary. Revolut's deposit insurance application is still under review at the Federal Deposit Insurance Corporation, and its U.S. holding company and British parent are both awaiting the Federal Reserve's decision on their applications to become bank holding companies. The OCC set conditions in the meantime: Revolut has to put at least $95 million of paid-in capital into the bank and hold a Tier 1 leverage ratio of at least 10% for its first three years. The approval expires if Revolut does not raise the capital within 12 months or open within 18 months. The review took 176 days, from a March 10 filing to Wednesday's decision.
The product-by-product staging stands out to advisors. "The OCC approved the core bank but held back the more complex product lines," said Evey Guo of FS Vector. "This kind of product-by-product staging as a formal condition is not something we've seen in other recent charter approvals," Guo added. No other charter the OCC granted this year gates individual products. Revolut serves roughly 1 million U.S. customers through partner banks including Lead Bank and intends to move them to its own bank, though a spokesperson said post-migration plans have not been finalized.
What remains unknown is whether Revolut can secure the additional sign-offs for the four gated products, and what the Federal Reserve and FDIC will decide on the outstanding applications. The OCC declined to comment, and the decision letter does not explain the reasoning behind the product-specific conditions. A Revolut spokesperson said the held-back products "are currently under development" and that the company will continue to work with the OCC and regulators to make sure they are ready for launch in the U.S.