Revolut’s OCC Nod Starts an 18-Month US Bank Clock

The OCC on September 2, 2026 granted Revolut preliminary conditional approval to form Revolut Bank US, N.A. in Stamford. The letter lets organizers build a national bank. It does not let them take deposits yet.

US CEO Cetin Duransoy said the decision keeps the company on track for a 2027 launch. The same file still needs FDIC insurance, Federal Reserve holding-company approval, and a later OCC go-ahead, and the approval itself dies if the bank is not open within 18 months.

The OCC Approved a Bank and Withheld Retail FX

Corporate Decision 1390, signed by Senior Deputy Comptroller Stephen Lybarger, names the new entity Revolut Bank US, National Association, proposed charter number 25420. The OCC’s Corporate Applications Search logged the filing as received on March 4, 2026 and marked it approved on September 2, 182 days later. Public comment ran from March 10 to April 9, 2026.

The bank would be a wholly owned subsidiary of Revolut Holdings US, Inc., a Delaware company. That holding company is owned by Revolut Group Holdings Ltd in the United Kingdom, which the OCC described as a foreign holding company under UK prudential supervision. Both US HoldCo and TopCo have applied to the Federal Reserve to become bank holding companies and said they will elect financial holding company status.

The letter is narrower than the product list in Revolut’s press statement. It does not include retail foreign exchange. Organizers must still win a supervisory non-objection under 12 CFR 48.4 before any retail FX book can start. A separate written condition also bars foreign-exchange forwards, merchant acquiring, and foreign non-affiliate correspondent banking until the OCC says otherwise.

This preliminary conditional approval does not include the proposed retail foreign exchange business.

Stephen Lybarger, Senior Deputy Comptroller, OCC Corporate Decision 1390

The OCC received three comment letters and wrote that they did not raise significant supervisory, Community Reinvestment Act, legal, or policy issues. It also waived the 12 USC 72 residency rule for the entire board. Final approval can still be modified, suspended, or rescinded if something material changes before opening.

Lead Bank Still Holds the US Deposits

Revolut already sells prepaid cards, credit, and payments to US retail and business customers through FDIC-insured bank partners. The company’s own follow-up on September 3 named the current wrapper: Lead Bank, Member FDIC. Until the Stamford entity opens, that is still the bank of record.

https://x.com/Revolut/status/2095526351243497520

The public application is blunt about why the charter exists. Organizers wrote that they want to serve US customers at lower cost and with greater efficiency than through the existing partner bank model, and to sell a wider package of products than a partner will carry. They also said Revolut has already moved US operations between depository institutions and plans a customer migration once the new bank is live.

That is the commercial core of the filing. A national charter would let Revolut hold insured deposits, book loans, and connect to Fedwire and ACH in its own name instead of renting those rails. Lead Bank keeps the deposits, the cards, and the compliance file until FDIC insurance attaches and the OCC finishes a preopening exam.

Founder and CEO Nik Storonsky called the letter a first step, not an opening day.

Conditional OCC approval is an important first step towards establishing the proposed Revolut Bank US. It gives us the foundation to build in the world’s largest financial market and bring the full Revolut experience to millions of Americans.

Nik Storonsky, Founder and CEO, Revolut newsroom, September 3, 2026

A $95 Million Floor and an 18-Month Clock

The OCC set paid-in capital at no less than $95 million, net of organization and preopening costs. The money must be raised the way the application described, unless the agency is told in writing. If capital is not in within 12 months of September 2, 2026, that is by September 2, 2027, the approval expires. If the bank is not open for business within 18 months, by March 2, 2028, it expires too. The letter says the OCC is opposed to extensions except in the most extenuating circumstances.

Those dates match the industry clock consultants now brief to de novo applicants: raise capital within 12 months and be ready to open within 18 months of conditional approval, then sit through a preopening exam. Duransoy has pointed to the first half of 2027 and a team of around 160, which would land inside both windows if the other agencies move.

THE PRE-OPENING CLOCK

Capital is not the only hard number. For the first three years the bank must keep a tier 1 leverage ratio of no less than 10.0 percent. Any big change to products, services, or risk limits needs 60 days’ written notice to the Specialty Asset Supervisory Office and a no-objection letter, and that condition lasts through the in-organization period and the first three years of operation. New senior officers and directors, including the BSA officer and chief risk officer, also need OCC no-objection before they sit.

Why the FDIC and Fed Still Hold the File

The OCC granted preliminary conditional approval only. Final authorization to open waits on every preopening requirement, including “all other required regulatory approvals.” The letter states that the FDIC insurance application is under review and that the bank will apply for stock in a Federal Reserve Bank. Without those two, there is no insured national bank and no Fed membership.

FROM FILING TO THE DROP-DEAD DATE

1. March 4, 2026: Organizers file the interagency charter and FDIC insurance application for Revolut Bank US, N.A., with Sullivan and Cromwell partner Andrew Gerlach as counsel of record.
2. March 10 to April 9, 2026: OCC runs a 30-day public comment period on the Stamford proposal.
3. September 2, 2026: OCC issues Corporate Decision 1390, preliminary conditional approval, with residency waivers granted and retail FX carved out.
4. September 3, 2026: Revolut says remaining work sits with the FDIC, the Fed, and a final OCC sign-off, with a planned 2027 opening.
5. September 2, 2027: Capital of at least $95 million must be paid in or the approval expires.
6. March 2, 2028: The bank must be open for business or the approval expires.

Sixty days before the planned opening, organizers must tell the OCC they have met every condition, request a preopening examination, and name an opening date. The exam will test policies, BSA and OFAC programs, affiliate-transaction rules, credit-risk rating, an independent audit, a security program with third-party risk management, and a full description of information systems. The electronic banking platform needs an independent security review. Until that exam clears, stationery and ads must carry “In Organization” after the bank’s name, and the bank may not begin the business of banking.

Duransoy said the OCC was “diligent and expedient” and that the company can still hit 2027. The remaining file is now an insurance decision and a holding-company decision, which run on different clocks from the Comptroller’s 120-day charter talk.

Stamford Gets a Bank With No Public Door

The main office will be in Stamford, Connecticut, zip 06901 or 06902, but the street address is still listed as to be determined. The application says the office will not be physically accessible to the public to make deposits, take withdrawals, or borrow money. There will be no branches. Products go nationwide through the app.

OCC records list the current US mailing address as 107 Greenwich Street, Floor 20, New York, NY 10006. The agency posed no objection to Duransoy as organizer, chief executive, and director; to Josh Van Hulst as chief compliance officer; to Robert Treadwell as chief financial officer; and to Siddhartha Jajodia and Bruce Wallace as organizer-directors, among others named in the letter.

PRODUCTS IN THE CHARTER FILE

• Deposits and payments: Demand deposit accounts, payment transfers between Revolut accounts, and nationwide digital delivery with no branch network.
• Consumer credit: Unsecured personal loans plus retail credit-card programs, both secured and unsecured.
• Business credit: Business credit cards and business term loans.
• Digital assets: Buy, sell, and hold digital assets, including stablecoins; remittances in digital assets; staking; and pay-by-card with digital assets, with some items offered through licensed third parties.
• Left out for now: Retail foreign exchange, trust powers, and any public teller line in Stamford.

The OCC wrote that all proposed activities are permissible for a national bank under 12 USC 24(Seventh). Digital-asset custody would sit in a nonfiduciary capacity with affiliate Revolut Ltd, called TechCo in the letter, a UK company regulated by the Financial Conduct Authority under the Electronic Money Regulations 2011. The bank represents it will not hold digital assets on its own balance sheet. Digital-asset services revenue is projected at less than 2 percent of total bank revenue over the three-year de novo period.

Revolut told customers it now serves more than 80 million people worldwide and still aims for 100 million by mid-2027. The OCC letter puts the operating map at more than 39 countries. In 2026 the group also took a French banking licence in August, plus licences in Australia and the UK, a UAE payments licence, a Mexican bank launch, and further filings in Brazil, Colombia, Peru, Argentina, and South Africa.

The Bank Will Not Issue the Coin

Company statements list a stablecoin among the products Americans would see once the bank is live. The OCC letter is more precise, and narrower. Customers, including deposit and custody customers, may send remittances using digital assets, including stablecoin. The bank plans to offer Revolut-branded stablecoins through a third party.

WHAT WE KNOW

• Issuer: The bank will not be the issuer of any Revolut-branded stablecoin.
• Reserves: The bank will not manage reserves tied to those coins.
• Bank role: Marketing, customer access, and custody through TechCo.
• Statute: Organizers said stablecoin activity will follow the GENIUS Act and related rules once they are in force.

WHAT IS UNCONFIRMED

• Which third party: The public file does not name the issuer.
• Opening half: First half of 2027 is the company’s target, not an OCC date.
• FX book: No date is set for a retail foreign-exchange non-objection.
• Insurance timing: The FDIC review has no public decision date in the letter.

That structure matters because a full-service insured bank and a trust charter are different jobs. Several crypto firms have spent 2025 and 2026 chasing national trust banks that custody assets and, in some plans, issue coins without taking retail deposits. Revolut asked for the heavier licence: deposits, credit, payments, and a branded coin sold through someone else. The 2 percent revenue cap and the no-balance-sheet pledge are how the OCC boxed the digital-asset slice inside a conventional de novo plan.

Gould Opened a Window That Still Denies Filings

Comptroller Jonathan V. Gould has said the OCC is again willing to charter new banks. In a line carried in a March 2026 Deloitte briefing, he argued that regulators had for too long stifled the formation of new banks, reduced competition, and weakened the resilience of the system. December 12, 2025 brought a batch of conditional national trust approvals, and 2026 has produced more full-service conditionals alongside public denials.

The Dutch neobank bunq was refused a US national bank charter in August 2026. Wise’s US holdings were turned down on a national trust application. Those outcomes sit beside this letter, not in conflict with it. Revolut cleared the Comptroller’s first-stage test as a full-service insured bank with a named CEO who previously ran Raisin US and spent 15 years at Capital One. Other European names did not.

Trust charters remain the faster crypto lane. The same agency has already issued a conditional national trust bank charter to a USD1 vehicle that would custody and issue a stablecoin without taking insured deposits. Revolut chose the slower, heavier path on purpose: FDIC insurance, a 10.0 percent leverage floor, a Stamford body corporate with no public door, and an 18-month fuse.

If the capital is late past September 2, 2027, or the doors are still shut on March 2, 2028, Corporate Decision 1390 lapses and the partner-bank model remains the US business. Duransoy’s first-half 2027 target is the company’s bid to beat that fuse. The OCC letter is the fuse.

Disclaimer: This article is news reporting and analysis of an OCC corporate decision and related company statements. It is informational only and is not banking, investment, legal, or deposit-insurance advice, and it does not recommend opening an account, buying Revolut securities, or using any stablecoin or crypto product. Readers should consult a licensed banker, attorney, or financial adviser before acting on US charter status, FDIC coverage, or digital-asset features. Figures and application statuses reflect the OCC letter dated September 2, 2026 and company statements dated September 3, 2026, and they can change before any final approval to open.