Revolut wins conditional OCC approval for a proposed U.S. national bank
Key takeaways
- Revolut said September 3 that the OCC conditionally approved formation of Revolut Bank US, N.A.; this is not a completed U.S. bank charter.
- FDIC, Federal Reserve and final OCC work remain open, and Revolut proposes a 2027 U.S. launch.
- A full bank launch would require entity-level capital, staffing, systems and controls. No U.S.-specific capital requirement or launch budget has been disclosed.
- Revolut's global profitability and existing partner-bank model provide time; they do not turn group capital into U.S. bank capital.
Revolut said on September 3 that the Office of the Comptroller of the Currency conditionally approved formation of a proposed national bank, Revolut Bank US, N.A. Revolut says it is still working through Federal Deposit Insurance Corporation and Federal Reserve approvals and final OCC approval, with a proposed U.S. launch in 2027.
The distinction matters. Conditional approval moves the application forward; it does not authorize the new entity to offer the full proposed product set. Revolut says loans, credit cards and FDIC-insured deposits could follow once all approvals are obtained.
Permission comes before the banking balance sheet
These are different measures and are not additive: approvals, global group capital and entity-level bank capital answer different questions.
The OCC application, filed March 4, proposes a de novo bank in Stamford, Connecticut, with a non-public-facing main office. It says a Federal Reserve holding-company application is intended after the charter and FDIC applications and identifies a supervisory non-objection requirement for retail foreign exchange.
The FDIC's August 10 process describes contingent authorization, pre-opening conditions, capital raising, staffing and infrastructure work, followed by approval and organizational steps. The Federal Reserve likewise describes the charter, FDIC insurance and Federal Reserve sequence for bank formation and control.
| Measure | Figure | Time basis / status |
|---|---|---|
| OCC status | Conditional approval | September 3, 2026; formation, not final charter |
| Proposed launch | 2027 | Company target, subject to approvals |
| Global customers | More than 80m | Company-reported point-in-time total |
| FY2025 revenue | $6bn | Global annual group figure |
| FY2025 profit before tax | $2.3bn | Global annual group figure; 38% margin |
| Group capital resources | £4.9bn | Year-end 2025; CET1, not U.S. bank capital |
| Revolut Bank UAB CET1 | 23.15% | Year-end 2025; separate European entity |
Global scale leaves the U.S. requirement open
The group's GBP4.9 billion capital resources are quantified funding headroom for mobilization, not U.S. bank capital.
Revolut's 2025 results report $6 billion of revenue, $2.3 billion of profit before tax, $67.5 billion of customer balances and $2.9 billion of lending. The company says 90% of assets were cash, cash equivalents or Treasuries and more than 30 of 40 markets had a licensed bank operation.
Global figures show funding capacity. The group annual report's £4.9 billion of capital resources and Revolut Bank UAB's 23.15% CET1 ratio belong to different entities from the proposed U.S. bank. Applying either figure to U.S. regulatory capital would be unsupported.
Revolut's U.S. customer FAQ describes funds held through Lead Bank or other FDIC-insured institutions under the current structure. That partner-bank model is a buffer during a long mobilization; it also delays the point at which Revolut captures direct deposit and lending economics.
No historical comparable was verified for a conditional charter-to-launch timetable. If the FDIC and Federal Reserve gates clear, Revolut can shift from partner-bank to direct deposit and lending economics. If the gates remain open through year-end, the 2027 target stays a regulated build option. The directional read-through is positive for European fintech equities if the charter advances and negative for partner-bank fee capture if Revolut removes the intermediary. Private-market holders face U.S. capital commitments, staffing, approval conditions and the first insured product's state footprint. Sponsor banks, card networks and U.S. neobanks can watch for intermediary removal. CTOL desk analysis assigns a revised 40% probability that by December 31, 2026 Revolut will receive final approval or launch an FDIC-insured deposit or credit product in at least three states. The next regulator-confirmed milestone will show whether the 2027 launch target is moving forward or remaining a regulated build option.