Corporate Decision 1384 — Denial of Application to Charter bunq US Bank, National Association

Chartering, Organization and Structure
Corporate Decision #1384
August 2026
August 4, 2026
Matthew Bornfreund, Esq.
Partner
Morrison & Foerster LLP
2100 L Street, NW, Suite 900
Washington, District of Columbia 20037
Re: Interagency Bank Charter Application bunq US Bank, National Association, New York, New York (Proposed) OCC Control Number: 2026-NE-Charter-344545 Dear Mr. Bornfreund:
The Office of the Comptroller of the Currency (OCC) has reviewed the Application to establish a new national bank with the proposed title of bunq US Bank, N.A., New York, New York (bunq USB). For the reasons discussed below, the OCC denies the Application.1 This action is based on a thorough evaluation of all information available to the OCC, including information obtained from the application, during the field investigation, and other supervisory and regulatory information available to us. The OCC would expect any subsequent application to charter a new national bank to satisfactorily address the reasons for this action and otherwise be consistent with the statutory and regulatory factors for approval of the proposed bank. Proposed Bank and Business The Application is sponsored by a proposed bank holding company, Bunq US Holding LLC (US Holding).2 The majority of US Holding will be ultimately owned by a single individual, Ali Niknam. Mr. Niknam, through several holding companies, also is the majority owner of bunq B.V. (bunq BV), a licensed Dutch Depository institution supervised by De Nederlandsche Bank (DNB). Bunq BV offers two products: (1) deposit accounts and (2) secured credit cards. 1 Because of this denial, the requests to waive director residency and citizenship requirements are moot. Therefore, the OCC will not act on these requests. 2 The OCC considers the financial and managerial resources of the sponsor and the sponsors’ record of performance if the organizing group is sponsored by an existing holding company. See 12 CFR 5.20(g)(5). The OCC did not perform this assessment because there is not an existing company in operation.