Revolut Clears the OCC—but Its U.S. Bank Still Needs Three Approvals

A September 3 statement from Revolut disclosed conditional approval for its proposed U.S. national bank and identified three decisions still needed: FDIC approval, Federal Reserve approval and final approval from the Office of the Comptroller of the Currency. The company is targeting a 2027 launch, but the bank cannot open yet.

The OCC decision dated September 2, 2026 grants preliminary conditional approval to organize Revolut Bank US, National Association, while withholding authorization to open until its preopening requirements are met; it also requires FDIC deposit insurance and Federal Reserve-related steps and makes the approval expire if the bank does not open within 18 months unless an extension is granted.

The OCC cleared formation, not opening

The decision moves Revolut beyond the first charter review and allows its organizers to build the legal and operational structure of the proposed bank. It is not final permission to accept deposits, make loans or conduct banking business as Revolut Bank US.

The proposed institution would be a full-service, branchless national bank headquartered in Stamford, Connecticut. Its planned activities cover deposit and credit products, payments, financial-management tools and certain digital-asset services for retail and business customers.

That scope is subject to important limits. Preliminary approval excludes the proposed retail foreign-exchange business, which requires a separate OCC supervisory non-objection before it can begin. Foreign-exchange forwards, merchant acquiring and correspondent-banking products for unaffiliated foreign banks also require written non-objection.

Before seeking a preopening examination, Revolut must complete work on governance, compliance policies, security controls, technology systems, third-party risk management and capital. The OCC retains the power to modify, suspend or rescind the conditional approval if developments during the organization period warrant it.

Three approvals remain on the regulatory path

The outstanding decisions cover different parts of the proposed bank’s structure. Receiving one would not remove the need for the others.

• FDIC approval: Revolut Bank US has applied for federal deposit insurance, and that application remains under review. The proposed institution cannot open as the insured national bank described in its charter application without this approval.
• Federal Reserve approval: Revolut Group Holdings Ltd. and Revolut Holdings US Inc. have applied to become bank holding companies through their ownership of the proposed bank. The Federal Reserve must act on that ownership structure.
• Final OCC approval: The OCC must determine that the organizers have satisfied the charter conditions and that the bank is operationally ready before authorizing it to commence business.

The sequence is therefore more substantial than collecting three signatures. The deposit-insurance review, holding-company review and final charter review examine separate legal and operational questions, while Revolut must prepare the institution for a preopening examination.

Final OCC action sits at the end of that process because the agency must verify readiness as well as the completion of other required regulatory approvals. Conditional approval creates a path to opening; it does not guarantee that every remaining decision will arrive on Revolut’s preferred schedule.

Existing U.S. accounts do not change now

The September decision concerns the formation of a separate proposed institution. It does not transfer existing balances, replace the bank currently identified in a customer’s account documents or alter account terms by itself.

Revolut currently provides certain U.S. services—including prepaid cards, credit and payments—through FDIC-insured partner banks. That arrangement is legally distinct from Revolut Bank US, which remains in organization and has no authorization to conduct banking business.

If the new bank receives all required approvals, the planned direct offering includes FDIC-insured deposits, loans and credit cards. Those products belong to the proposed operating model; they are not evidence that Revolut Bank US is already serving customers.

Any later migration of accounts or change in the institution holding customer funds would require separate communications and applicable disclosures. Conditional charter approval alone gives customers no reason to expect an immediate change in their account access, protections or contractual counterparty.

The 2027 launch is a target, not an approved date

Reuters reporting published September 3, 2026 placed Revolut’s expected launch in the first half of 2027 and confirmed that FDIC and Federal Reserve clearances were still pending. That timing comes from the company, not from a regulator’s authorization to open on a specified date.

The schedule also depends on completing the OCC’s operational requirements and passing the preopening stage. Delays in systems, capital, compliance preparations or another agency’s review could move the launch beyond the company’s present target.

As of September 5, the regulatory timeline has four clear stages: preliminary conditional OCC approval has been obtained; FDIC and Federal Reserve decisions remain outstanding; final OCC authorization must follow satisfaction of the preopening conditions; and only then can Revolut Bank US begin business. Until those remaining decisions arrive, the proposed bank stays in formation and existing U.S. customer accounts remain under their current arrangements.

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