The U.S. Office of the Comptroller of the Currency (OCC) granted conditional approval to Nubank to establish a bank to be named Nubank, N.A. The application, filed on September 30 of last year, provides a precedent for banking participants and crypto platforms.
The conditional approval from the OCC allows Nubank to build a nationwide bank from the ground up, without having to acquire an existing one. However, the same approval requires Nubank to capitalize the bank within 12 months and begin operations within a maximum of 18 months.
Nubank’s entire operation must pass through a series of authorizations from the Federal Deposit Insurance Corporation, in addition to scrutiny from the Federal Reserve. For traders and risk managers, the conditional letter shifts the conversation from speculation to a defined regulatory path with measurable short-term checkpoints.
It is estimated that the bank will be able to attract around 127 million customers, generate $4.2 billion in revenue, and achieve net income of $783 million. Nubank also has approximately $8.8 billion in available capital to support the new letter.
The project’s leadership in the US includes co-founder Cristina Junqueira, who relocated to the United States, and former Central Bank of Brazil president Roberto Campos Neto as chairman of the board.
Nubank intends to operate federal deposit accounts, credit cards, and loans, and offer digital asset custody services in the US. This capability would allow the firm to provide legally authorized custody to US clients, expanding institutional and retail custody options under a federally chartered bank framework.
Market reactions following Nubank’s approval
The market reacted with mixed feelings about Nubank’s announcement. Michele Alt, co-founder and partner at Klaros Group, described the swift resolution as a sign that the OCC is streamlining its application processing.
The Bank Policy Institute said substantial questions remain, with analysts pointing to credit risk in Latin America and the unproven nature of Nubank’s credit scoring in a recessionary US environment. Michail Choustoulakis highlighted higher customer acquisition costs in the competitive US market compared to Nubank’s viral growth in Latin America.
For crypto traders and custodians, the conditional letter is structurally significant. A national banking charter that includes digital asset custody provides a regulated ramp for custody services under federal oversight, potentially reducing legal friction for product launches and institutional allocations.
That said, the approval is conditional: final authorizations from the FDIC and the Federal Reserve, along with the firm’s ability to meet capital and operational milestones, will determine how quickly those custody services can be marketed and integrated with trading, custody, and lending products.
Operationally, market participants should monitor three verifiable elements: progress toward full capitalization within 12 months, formal approvals from the FDIC and the Federal Reserve, and the firm’s public timeline for launching custody products.
