We’re joined today by Priya Jaiswal, a leading authority on banking and financial technology. We’re discussing a pivotal moment in the U.S. banking landscape: the conditional approval of a national bank charter for Nubank, a Brazilian digital banking giant with over 127 million customers. This development, marked by its surprising speed, could signal a new era for foreign fintechs aiming to enter the competitive American market. We’ll explore the remaining regulatory hurdles for Nubank, its strategy for adapting its successful Latin American model, the implications of its rapid preliminary approval, and what this means for the future of digital banking competition in the United States.
With conditional OCC approval secured, Nubank has 18 months to launch. What are the most significant remaining hurdles with the FDIC and the Fed, and could you walk us through the step-by-step plan to fully capitalize the institution within the required 12-month window?
Getting the OCC’s conditional nod in just 121 days was a remarkable first step, but the journey is far from over. The biggest hurdles are now with the Federal Deposit Insurance Corp. and the Federal Reserve. These are not rubber-stamp approvals. The FDIC will scrutinize their plan to insure deposits, focusing on risk management, consumer protection, and the overall safety and soundness of the institution. The Fed, in turn, will look at the broader implications of a foreign-owned digital bank entering the U.S. system. The 12-month capitalization window is a race against time. Nubank must now raise and inject the required capital, a process that has to be meticulously documented and proven to regulators. This involves finalizing their U.S. leadership team, building out their compliance infrastructure, and demonstrating that they have the financial fortitude to operate independently within the U.S., all while satisfying two more sets of powerful, discerning regulators.
Nubank serves 127 million customers in Latin America but is now entering the highly fragmented U.S. market. How will Cristina Junqueira’s leadership adapt the company’s digital-first model for American consumers, and what key performance indicators will define a successful first year?
This is the billion-dollar question. What works in Brazil, Mexico, and Colombia doesn’t automatically translate to the U.S., which is arguably the most saturated and competitive banking market in the world. Cristina Junqueira’s challenge is to maintain Nubank’s customer-centric ethos while tailoring it to the American consumer, who is already bombarded with choices. A successful first year won’t be about massive market share. Instead, the key indicators will be more nuanced. I’d be watching their cost of customer acquisition very closely, as well as the initial rate of deposit growth. Early adoption rates for their credit cards and lending products will be critical to see if their value proposition is resonating. Ultimately, success in year one will be about proving their thesis, as CEO David Vélez put it, by establishing a solid beachhead of loyal, engaged customers and demonstrating that their digital-first model can indeed carve out a niche here.
Your planned services range from deposit accounts to digital asset custody. How will you prioritize this product rollout for the U.S. market, and what strategic advantages do your planned hubs in Miami, the Bay Area, and North Carolina provide for talent acquisition and growth?
A smart rollout will be crucial. You can’t launch everything at once. I expect them to lead with the fundamentals: fee-free deposit accounts and a compelling credit card offering. That’s the hook to get customers in the door and build a base. Lending products will likely follow, as that’s a core revenue driver. Digital asset custody is a fascinating differentiator, but I see it as a second-phase offering to deepen relationships with digitally-native customers once the core bank is stable. The choice of U.S. hubs is incredibly strategic. Miami is a brilliant gateway to Latin American talent and capital, leveraging their existing brand strength. The Bay Area gives them direct access to the heart of tech innovation and engineering talent. And the North Carolina research triangle is a powerhouse for finance and tech professionals, often with a lower cost base than the other two hubs. It’s a distributed model designed to tap into the best talent pools for finance, technology, and operations.
Your charter application received conditional approval in a relatively quick 121 days. How does this signal a potential shift in the U.S. regulatory environment for fintechs, and how might it influence the competitive landscape as other neobanks like Bunq and Revolut pursue charters?
The speed of this approval is a seismic event for the industry. For years, the chartering process was seen as a black box—long, arduous, and unpredictable. Nubank’s 121-day journey from application to conditional approval, as Michele Alt from Klaros Group noted, signals that the OCC, under Comptroller Jonathan Gould, is serious about creating a “clear and constructive pathway for financial innovation,” just as Junqueira praised. This absolutely changes the calculus for other foreign neobanks. We’ve already seen the Dutch neobank Bunq re-apply, and Revolut is known to be interested. This creates a tangible sense of momentum. It tells innovators that if you have a solid business plan, strong leadership, and a commitment to compliance, the door is now genuinely open. The days of slow-walking these applications seem to be over, which is poised to inject a significant new wave of competition into the U.S. market.
What is your forecast for foreign digital banks attempting to enter the U.S. market over the next five years?
My forecast is one of cautious, but accelerated, optimism. Nubank’s progress is a bellwether for the entire global fintech community. If they successfully navigate the final approvals from the FDIC and Fed and launch effectively, they will have created a viable, modern playbook for others to follow. Over the next five years, I don’t expect a floodgate to open, but I do anticipate a steady and growing stream of applications from top-tier European and Asian neobanks. Regulators will be watching Nubank’s performance like a hawk, and their success or failure will heavily influence the risk appetite for approving the next wave. The U.S. remains the ultimate prize in financial services, and with a clearer regulatory path emerging, the most ambitious global players will feel more emboldened than ever to try and claim a piece of it.
