Revolut is not a U.S. bank and will not be one before 2027. The headlines on Sept. 2 were describing a conditional approval to build one, which is the first of three regulatory sign-offs. Two are still outstanding.
The Office of the Comptroller of the Currency cleared Revolut’s plan to form a national bank in Stamford, Connecticut, on an application filed in March.
The approval carries a clock and a price. Revolut has to put at least $95 million of its own capital into the bank within 12 months, and open it by March 2, 2028, or the approval expires and the process starts over.
The two regulators that have not ruled are the ones that matter for anyone’s money. Revolut’s application for deposit insurance is “currently under review” at the Federal Deposit Insurance Corporation, in the OCC’s own words.
Its holding companies applied to the Federal Reserve in April, and no decision has been published. Revolut says it is aiming to launch in 2027.
The OCC held back four products, and the first is listed as "retail foreign exchange," which several outlets have taken to mean the currency conversion Revolut is known for. It does not.
Retail forex is a regulatory term for leveraged currency speculation, and the rule behind it excludes any exchange that settles within two days. Converting dollars to euros, or taking a client payment in a currency you don't hold, is inside the approval.
The three other held-back products are currency forwards, merchant acquiring and correspondent banking for foreign banks, all business lines rather than consumer features.
For anyone invoicing clients abroad through Revolut, none of this changes anything. Same account, same conversion, same transfers, at least into 2027.
What is worth knowing is the arrangement already in place, because most people using it cannot name the bank holding their money. Revolut Technologies Inc. is not a bank. It runs a program on top of other companies’ banks.
Dollars in a U.S. card balance or a Pocket sit at Lead Bank. Savings Vault money sits at Sutton Bank if the vault was opened on or before July 29, 2025, and at Cross River Bank if it was opened after. FDIC coverage of $250,000 applies to each of those banks, and only if that bank fails.
Revolut’s own help page states the limit plainly: “FDIC insurance doesn’t cover losses from Revolut’s failure, theft, or fraud.”
Wise runs on the same borrowed-banking model and is also not a bank, but the protection is not the same. A U.S. Wise balance carries no FDIC insurance at all unless the customer opts into the interest feature.
Wise says so in its own words: money "where you haven't opted into interest" is "not subject to Federal Deposit Insurance Corporation (FDIC) insurance." Opting in sweeps the balance to JPMorgan Chase and brings $250,000 of pass-through coverage across dollars, euros and pounds combined.
In Britain, the gap runs the other way. Wise is an electronic money institution and states that its accounts are "not subject to the Financial Services Compensation Scheme," while Revolut has been a fully licensed U.K. bank since March, with deposits protected to £120,000.
Related:
A consultant who lets two or three client payments stack up in a balance while waiting for a better exchange rate is insured against the least likely of the things that could go wrong, at either company.
Moving money out to an account in your own name on a set schedule is the answer, and it is the same answer whether or not this charter ever arrives. Customers outside the United States are unaffected, since their money sits with Revolut's British, Lithuanian or French entities.
When the FDIC and the Federal Reserve will act, and whether Revolut pursues the excluded retail forex business at all, are not yet known.
Sources
Office of the Comptroller of the Currency, Corporate Decision #1390, Sept. 2, 2026
Office of the Comptroller of the Currency, charter application for Revolut Bank US, N.A., filed March 4, 2026
Legal Information Institute, Cornell Law School, 12 CFR § 48.2, definitions
Legal Information Institute, Cornell Law School, 12 CFR § 48.4, supervisory non-objection
Revolut, “Revolut Receives Conditional Approval from U.S. Office of the Comptroller of the Currency to Form a National Bank”, Sept. 3, 2026
Revolut US help centre, “How does Revolut keep my money safe?”, accessed Sept. 4, 2026
Revolut US help centre, “How are the funds in my Savings Vaults protected?”, accessed Sept. 4, 2026
Board of Governors of the Federal Reserve System, H.2 release, New York district, week ending April 4, 2026
Federal Register, “Formations of, Acquisitions by, and Mergers of Bank Holding Companies”, April 8, 2026
American Banker, “Revolut wins US charter with limits on four products”, Sept. 3, 2026
Wise, “How our US entity, Wise US Inc., protects customer funds”, accessed Sept. 4, 2026
Wise, “Am I eligible for Wise interest in the US, and how can I opt in?”, accessed Sept. 4, 2026
Wise, “How our UK entity, Wise Payments Ltd, safeguards customer funds”, accessed Sept. 4, 2026