With conditional approval for a US national bank, how should Nubank enter the United States?

Introduction

Nubank applied to the US Office of the Comptroller of the Currency (OCC) in September 2025 and in January 2026 received conditional approval to form a de novo national bank, Nubank, N.A. Approvals from the FDIC and the Federal Reserve were still pending at the time of reporting, and the bank must be capitalised and opened within set deadlines. Co-founder Cristina Junqueira leads the US effort. Nubank enters from a position of strength: 139 million customers across Brazil, Mexico and Colombia, about US$1.1 billion of quarterly net income in Q2 2026, and an efficiency ratio around 20%.

But the US is the hardest banking market in the world to crack. Chime, SoFi, Cash App, Revolut and many others compete with giants like JPMorgan Chase, Bank of America and Capital One, and customer acquisition costs are high. The question: how should Nubank enter the United States?

Key objectives:

1. Build a profitable US franchise, not just a presence.
2. Use Nubank's advantages: low-cost operations, credit underwriting, simple products and Latin American brand recognition.
3. Avoid regulatory and reputational missteps that could threaten the core business.
4. Create a platform for long-term growth.

Step 1

Clarify the Strategic Goals (3-4 minutes)

• Is the goal a mass-market launch or a focused niche first? I'll assume a focused wedge, because a broad launch in the US would require enormous marketing spend.

Why it matters: niche entry lowers acquisition costs and lets Nubank prove unit economics. Impact on approach: choose a segment where Nubank has an unfair advantage.

• What capital and time horizon does leadership accept? I'll assume several years of investment before profitability, with clear milestones.

• Are there constraints from the charter? I'll assume standard national bank requirements: capital, compliance, anti-money-laundering (AML/BSA), consumer protection (CFPB rules), and fair lending.

Strategic assumptions:

1. Nubank's brand is strong among Brazilian, Mexican and Colombian communities in the US.
2. Its credit underwriting can work with alternative data (including Latin American history, with consent).
3. Low operating cost lets it offer better pricing than incumbents.