The news: Brazil-based Nubank applied to the OCC for a national bank charter to expand into a country with an adult population of over 250 million and a substantial Latino demographic, particularly in the Southwest.

The backdrop: Nubank was founded in 2013 to serve underbanked consumers. It entered Mexico in 2019 and Colombia in 2020. For the year 2024, Nubank reported $11.51 billion in revenues (in the same neighborhood as Truist). In Q2 2025, it reported over 122 million customers between its core markets.

Nubank has chased growth by entering Latin American countries with huge addressable markets of consumers and businesses that are poorly served by incumbent financial institutions. Its scale goes beyond payment accounts and debit cards to credit cards, secure loans, insurance, and crypto.

The opportunity: The FDIC found in a 2023 study that the US unbanked rate was 4.2% (5.3 million households) and that 14.2% of households (19.0 million) were underbanked (primarily using nonbank products and services for financial needs). That’s 24.3 million households out of 131.4 million total that year.

Big questions: The Hispanic unbanked rate is higher than average in the US, according to the FDIC study, but not earth-shatteringly so. And the number of unbanked and underbanked consumers is declining.

One question that needs to be asked is: What market could, would, or should Nubank go for in the US? A second is: Is that opportunity big enough?

Our take: Acquiring a national bank charter doesn’t mean opening a bank for the sake of deposits and lending—payment services without a bank partner may be the goal, at least for now. That would connect Latin Americans with counterparts in the US, competing with remittance services.

But a splashy entrance into the US would mean a fight against megabanks for higher-income customers and behemoths like Chime for customers underserved by traditional financial institutions. Nubank will struggle to scale in the US as quickly as has in Latin America.