| As OCC Confirms Protest to
Bunq Silent on Fair Finance Watch Simultaneous
Filing vs WLTC
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY, Jan 14 –
Amid the FDIC's bid to
eliminate public notice of and
public comment on branch
applications, UBS -- Union
Bank of Switzerland -- is
trying to convert to a
national bank in the US and
become a bank holding company.
The OCC has denied the public
hearing request by Fair
Finance Watch.
Meanwhile fellow
money laundering settler Bunq
is applying to the OCC for a
bank, along with a higher
profile application by WLTC
also protested by FFW.
While Inner
City Press simultaneously
challenged Bunq and WLTC, by 7
pm on January 14 the OCC had
only acknowledged FFW's
comment on Bunq - nothing on
WLTC. This as it says its
reviews are apolitical. FFW:
On behalf
of Fair Finance Watch, this is
opposition to the (re)
application for a bank charter
by bunq, which settled money
laundering charges last year
but whose application as of
this morning is not on the
OCC's "Digital Assets
Licensing Applications"
website, and to WLTC NA, which
is now listed there (and on
which Fair Finance Watch first
commented to the OCC on
January 10, incorporated
herein by reference).
For the
record: "On August 25, 2025,
De Nederlandsche Bank (DNB),
the Dutch central bank,
announced a €2.6 million fine
against Bunq for serious
shortcomings in its
anti-money-laundering (AML)
controls. The enforcement
follows repeated warnings to
the Amsterdam-based neobank
over several years."
Since no PDF of
bunq (re) application is on
the OCC's website, it is
impossible to know if bunq,
like so many others, is
counting on today's OCC to
shield it from the Community
Reinvestment Act. On the
second, on which hearing are
clearly needed including on
the obvious structural
conflict of interest of the
Comptroller deciding the
application - we note - and
oppose - this statement:
"Community Reinvestment Act
(CRA) Plan... Not
applicable... as set forth in
Confidential Exhibit B." This
a request for that Exhibit
and/or for the OCC to
immediately review whether it
can legitimately be withheld
under
FOIA.
We note Inner City Press'
pending and unacted on - not
even yet acknowledged - FOIA
request:
"This is a
FOIA request in connection
with the pending Augustus /
Ivy GmbH application to the
OCC, which confines nearly all
details to self-described
Confidential Exhibits. Most
outrageous is the withholding
of the so-called CRA plan:
"Community Reinvestment Act
(CRA) Plan Confidential
Exhibit 10."
This plan is supposed about
the community - but it is
being hidden. Be aware that
for example the Utah
regulator, on PayPal's
application there, recently
after Inner City Press
submitted a state FOIA request
released PayPal's proposed CRA
plan. Why is
the OCC allow proposed new
banks to withhold CRA plans?
And list of affiliates? So
this is a FOIA request for all
of the exhibits described as
Confidentia, and for this
application, already announced
by the applicant
FFW will
have further comments when the
requested information is
released by the OCC - the
comment periods must be
extended.
The
OCC including Comptroller
Gould are on record promising
ever-faster review and
approval of applications. FFW
early (4:12 am) on January 10,
2026 received this, on a CRA
comment submitted a week
before:
From: Burke,
Debra, Debra.Burke at
occ.treas.gov Date: Sat, Jan
10, 2026 at 4:12 AM Subject:
FW: [EXTERNAL]Early Opposition
to the proposal by OceanFirst
to acquire Flushing Bank To:
Fair Finance Watch cc: Inner
City Press Mr. Lee, Thank you
for your email. We do not
currently have a
merger/acquisition application
on file from OceanFirst.
If and when an application is
filed by OceanFirst, the
public portion of the
application will be available
on occ.gov (use the CAS tool)
for your review and
comment. Please let us
know if you have any
questions.
FFW immediately responded, for
the record:
"Fair Finance
Watch does have some
questions, including in light
of Comptroller Gould's public
statements about reviewing and
approving merger applications
faster and faster. 1)
This does not confirm that the
OCC will consider FFW's early
filed comment when the
OceanFirst national bank
application is filed. Does FFW
have to re-file the comment,
such that it will only re
received some period into the
short comment period? 2)
It is not the case that copies
of applications are available
on the OCC website. For
example, the comment period is
already running on Fulton -
Blue Foundry - with no link to
the application, and no copy
provided despite FFW's
December 8 request (and
comment). 3) Why did the
OCC without public notice or
comment cancel the Weekly
Bulletin of pending
applications? What if any
savings did that
occasion? Please
answer these asap.
Four days later, no response.
Instead, we
received a denial of FFW's
November 2025 request for a
public hearing on the bank
application of UBS, itself
with a money laundering
history. Whatever the (lack
of) merits of the OCC's
belated denial of a public
hearing on UBS, one is clearly
needed on
WLTC. On the
current record, these
applications could not
legitimately be approved
UBS, beyond its involvement in predatory
subprime lending - see, e.g., "UBS to pay $300
million to resolve US mortgage securities
cases," August 4, 2025 - has numerous other
compliance scandal on which public hearings
should be held, on this application and
possible plan to relocate to the
US.
There is tax evasion and retaliation against
whisteblowers: “France: UBS fined in France
for harassing whistleblowers”, 10 March 2025
The Swiss bank UBS was fined €75,000
(CHF71,410), the maximum penalty, in Paris on
Monday for moral harassment by its French
subsidiary of two whistleblowers, who had
denounced the tax evasion system organised by
the bank. UBS Europe, which absorbed the
French branch, was also ordered to pay €50,000
in damages to Nicolas Forissier, the former
head of internal auditing.
See, e.g., Sept
10, 2025: https://www.americanbanker.com/opinion/the-fdic-is-undercutting-a-key-element-of-the-cra
But now the
Federal regulator(s) blithely
propose(s) to eliminate public
notice and public comment on
banks' proposals to
expand. The above-quoted
reasoning is that few comments
are filed. So, that is now
changing.
***
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