the rails

Nubank has three banking licences. To enter the US it rented a fourth.

September 11, 2026 · 6 min read · ← all posts · the dataset

On 10 September, Nu — the company most people still call Nubank — opened for business in the United States. A deposit account paying 3.5%, a no-annual-fee Mastercard with 1.5% cashback, free domestic and international transfers, and Nu Global, a multi-currency account that moves money across more than 35 countries.

It arrives with numbers almost nobody in this industry can match. In Q2 2026 it reported 139 million customers, revenue of about $5.9 billion (up 39% year over year), and net income of $1.06 billion — the first quarter in its history above a billion dollars, at a 33% return on equity. It holds its own banking licences in Brazil, Mexico and Colombia.

And to launch in the United States, it is using somebody else's.

The Lead Bank arrangement

Nu's US deposits sit at Lead Bank, an FDIC-insured lender that appears in our infrastructure map because it already carries a number of American fintechs. Nu supplies the app, the brand and the distribution; the charter, and the legal relationship with your money, belong to the partner.

That is the partner-bank model, and it is the single most common structure in American consumer fintech. It is also, on this site's reading of the evidence, the structure with the most moving parts — three of the six neobanks in our graveyard died when the institution underneath them withdrew.

None of which makes Nu's choice wrong. It makes it normal, and that is the striking part. If a company with 139 million customers, a $1 billion quarter and three national banking licences still enters the US market on rented rails, the licence is not a detail that ambitious companies simply acquire when they are big enough. It is a genuine barrier, and most never cross it.

What the American market actually looks like

We track 61 neobanks headquartered in the United States and Canada. The licence split is stark:

StructureCountWhat it means for your money
Holds its own bank charter10The company you signed up with is the bank. Deposit insurance and a regulator-run resolution if it fails.
Partner-bank model38A licensed bank holds the balance; the app is a brand and an interface on top.
Other (e-money, payment, crypto permissions, self-custody)13Varies — and the variation is the whole point of reading the profile.

Ten out of sixty-one. Across the whole dataset the ratio is a little better — 132 of 381 tracked neobanks hold their own licence — but the American picture is the extreme version, and it is the market Nu just walked into.

The charter is coming, unusually fast

Nu is not content to rent indefinitely. It applied to the OCC for a national bank charter on 30 September 2025 and received conditional approval on 29 January 2026 — 121 days, against a historical norm measured in years. It is now in the bank organisation phase: capitalise within twelve months, open within eighteen, with FDIC and Federal Reserve approvals still to come. Roberto Campos Neto, until recently governor of Brazil's central bank, chairs the new entity.

So the honest way to record this moment is as a transition, not an arrival. Today Nu's American customers are customers of a fintech whose partner bank holds the money. If the charter completes, they become customers of a bank. Those are different products wearing the same app icon, and the difference only becomes visible on the worst day.

what changed in the datasetNubank's profile now reads 139M customers (Q2 2026), up from 131M, with the United States added to its availability and the Lead Bank arrangement recorded alongside its three banking licences. As always the change is in the changelog and the raw fields are in data.json.

The part that should worry incumbents

Nu is not entering the US with a better savings rate, though 3.5% is competitive. It is entering with an operating model built for customers American banks have historically priced as marginal — and refined across 139 million of them in three countries where the unit economics are far harder than they are in the United States. David Vélez has said the US business will take years to turn a profit and has talked about ten to twenty million customers over the long run, with young digital-first consumers and the US Hispanic population as the initial target.

Meanwhile the centre of gravity in this industry sits far from the US: 817 million of the neobank users we track are in Asia, 354 million in Latin America. Nu is the first company from that larger half of the market to bring its playbook into the smaller, louder one at full scale. Whether the American model bends to it is the question worth watching, and it will take longer than a launch week to answer.

go deeperNubank's full profile — custody, licences, cards, every field with its source · the North America chapter — all 61, and a steward seat that is still open · who actually holds your money — how to read the structures above.