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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