It will also need separate supervisory sign-off for four activities: retail foreign-exchange trading, FX forward contracts, merchant acquiring and correspondent banking for foreign banks.

Foreign exchange and payments are at the heart of what the company does. So the regulatory process isn’t just about whether Revolut can become a bank. It’s also about whether regulators are comfortable with how it plans to operate some of its most important products in the U.S.

And that tells us something about where fintech is heading. For years, fintech companies have been able to build financial products without actually being banks. The model was relatively simple. A fintech built the technology, owned the customer relationship and designed the experience, while a licensed bank provided the regulated infrastructure behind the scenes. It was a good model for moving quickly.

But it came with a trade-off: the fintech didn’t fully control the banking infrastructure it was building on. Now some of the biggest companies in the sector are starting to ask whether that trade-off still makes sense. What happens when the bank itself becomes part of the product?

Chime is taking a different approach. Rather than applying for a new charter, Chime has agreed to acquire Stride Bank, one of its existing banking partners. The deal still needs regulatory approval, but if completed, it would give Chime much more control over the banking infrastructure behind its business.

The reason is fairly obvious. As a fintech gets bigger, its relationship with its banking partners becomes increasingly important.

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