From SOFOM to Bank: Scaling Non‑Bank Financial Services Across Latin America

Mexico’s fintech ecosystem is undergoing a remarkable evolution—from nimble unregulated operations to full banking institutions. One compelling example is Nubank’s Mexican arm, Nu Mexico, which began as a SOFIPO, secured over 12 million customers, and has now obtained approval to become a fully licensed bank. This milestone sets a precedent for how financial innovators can scale deliberately and sustainably.

The Path from SOFOM → Regulated SOFIPO → Bank

  1. Start as an Unregulated SOFOM (ENR) – Many fintechs begin as unregulated multiple-purpose financial companies (SOFOM ENR), focused on credit without heavy regulatory oversight. This structure allows rapid launch and agile product development.
  2. Transition to a Regulated Entity—SOFOM ER or SOFIPO – As businesses gain momentum and customer trust, evolving into a regulated financial institution like a SOFOM ER or SOFIPO becomes the next logical step. These entities are overseen by the CNBV, enabling deposit-taking and public trust.
  3. Secure a Full Banking License – Once deposit volume, customer base, and operational maturity reach significant thresholds, applying for a full banking license opens the door to offering expanded services—like payroll accounts, higher deposit coverage by IPAB, and broader product suites. This is exactly what Nu Mexico is doing after securing CNBV approval to transform into a bank.

Fintech players across Latin America are following a similar trajectory. For instance, Mercado Pago and Revolut have also applied for or received banking licenses in Mexico, signaling a broader shift towards regulated full-banking models.

Scaling Across Latin America: Expansion Strategies

Once the core Mexican operation is bank-ready, the model can be replicated across the region through:

  • Sales Offices or Commissioned Representative Offices – These serve as strategic outreach hubs—facilitating partnerships, market intelligence, and customer acquisition without full licensing.
  • Additional Licensed Entities – Launching local SOFOMs, SOFIPOs, or banks in other LATAM jurisdictions allows businesses to tailor offerings to each market’s legal framework, increasing reach while maintaining compliance.

This cross-border multi‑stage strategy—from unregulated entity to bank, then regional rollout—combines agility with credibility, enabling fintechs to scale prudently and thoughtfully.

Tailored Growth: Your Strategic Playbook

  • Launch fast with a SOFOM ENR – Deliver credit products or alternative lending solutions under minimal regulatory burden.
  • Build trust—transition to SOFIPO or SOFOM ER – Unlock deposit-taking, strengthen compliance frameworks, and expand service capabilities.
  • Achieve banking status – Expand product range fully, gain IPAB protection, and reinforce customer confidence.
  • Grow regionally – Use representative hubs for expansion and establish compliant entities across Latin America.

Take the Next Step

Contact us today to explore how we can guide you through each stage—crafting a scalable, compliant financial platform that evolves from nimble fintech to trusted Latin American banking powerhouse.

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