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Comment Letter: On the OCC’s White Paper: Exploring Special Purpose National Bank Charters for Fintech Companies

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State bank regulators oppose the creation of a special purpose national bank charter for financial technology (fintech) and other nondepository companies because:

  1. The OCC lacks statutory authority to issue such a charter;
  2. Such a charter will distort the marketplace for financial services, with a federal agency arbitrarily picking winners and losers;
  3. The issuance of such a charter creates tremendous uncertainty and risks pertaining to access to critical government resources, including the payments system and the federal safety net; and
  4. The preemptive effect of this charter nullifies the states’ ability to protect consumers.

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