The proposed rule states that currently, validation notices, combined with the limited disclosure of consumers’ rights with respect to debt collection, may limit a consumer’s ability to fully exercise their dispute rights.
Comment Letter: On the OCC’s White Paper: Exploring Special Purpose National Bank Charters for Fintech Companies
Jan 13, 2017
State bank regulators oppose the creation of a special purpose national bank charter for financial technology (fintech) and other nondepository companies because:
- The OCC lacks statutory authority to issue such a charter;
- Such a charter will distort the marketplace for financial services, with a federal agency arbitrarily picking winners and losers;
- 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
- The preemptive effect of this charter nullifies the states’ ability to protect consumers.