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2016 Press Releases
Idaho Department of Finance Earns Banking Supervision Re-accreditation
California and Missouri Begin Using Uniform Mortgage Test; 50 State Agencies Now Using the Test
North Dakota Department of Financial Institutions Receives Certificate of Mortgage Accreditation
CSBS Names Jim Kurtzke Vice President of Communications
CSBS Announces 2016 Community Bank Case Study Competition Participants
SRR Releases 2015 Annual Report
Colorado Begins Using Uniform Mortgage Test; 51 State Agencies Now Using the Test
Gonzales Appointed to FFIEC State Liaison Committee
Scott Corscadden Named New NMLS Ombudsman
FFIEC Seeks Comments on Proposed Revisions
Financial Regulators Release New Appendix for Retail Payment Systems Booklet
Face Appointed to FFIEC State Liaison Committee
Lawson Elected as State Liaison Committee Chairman
Multi-State Non-Bank Supervision Groups Release Annual Reports
CSBS Releases 2015 Annual Report
12 Student Teams Named Finalists in 2016 Community Bank Case Study Competition
CSBS and MTRA Issue White Paper on State Supervision of MSBs
CSBS Announces New Leadership
Texas Department of Savings and Mortgage Lending Receives Mortgage Reaccreditation
CSBS Announces Winners of the 2016 Community Bank Case Study Competition
CSBS Chairman Challenges State and Federal Regulators to Work Together
Illinois Begins Using Uniform Mortgage Test; 52 State Agencies Now Using the Test
West Virginia Department of Financial Institutions Receives Banking Reaccreditation
FFIEC Issues Statement on Safeguarding the Cybersecurity of Interbank Messaging and Payment Networks
Statement on the Financial CHOICE Act
Statement on Introduction of the Bank Service Company Examination Coordination Act
New Call Report to Streamline Supervision of Money Services Businesses
Fed/CSBS 2016 Community Banking Research Conference to Be Held Sept. 28-29
FFIEC Invites Public Comment on Streamlined "Call Report" for Smaller Institutions
Fed/CSBS Announce Papers Selected for the 2016 Community Banking Research Conference
Financial Regulators Release Revised Information Security Booklet
White Paper Discusses Opportunities for Community Banks to Collaborate
NMLS Launches New Capabilities to Streamline State Licensing Processes
North Carolina Commissioner Ray Grace Appointed
CSBS Releases Second Quarter NMLS
Federal Financial Institutions Examination Council Announces Availability of 2015 Data on Mortgage Lending
Federal Reserve and CSBS Release Findings from 2016 National Survey of Community Banks
Washington Department of Financial Institutions Earns Bank, Mortgage Accreditation
CSBS-Federal Reserve Research Conference Describes the Value and Business Prospects of Community Banks
FFIEC Announces Webinars in Observance of Cybersecurity Awareness Month
Maryland Office of the Commissioner of Financial Regulation Receives Accreditation of Mortgage Supervision Program
CSBS Names Tom Bayer Executive Vice President and Chief Information Officer
FFIEC Issues Frequently Asked Questions Guide on the Cybersecurity Assessment Tool
Third Annual “Your License is Your Business Campaign” Launches Today
CSBS Releases Map of State Requirements for Opening Bank Accounts for Minors
FFIEC Issues Uniform Interagency Consumer Compliance Rating System
State Regulators Oppose OCC Fintech Charter
State Regulatory Group Announces New Cyber Certification Program for Bank Examiners
Statement by the Conference of State Bank Supervisors on Comptroller’s Announcement of New Federal Charters
2017 NMLS Renewal Campaign “Your License is Your Business” Off to Strong Start
FFIEC Streamlines “Call Report” for Small Institutions
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Media Release

Conference of State Bank Supervisors
        1129 20th Street, NW, 9th Floor, Washington, DC, 20036

 Statement by the Conference of State Bank Supervisors on Comptroller’s Announcement of New Federal Charters  

Washington, D.C. – Comptroller Curry today raised important issues related to financial regulation. State regulators agree that financial technology offers potential to improve the financial system’s ability to provide access to credit and operate more efficiently. We look forward to advancing this public debate.

State regulators believe, however, that a special purpose charter from the OCC for fintech firms is fatally flawed, and represents a direction that threatens to damage the U.S. financial system.

Quote attributable to John W. Ryan, president and chief executive officer at CSBS: “Today’s announcement represents an historic expansion of the role of the federal government, one that will permeate into the economies in all 50 states and distort the financial system with unwelcome consequences.”

CSBS has the following concerns about a new OCC charter:

First, a federal fintech charter will distort the marketplace and institute command-and-control innovation. State regulators are concerned that the OCC’s subjective criteria for awarding charters, and its intent to not include the normal regulatory safeguards placed on national banks – such as deposit insurance -- would result in the OCC choosing winners and losers within the fintech industry as well as the broader banking industry, a sharp departure from the role of a financial regulator.

Second, the OCC is expanding its mandate absent statutory authority. The National Bank Act does not give the OCC authority to issue full-service bank charters to institutions that do not engage in deposit taking. To get around this, the OCC is relying on its own regulations – not the National Bank Act – to create a non-depository special purpose charter for fintech firms. However, there is no historical precedent for such a charter in the national banking system. In fact, Congress for more than a century and a half has purposely limited the OCC’s chartering authority, as CSBS made clear in our comment letter of Nov. 14.

Third, despite assurances to the contrary, we believe consumers will be at risk. The OCC has a history of pre-empting state consumer protection laws in ways that damaged consumers. During the early 2000s, many states adopted laws and brought enforcement actions to stop predatory lending. The OCC’s response was to preempt the application of state anti-predatory lending laws to national banks and their operating subsidiaries, thereby permitting unsafe and abusive lending practices to flourish in the lead up to the U.S. financial crisis. It later required congressional action to reset the balance between state and federal regulation in consumer protection. State regulators believe that, when it comes to pre-emption, the past is prologue.

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