State regulators remain concerned about the ability of lenders to use the internet to reach borrowers in states where payday lending is restricted. The Bureau’s 2017 Rule would not have prevented illegal payday lending, but its implementation would…
On the OCC’s White Paper: Exploring Special Purpose National Bank Charters for Fintech Companies
Jan 17, 2017
As stated in our November 2016 comment letter to the OCC 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.