May 4th, 2020 Office of the Comptroller of the Currency Chief Counsel’s Office 400 7th Street, SW, Suite 3E-218 Washington, DC 20219 Docket ID OCC-2019-0024 Re: Licensing Amendments.
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.