While we appreciate the consideration given to the need for regulatory coordination with respect to financial innovation, we believe that the Bureau should continue to make clear that it lacks the authority to waive state disclosure requirements…
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.