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.
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:
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