In his remarks at the LendIt Conference in New York, Comptroller
of the Currency Tom Curry discussed the special purpose national
bank charters to be granted by the OCC to fintech companies and
addressed the various questions, criticism and challenges that have
been made since the OCC's fintech charter announcement (click
here to read Orrick's previous client alert regarding this
announcement).
OCC Authority
In response to comments challenging the OCC authority and the
wisdom of issuing such charters, Curry said, in no uncertain terms,
that the OCC will be issuing special fintech charters.
Curry said that the OCC has authority under the National Bank Act
to grant special purpose national bank charters to fintech
companies "engaged in the business of banking," including
to firms that do not take deposits. Curry emphasized that limited
purpose charters have been issued for decades. He also said that
the OCC has the knowledge of the relevant models, the
