On Friday December 2nd, the Officer of the
Comptroller of the Currency (OCC) announced that it would consider
granting financial technology (fintech) firms special purpose
national bank charters. The OCC's proposal constitutes a
major development for fintech companies and the financial services
industry more generally. This move builds on recent actions
taken by the OCC in an attempt to promote financial innovation,
including releasing a white paper regarding responsible innovation
in the financial industry in March, and announcing the creation of
an Office of Innovation in October.
Under the OCC's proposed framework, fintech companies may
apply for a special purpose national bank charter—the same
type of charter that the OCC has granted primarily to trust banks
and credit card banks. In a release summarizing the proposal, the
OCC claims that the proposed system will improve safety and
soundness of fintech institutions, promote consistency in the
application of
