OCC To Charter FinTech Banks, Solicits Comments

Taking another step in its responsible innovation initiative, the Office of the Comptroller of the Currency (the "OCC") recently announced that it will consider granting special purpose national bank charters to FinTech companies and is soliciting public comment on a number of questions. The comment period closes on January 15, 2017.

Chartering Authority

The OCC has precedential authority to charter a limited purpose national bank as long as it conducts one of the three main core banking functions: (1) receiving deposits, (2) paying checks (and modern equivalents such as debit cards, electronic payment processing and digital currency) or (3) lending money. The OCC has relied on this authority to charter two types of limited purpose banks: trust banks and credit card banks.