On December 2, 2016, Comptroller of the Currency Thomas J. Curry
announced that the Office of the Comptroller of the Currency
("OCC") would move forward with considering applications
from fintech companies that conduct at least one of three core
banking activities (i.e., receiving deposits, paying checks or
lending money) to become special purpose national banks. Fintech
companies will have the option to seek a charter, and the OCC will
evaluate applicants to ensure they have a reasonable chance of
success, appropriate risk management, effective consumer protection
and strong capital and liquidity.
The OCC simultaneously published a paper discussing the issues
and conditions that the agency will consider in granting special
purpose national bank charters. Comments to the paper may be
submitted through January 15, 2017. For further discussion relating
to the announcement, please see "National Bank Charters for
Fintech Companies."
Orrick Alert. Release. White Paper.
