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ARTICLE · 22 DECEMBER 2016

US Exploring Special Purpose National Bank Charters For Fintech Entities

McCarthy Tétrault
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On December 2, 2016, the United States' OCC announced that it would move forward with considering applications from Fintech companies to become special purpose national banks.

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Ana Badour
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On December 2, 2016, the United States' Office of the Comptroller of the Currency (OCC) announced that it would move forward with considering applications from Fintech companies to become special purpose national banks. The OCC also published a paper discussing the issues and conditions that it will consider in granting special purpose national bank charters (the "OCC Paper").

Background

The OCC's chartering authority includes the authority to charter "special purpose national banks", for example trust banks and credit card banks. A special purpose national bank must conduct at least one of the following functions: fiduciary activities, receiving deposits, paying cheques, or lending money. Fintech entities engaging in such activities would be granted the option to apply for a special purpose national bank charter. There is currently no equivalent concept in Canada to "special purpose national banks" and the Bank Act generally treats banks that are chartered in

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