On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its much-anticipated white paper on the growing intersection between financial services and technology, or “FinTech.” In this white paper, the OCC outlines steps that it is considering to make the agency more receptive to what it deems “responsible innovation.” From internal training programs, to making examination, legal, and information technology staff available for consults with the industry, to providing a forum for reporting on innovation success stories, the OCC appears willing to embrace the synergies that may result from the collaboration of banks and technology firms. The OCC cautions however that banks, in selecting their tech partners, must still consider some of the risks that are inherent in any third-party relationship. The OCC is also soliciting comments on a number of questions regarding regulation of FinTech.
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