On December 2, 2016, Comptroller Thomas J. Curry of the Office of the Comptroller of the Currency (“OCC”) announced that the OCC will move forward with chartering financial technology (“FinTech”) companies that offer bank products and services and meet the OCC’s chartering requirements. However, while encouraging, the announcement, and the OCC paper released with it, left many issues unresolved.
The OCC did not provide a timeline for accepting or issuing the proposed special purpose national bank charters. In addition, while recognizing that FinTech charters will be different, the OCC did not clarify whether or how those differences would be reflected in the chartering process, standards, or subsequent supervision. The OCC simply stated that the standard chartering process would apply.
To read the full Alert Memo, click here.