OCC Releases Draft Chartering Manual for FinTech Banks

    View Authors April 2017

    On March 15, 2017, the Office of the Comptroller of the Currency (OCC) released a draft supplement to the Comptroller’s Licensing Manual on “Evaluating Charter Applications from Financial Technology Companies.” While the OCC does not normally release drafts of the Licensing Manual for public comment, according to the OCC, it is doing so in this instance to be “consistent with its guiding principles of transparency and fostering open dialogue with stakeholders.” Comments are due April 14, 2017. In connection, the OCC also released the “OCC Summary of Comments and Explanatory Statement: Special Purpose National Bank Charters for Financial Technology Companies.”

    In the first part of this alert, we summarize the OCC’s releases and in the second part, we explore a few of the public policy implications.