The letter commends the OCC for its recognition that technologically driven innovation is reshaping the financial system and requires a recalibration of the regulatory approach. Our letter offers several recommendations to support the OCC’s objectives, including clarifying existing supervisory expectations, in particular, that banks are not expected to receive prior OCC approval before developing a new product, process or service; refining the scope of the Pilot Program to multi-bank projects or other cases raising novel interpretive issues; and treating the Pilot Program as a “safe zone” allowing banks to innovate in good faith without facing supervisory action.
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