The Clearing House (TCH) submitted a letter to the OCC responding to their recent release of a draft supplement to its licensing manual entitled Evaluating Charter Applications From Financial Technology Companies. This letter is largely consistent with the comment letter TCH submitted in January 2017 responding to a white paper the OCC released on the same topic. However, in this most recent letter, TCH offers two additional comments for the OCC to consider. Specifically, TCH recommends that the OCC should: (i) clarify what qualifies as a “FinTech” company and what would constitute as “core banking activities” for purposes of determining charter eligibility, and (ii) clarify types of commercial activities it deems appropriate to commingle with banking activities.
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