The Clearing House (TCH) joined by SIFMA and the ICBA, submitted a letter to the OCC in response to its white paper on Exploring Special Purpose National Bank (SPNB) Charters for Fintech Companies. The letter argues that: (i) more concrete guidance is needed from the OCC on its expectations about the types of businesses it considers eligible for an SPNB charter; (ii) the regulatory and supervisory framework for SPNBs should be transparent to both FinTech companies considering seeking a charter and companies dealing with FinTech SPNBs on an ongoing basis; (iii) regulatory coordination is necessary to ensure that well-established principles of bank regulatory policy, such as separation of banking and commerce and consolidated supervision, are not undermined as FinTech companies are incorporated into the supervised financial services sector; (iv) issues of consumer protection and financial inclusion must be the subject of consistent, rigorous, and transparent application across FinTech SPNBs and full-service national banks; (v) the OCC must establish a fair and level competitive playing field to address the concern that FinTech SPNBs would be able to offer services and products in direct competition with full-service banks, but subject to a more limited and less burdensome regulatory regime; and (vi) the OCC should engage in a robust outreach program for the White Paper’s FinTech SPNB proposal, which could include convening a public hearing as well as a formal rule-making process subject to the Administrative Procedure Act.
You Might Also Be Interested In...
FinTech & Innovation Distributed Ledger Technology: A Case Study of The Regulatory Approach to Banks’ Use of New Technology
More Posts by This Author
Security BPI and Joint Trades Comment on FCC’s Second Notice of Proposed Rulemaking on Illegal Text Messages
Regulatory Reporting and Accounting BPI Supports Call Report Revisions to Improve Securities Reporting Consistency