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.
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