10 August 2018
On July 31, 2018, the Office of the Comptroller of the Currency (the "OCC") announced that it will begin to accept special purpose national bank charter applications from financial technology ("FinTech") companies. Concurrently, the OCC published a Policy Statement on Financial Technology Companies' Eligibility to Apply for National Bank Charters and Comptroller's Licensing Manual Supplement: Considering Charter Applications from Financial Technology Companies. The OCC special purpose national bank charter for FinTech companies may be attractive to FinTech companies that provide or intend to provide technology-enabled lending and/or payment services.
This briefing outlines the pros and cons of the OCC FinTech Charter, along with certain other observations and considerations of an alternative to that charter.