In conjunction with a wide-open request for views on ways to increase the innovativeness of national banks and federal savings associations (FSAs), the OCC has proposed a significant rewrite of the more traditional powers and activities these institutions may conduct.  Although much of the lengthy proposal updates national-bank activities and codifies interpretations and market developments, several proposals open existing activities to more flexible standards, provide more generous interpretation of exposures and risks, and represent an overarching effort to increase the ability of national banks and FSAs to offer new products and services regardless of the delivery channel – analog or digital – through which the product is delivered.

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