Recognizing the fast-shifting framework for banking resulting from the disruptive impact of financial-technology (fintech) ventures, the OCC has released a white paper laying out how it plans to consider this new environment and seeking views on it. Although much in the white paper addresses internal OCC organizational matters, its overall thrust is to demonstrate the agency’s determination to make the national-bank and federal-thrift charters under its authority the go-to ones for any fintech ventures that meet evolving prudential requirements. As a result, the OCC is opening itself not only to new ventures through its charters either in existing or new entities but also through providing a framework to address the regulatory uncertainty that often stymies new ventures at banking organizations. The FRB has also indicated some openness to considering new ventures, although none of these regulators has yet taken affirmative action to reduce explicit barriers to innovation such as complex new-product approval protocols and, especially at the OCC, heightened risk management requirements.

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