Building on its white paper laying out fintech policy, the Office of the Comptroller of the Currency has laid out a proposed framework governing approval criteria for the special-purpose charters sought by financial technology (fintech) companies that cannot or do not wish to meet the criteria needed to establish a full-purpose national bank. Reflecting the current Comptroller’s priorities, these fintech charters would come under express financial-inclusion requirements if they offer lending (apparently regardless of to whom) or consumer and small-business services. Comment would be solicited on these plans, essentially creating a transparent version of Community Reinvestment Act (CRA) standards for many fintech charters subject to public comment as a chartering condition. Fintech charters would also come under bank-like leverage and risk-based capital rules, although the OCC has reserved authority to vary these based on the nature of a fintech charter.
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