Hard to Figure: A Fintech Application’s Policy Challenges
Continuing Acting Comptroller Brooks’ policy of considering precedent-breaking applications and charters, the agency has received a controversial application from Figure to establish a national bank that, by virtue of this charter, would also be a Fed member. Although the company has suggested it would take only uninsured deposits, its application leaves open the potential also for taking insured funds. Regardless, Figure is clearly seeking access to the payment system and a platform for banking operations in a novel, controversial charter that could evolve over time without public notice were the OCC to approve this application.

CHARTER28.pdf