In this analysis, we build on prior work highlighting opportunities in the mortgage sector via the new special-purpose national bank (SPNB) charter soon to be offered by the Comptroller of the Currency. Since our prior work, the OCC has pressed forward despite Congressional and industry critics, now laying out the specific criteria on which chartering decisions will be based. We turn here to how these new requirements affect mortgage-focused charters and how this framework could change as Trump Administration policy takes hold at the financial regulators. As in any assessment of financial policy, details really make a difference – the SPNB will work very, very differently based on the business objective and the way the OCC decides to let a company achieve it.
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