Alert

March 15, 2017

OCC Issues Draft Licensing Manual Supplement for Evaluating Charter Applications from Financial Technology Companies

On March 15, 2017, the Office of the Comptroller of the Currency published the Comptroller's Licensing Manual Draft Supplement (the "Supplement") for evaluating charter applications from financial technology ("fintech") companies. Extensive regulations and policies already exist that govern the OCC's review and decision making with respect to chartering national banks. However, the Supplement provides additional details on how the OCC will evaluate national bank charter applications from fintech companies that engage in the business of banking. In particular, the Supplement will describe:

• how the OCC will apply the licensing standards and requirements in existing regulations and policies to fintech companies applying for special purpose national bank charters;
• unique factors that the OCC will consider in evaluating applications from fintech companies;
• expectations for promoting fair access, fair treatment, and financial inclusion; and
• the OCC's approach to supervising those fintech companies that become national banks.

The OCC will accept comments on the Supplement through the close of business on April 14, 2017. Comments should be submitted to specialpurposecharter@occ.treas.gov.

In addition, the OCC released the comments submitted in response to its December 2016 white paper discussing issues associated with chartering fintech companies.