• OCC Updates on Fintech Special Purpose Charter
  • April 17, 2017 | Authors: Lawrence D. Coppel; Christopher R. Rahl
  • Law Firm: Gordon Feinblatt LLC - Baltimore Office
  • We reported in our December 2016 Maryland Legal Alert about the Office of the Comptroller of the Currency's plan to issue special purpose national bank charters (Special Purpose Charters) to fintech firms engaged in certain lending, deposit, and check-cashing activities. The OCC issued a request for comments concerning Special Purpose Charter qualifications, limits on how they should be used, etc. (asking for comments by January 15, 2017). Thomas Curry, the Comptroller of the Currency, made remarks in a recent presentation indicating that the OCC received more than 100 "thoughtful comments" and is planning to roll out its blueprint for how it will issue Special Purpose Charters in a supplement to its Licensing Manual. The Comptroller did not provide any firm indication on the timing for the release of the updated Licensing Manual. The Comptroller did however stress that a Special Purpose Charter will not be a way to get a "light touch" on supervision, re-enforcing our view that obtaining a Special Purpose Charter will not be easy and will come with many compliance/supervisory burdens. For questions concerning this topic, please contact Christopher Rahl.