|Event Date||Wed Oct 3 EDT (about 3 years ago)|
The Office of the Comptroller of the Currency (OCC) announced July 31, 2018, that it will begin accepting national bank charter applications from financial technology companies. In December 2016, the OCC initiated a public comment process concerning fintech charters that culminated with the July 31, 2018, issuance of a Policy Statement on Financial Technology Companies' Eligibility to Apply for National Bank Charters (Policy Statement) and a related supplement to the Comptroller's Licensing Manual (Supplement).
This special purpose charter may be an attractive option for residential mortgage lenders who would benefit from a more streamlined supervisory and examination regime (e.g., one primary regulator), exportation of interest rates and certain fees and preemption of certain state lending requirements, including licensing. While the charter has certain clear benefits, there are certainly some potential disadvantages and a number of unresolved questions that potential applicants should understand.
Partner & Consumer Financial Services Member, Mayer Brown
Partner & Financial Services Regulatory Attorney, Mayer Brown