By Julia Dempewolf on Posted in OCC Fintech CharterEarlier this summer the Office of the Comptroller of the Currency issued the anticipated announcement that fintech companies engaged in the business of banking may apply for special purpose national bank charters. In conjunction with its announcement, the Comptroller of the Currency, Joseph Otting, adopted a Policy Statement describing how the agenc… Read the rest
By Andrew J. Lorentz and Julia Dempewolf on Posted in OCC Fintech CharterOn March 15, 2017, the Office of the Comptroller of the Currency issued a “Draft Supplement” to the Comptroller’s Licensing Manual, entitled “Evaluating Charter Applications from Financial Technology Companies” (Supplement). The OCC’s Supplement is designed to provide substantive standards and procedures for the OCC’s evaluati… Read the rest
By Davis Wright Tremaine on Posted in OCC Fintech CharterOn February 21, DWT Payments team members Andy Lorentz and Tom Scanlon took part in a discussion organized by NYPAY that focused on the prospects of the OCC special purpose fintech charter. The questions discussed included, “Will the concept survive the many challenges it can be expected to attract, including from fellow regulators? What kind of co… Read the rest
By Davis Wright Tremaine on Posted in OCC Fintech Charter
At ACI’s 13th National Forum on Emerging Payment Systems Conference in Washington, D.C., DWT’s Emerging Payments and Prepaid practice leader, Andy Lorentz, discussed the climate for payments innovation in the context of the OCC’s “FinTech” charter. During the discussion, which was presented as part of a panel entitl… Read the rest
By Julia Dempewolf on Posted in OCC Fintech CharterOn June 23, the Office of the Comptroller of the Currency hosted an all-day forum on supporting responsible innovation in the federal banking system. The forum builds on the OCC’s white paper on responsible innovation, which the agency released in the spring. Our analysis of the white paper is available here. The OCC’s forum included speakers from acr… Read the rest
By Davis Wright Tremaine on Posted in OCC Fintech CharterOn March 31, the Office of the Comptroller of the Currency articulated its “vision” for responsible innovation in the federal banking system in the form of a white paper, continuing the agency’s own multi-year initiative to stay abreast of developments in the financial services industry. The OCC’s stated goal is to build the regulatory framew… Read the rest
Our Payments Team addresses changes and continuities in the payments industry every day—leveraging our many years of industry experience and our presence on both coasts and in China. On paymentlawadvisor, we offer commentary on new developments that seem particularly significant, as well as resources that we believe can be helpful to others who are tasked with anticipating, understanding and addressing these developments.