“Feds Boost Innovation and Begin Occupying the Field: Treasury Department Report & OCC FinTech Charter”
On July 31, 2018, the Treasury Department released its report on regulatory reform for financial innovation. Among other issues, it recommended the issuance of FinTech national bank charters, the repeal of the payday rule, and the “updating” or adoption of Federal guidelines on a range of activities from nonbank lending to data breach notification. Within hours, the Office of the Comptroller of the Currency (OCC) announced that it will begin accepting applications for FinTech special purpose national bank charters.
This Stroock Special Bulletin summarizes key aspects of the Treasury Department’s Report and the OCC’s announcement, and discusses how they lay the groundwork for a Federal regulatory framework that is not only more hospitable to industry, but also potentially immediately useful in forestalling stringent and fragmented State regulation.