SFIG Submits Response to OCC Regarding Special Purpose National Bank Charter for Fintech Companies

On Friday, January 13th, SFIG submitted a response to the Office of the Comptroller of the Currency's (OCC) request for comment on "Exploring Special Purpose National Bank Charters for Fintech Companies."

SFIG's response focused on four primary issues that are most important to the securitization markets:

  • Special purpose national bank charters for fintech companies will facilitate greater stability and thereby increase overall lending;
  • The rules and standards applicable to special purpose national banks will afford consumers greater safety and confidence in fintech products;
  • If the OCC includes public policy driven conditions within its charters, then the agency should systemically impose such conditions; and
  • The OCC should affirm the treatment of financial assets transferred in connection with a securitization.

If you would like to join SFIG's Marketplace Lending Committee, please contact Michael.Williams@sfindustry.org.

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