Volume: 11 Issue: 4
In December 2016 the Office of the Comptroller of the Currency (‘OCC’) in the US announced that it will issue special purpose national bank charters for FinTech companies. This move drew varied responses from industry, including to the white paper the OCC subsequently released. The OCC has since published a draft supplement to its Licensing Manual entitled ‘Evaluating Charter Applications from Financial Technology Companies,’ which asks the public for feedback. In this article, Alan W. Avery, Vivian Maese, Louis Trotta, Pia Naib and Will Clark of Latham & Watkins provide a detailed look at the rules applicable to such special purpose national bank charters and the chartering process, and also examine the reaction to the OCC’s proposals in the FinTech space thus far.