An Update on OCC's Special Purpose National Bank Charters
Member Price: $49.00
Nonmember Price: $79.00
Product Code: DL2-011490-WC-WPurchase
Live webinar held on October 3, 2018.
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.Objectives:
- Potential benefits to residential mortgage lenders and other types of technology companies.
- How the special-purpose bank charter could help lower compliance costs, particularly in the area of licensing.
- Key features of this charter and the related supervisory expectations.
- Unresolved questions pertaining to the special purpose national bank charter.
- Preparing an application and business plan and navigating the chartering process.
- How potential lawsuits and other bank charter options could impact the desirability of special purpose national bank charter.
- Melanie Brody, Partner & Consumer Financial Services Member, Mayer Brown
- Jeff Taft, Partner & Financial Services Regulatory Attorney, Mayer Brown
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