On July 31, 2018, after a review period following its initial proposal, the Office of the Comptroller of the Currency (OCC) announced it would begin accepting applications for its special purpose national bank charter for financial technology (fintech) companies. While the New York State Department of Financial Services has (again) sued the OCC claiming that it lacks the legal authority to issue this type of charter, companies are actively exploring the OCC fintech charter as well as other bank charter alternatives, such as industrial loan companies (ILCs), to facilitate their nationwide operation. Because many of these companies want to avoid owning a “bank” and being regulated as a bank holding company, there is a particular interest in those depository institutions excluded from the Bank Holding Company Act’s definition of “bank.”
Please join Mayer Brown partners Tom Delaney, Jeff Taft and Don Waack as they answer:
- What are the potential advantages and disadvantages of an OCC fintech charter?
- What are the alternative banking charters, such as ILCs, credit card banks and full-service insured depository institutions?
- What is a “bank holding company”? (And why you may want to avoid this status.)
Mayer Brown’s Global Financial Markets Initiative helps clients deal with the legal and business challenges resulting from the ongoing turbulence in worldwide financial markets. By mobilizing the firm’s global resources from multiple practices and offices, the initiative provides clients with knowledgeable and timely counsel on a broad spectrum of their legal needs.
For additional information or to register, please contact GFM@mayerbrown.com.