The recent decision by the US Office of the Comptroller of the Currency to allow fintech companies to apply for special-purpose national bank (SPNB) charters is good news for some such companies, particularly those that are well capitalized and have a strong management team. However, fintech companies will need to review the December 2, 2016, announcement with care to consider whether an SPNB charter is the right choice for them and how the announcement will change the competitive landscape. This Legal Update provides an overview of the announcement, some of the key points for consideration by companies evaluating whether to apply for an SPNB charter, and a brief summary of the chartering process and certain national bank application requirements.
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