News & Events

Partner Keith Noreika was quoted in a Law360 article addressing the Office of the Comptroller of the Currency’s (OCC) decision to begin accepting applications from non-deposit-taking fintech firms for special-purpose national bank charters. Keith, former Acting Comptroller of the Currency, discussed how the charter will work, specifically how much capital a firm will have to hold and what its financial inclusion requirement will be, and aspects which may result in litigious action from states. “My own personal view, having had to look at this sitting in the comptroller’s chair, is that the OCC is right on the merits,” Keith said. “I think there’s a very high likelihood they will succeed in a challenge by the states, but still, if you’re investing your own money to get one of these things, you may be buying a lawsuit and that may be something people are worried about and, obviously, no litigation is certain.”

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