FinTech Update: OCC Financial Inclusion Rules Present Uncertainties for Applicants
In March, the OCC issued draft licensing procedures on the chartering process for fintech companies. These procedures outline a set of supervisory criteria specific to fintech companies that the OCC will use when evaluating applications for fintech charters, including a requirement that a fintech applicant demonstrate its commitment to “financial inclusion” if it intends to engage in lending or providing financial services to consumers or small businesses. This “financial inclusion” requirement presents several uncertainties for applicants, and is expected to be an area of significant discussion with OCC staff during the application process.