Despite significant concerns raised by a number of interested parties—including hundreds of advocacy groups, state regulators, and a bipartisan group of Members of Congress—the OCC is moving forward with its fintech charter proposal. This comment letter asserts that the OCC does not have the legal authority to charter non-depositories, that a national bank charter for non-depository fintech institutions will facilitate consumer harm through preemption of strong state laws, and that federal supervision from the OCC is not a substitute for critical safeguards that exist at the state level.
