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Abstract: 

A fintech company considering applying for a national bank charter must thoroughly understand what the OCC has proposed for such charters. The authors lay out this subject by describing (1) what is available; (2) the potential benefits; (3) what is required; and (4) whether it is worthwhile. They conclude that, given the rigorous requirements, the significant benefits of a charter would be worthwhile only for well-established and stable fintechs with deep financial and human resources. *This article is adapted, with updates by the authors, from The Review of Securities & Commodities Regulation, © RSCR Publications LLC, and is available for download for Journal of Taxation & Regulation of Financial Institutions subscribers only; no pay-per-article option is available.

Keywords: fintech, bank charter, special purpose bank, Comptroller of the Currency

Affiliations:  1: Pepper Hamilton LLP; 2: Pepper Hamilton LLP.