On Dec. 2, 2016, the Office of the Comptroller of the Currency (OCC) published a preliminary proposal to create a national bank charter for financial technology companies (fintech). The OCC’s rationale in support of the proposal was that such a charter could promote the safety and soundness of fintech institutions, bring greater legal and regulatory uniformity and consistency, and strengthen the federal banking system. Despite being a somewhat amorphous proposal and invitation for comment, the proposal drew prompt reaction for state financial regulators, highlighting some of the tensions inherent in any eventual OCC charter for fintech.

To learn more, please read the GT Alert, “OCC Consideration of Special Purpose Fintech Charters Draws Rapid Reaction for State Banking Regulators.”

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Photo of Andrew S. Wein Andrew S. Wein

Andrew S. Wein is a regulatory, litigation, and corporate attorney who represents financial services clients. His national practice focuses primarily on mortgage companies and other consumer financial institutions, assisting them with both litigation and regulatory compliance. Andrew handles litigation and regulatory issues arising…

Andrew S. Wein is a regulatory, litigation, and corporate attorney who represents financial services clients. His national practice focuses primarily on mortgage companies and other consumer financial institutions, assisting them with both litigation and regulatory compliance. Andrew handles litigation and regulatory issues arising out of federal and state consumer protection statutes, including the Real Estate Settlement Procedures Act, Truth in Lending Act, Fair Debt Collection Practices Act, Fair Credit Reporting Act, Telephone Consumer Protection Act, Home Mortgage Disclosure Act, Secure and Fair Enforcement for Mortgage Licensing Act, and the Home Affordable Modification Program.

On the regulatory side, Andrew’s experience includes proceedings before state and federal agencies, including the Consumer Financial Protection Bureau, the U.S. Department of Housing and Urban Development, and the New York Department of Financial Services. In addition, Andrew has deep experience with all facets of the mortgage industry, including the licensing of mortgage companies and their affiliates, examinations by state and federal agencies, loan repurchase disputes, pooling and servicing agreements, financing agreements, and various other originations and servicing transactions.

Photo of Gil Rudolph Gil Rudolph

Gil Rudolph focuses his practice on the representation of finance companies, banks, mortgage originators and servicers, lease company transactions, retail installment transaction financers and other consumer financial service providers in regulatory and litigation matters. Gil also represents various alternative financial service providers, including…

Gil Rudolph focuses his practice on the representation of finance companies, banks, mortgage originators and servicers, lease company transactions, retail installment transaction financers and other consumer financial service providers in regulatory and litigation matters. Gil also represents various alternative financial service providers, including small dollar/short term lenders, check cashers, pawn and auto title lenders. He additionally represents various participants in the credit, debit, and prepaid card issuance and processing industries.