New Office of the Comptroller of the Currency Fintech Regulation: Ensuring a Successful Special Purpose National Bank Charter Application

  • Alexa Philo


Financial technology (fintech) companies evaluating whether to apply for an OCC Special Purpose National Bank (SPNB) charter must consider a variety of factors. Among them are the regulatory and compliance requirements they will need to adhere to; the work involved in applying for the charter and transitioning to full conformance; the challenges (and opportunities) associated with competing against traditional banks; and the strategic and operational changes that may be required down the road to align with the OCC’s expectations on an ongoing basis.


fintech fintech regulation OCC Capital planning/funding Enterprise risk management Liquidity/funds management Risk assessment Stress scenarios 


  1. Brear, D. (2015, July 20). What differentiates banking and fintech. Retrieved November 28, 2018, from The Financial Brand
  2. Lang, H. (2018, August 17). Fintechs have more work to do to prevent discrimination: Congressman. Retrieved November 28, 2018, from American Banker
  3. LendingClub Corporation. (2017, December 31). SEC 10-K filing. Retrieved November 28, 2018, from Securities and Exchange Commission
  4. Office of the Comptroller of the Currency. (2018, July). Considering charter applications from financial technology companies. Retrieved November 28, 2018, from

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© The Author(s) 2019

Authors and Affiliations

  • Alexa Philo
    • 1
  1. 1.BrooklynUSA

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