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Among other things, he asked various questions about whether existing laws were adequate in addressing and promoting responsible innovation. He asked if the innovations seen in marketplace lending should be regulated, who should be responsible for regulating an organization or activity.
This is where he spoke of the possibility of a federal license or charger for marketplace lenders and fintech firms. In talking about a fintech charter, he stated that some believe a federal charter could help responsible innovation through ensuring fintech companies receive rigorous, bank-like federal regulation and ongoing supervision.
However, he said others have voiced concerns that a fintech charter would allow fintech companies to avoid certain state consumer protection laws. The paper sought public responses to poloniex llc operating systems following specific questions to help them assess the pros and cons of a fintech charter:. We believe that, from a public policy perspective, it is far better for financial services regulators to be active participants than onlookers.
Protection of poloniex llc operating systems, small businesses, and the financial system itself will be more effective if carried out by supervisors who are fully informed and knowledgeable.
Posted on February 8, by Editor. You are commenting using your WordPress. You are commenting using your Twitter poloniex llc operating systems. You are commenting using your Facebook account. Notify me of new comments via email. The paper sought public responses to the following specific questions to help them assess the pros and cons of a fintech charter: What are the public policy benefits of approving fintech companies to operate under a national bank charter?
What are the risks? What elements should the OCC consider in establishing the capital and liquidity requirements for an uninsured special purpose national bank that limits the type of assets it holds?
What information should a special purpose national bank provide to the OCC to poloniex llc operating systems its commitment to financial inclusion to individuals, businesses and communities?
For instance, what new or alternative means e. How could an uninsured special purpose bank that uses innovative methods to develop or deliver financial products or services in a virtual or physical community demonstrate its commitment to financial inclusion? Should the OCC seek a financial inclusion commitment from an uninsured special purpose national bank that would not engage in lending, and if so, how could such a bank demonstrate a commitment to financial inclusion?
How could a special purpose national bank that is not engaged in providing banking services to the public support financial inclusion? Should the OCC use its chartering authority as an opportunity to address the gaps in protections afforded individuals versus small business borrowers, and if so, poloniex llc operating systems What are potential challenges in executing or adapting a fintech business model to meet regulatory expectations, and what specific conditions governing the activities of special purpose national banks should the OCC consider?
What actions should the OCC take to ensure special purpose national banks operate in a safe and sound manner and in the public interest? Would a fintech special purpose national bank have any competitive advantages over full- service banks the OCC should address?
Are there risks to full-service banks from fintech companies that do not have bank charters? Are there particular products or services offered by fintech companies, such as digital currencies, that may require different approaches to supervision to mitigate risk for both the institution and the broader financial system?
How can the OCC enhance its coordination and communication with other regulators that have jurisdiction over a proposed special purpose national bank, its parent company, or its activities? Certain risks may be increased in a special purpose national bank because of its concentration in a limited number of business activities. How can the OCC ensure that a special purpose national bank sufficiently mitigates these risks? What additional information, poloniex llc operating systems, and technical assistance from the OCC would a prospective fintech applicant find useful in the application process?
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Kennedy School of Government, Harvard University. Meeks, Gwen Moore, Donald M. Sewell Members poloniex llc operating systems Congress.
