The Office of the Comptroller of the Currency’s (OCC) announcement earlier this month that it will begin accepting applications for special purpose national bank (SPNB) charters from nondepository financial technology (Fintech) companies represents a major development that provides Fintech companies with the opportunity to take advantage of federal preemption and other benefits available to full-service national banks. Most significantly, the OCC’s decision means that obtaining an SPNB charter is now an option for Fintech companies that would be disqualified from obtaining a full-service national bank charter due to their own non-financial activities or those of an affiliate.

Please join us to explore the issues that Fintech companies contemplating an SPNB charter will need to consider in deciding whether to submit an application to the OCC. The issues we will discuss include the following:

• The benefits of an SPNB charter

• The restrictions/requirements/standards that will apply to an SPNB

• The OCC's application and approval process

• Potential challenges to the OCC's decision to accept SPNB charter applications

• Alternatives to an SPNB charter, including a full-service, deposit-taking bank or an industrial loan company

• Application of Bank Holding Company Act