December 8, 2016

Hudson Cook Issues Analysis of OCC's Fintech Charter Proposal

In response to the Office of the Comptroller of the Currency's ("OCC") proposal on how it will address the growing calls for a national financial technology ("Fintech") charter, Hudson Cook LLP has considered the implications of a Fintech Charter on preemption of state laws, among other items, in an analysis by Catherine M. Brennan, Meghan S. Musselman, and Robert A. Cook. The OCC proposal, eagerly awaited by online lenders and participants in marketplace lending platforms, outlines a way for such entities to enjoy the same preemption authority of national banks over various state licensing, usury, and disclosure requirements. Interested parties may submit comments on the OCC's proposal through January 15, 2017.

Prior Alert: OCC to Consider Applications from Financial Technology Companies to Become Special Purpose National Banks