OCC Announces Preliminary Framework on FinTech and Responsible Innovation

On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) released a white paper on financial technology innovation (“White Paper”), which lays out a preliminary framework for “responsible innovation.” The White Paper articulates principles the OCC will follow when evaluating innovative products, services, and processes that require regulatory approval and identifying potential risks associated with them. The White Paper also represents the OCC’s commitment to improving its own understanding of new technology and to improving collaboration with the Consumer Financial Protection Bureau (“CFPB”) and other banking regulators to develop a consistent supervisory approach in this space.

As part of the White Paper, the OCC broadly requested feedback on the challenges banks face with respect to FinTech and how the OCC can facilitate innovation, including by issuing guidance to banks and nonbanks and by establishing formal channels for communication with stakeholders. Comments are due by May 31, 2016. The OCC also plans to host a forum on responsible innovation on June 23, 2016, in Washington, D.C., to discuss the comments it receives on the White Paper.

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