January 17, 2017
Dear Comptroller Curry:
The Electronic Transactions Association (“ETA”) submits these comments in response to the Office of the Comptroller of the Currency’s (“OCC’s”) request for comment on its white paper, “Exploring Special Purpose National Bank Charters for Fintech Companies” (the “White Paper”). ETA and its members support the OCC’s recent announcement that it will consider applications for special purpose national bank charters from “FinTech” companies that offer bank products and services that meet OCC standards and chartering requirements. We hope that these comments will assist the OCC in tailoring its application and evaluation process for the FinTech industry.
ETA is the leading trade association for the payments industry, representing over 500 companies that offer electronic transaction processing products and services. ETA’s members include financial institutions, mobile payment service providers, mobile wallet providers and non-bank online lenders that make commercial loans, primarily to small businesses, either directly or in partnership with other lenders. ETA member companies are creating innovative offerings in financial services, revolutionizing the way commerce is conducted with safe, convenient and rewarding payment solutions and lending alternatives. As a result, ETA applauds the OCC’s innovation initiative and its efforts to develop a comprehensive framework to improve its ability to identify and understand trends and innovations in the financial services industry and the evolving needs of consumers of financial services