OCC Announces It Will Accept Fintech Special Purpose Bank Charter Applications

On July 31, 2018, the OCC announced a new policy to begin accepting special purpose national bank charter applications from qualifying nondepository fintech companies. The decision followed two years of stakeholder outreach and public comment periods, culminating in a formal policy statement and a supplement to the Comptroller's Licensing Manual. Eligible applicants must be engaged in at least one core banking function — paying checks, lending money, or taking deposits — though FDIC deposit insurance is not required.

The OCC stated it would evaluate each application individually, assessing business models, risk profiles, capital adequacy, liquidity, contingency planning, and commitments to financial inclusion. Heightened supervisory expectations were outlined for de novo fintech banks operating under such charters. No charters were actually approved or granted in July 2018; the announcement solely opened the application process.

The policy represented a significant shift in the U.S. regulatory landscape, offering fintechs a potential federal alternative to state-by-state licensing. Industry groups including Financial Innovation Now, representing Amazon, Apple, and Google, publicly welcomed the OCC's decision.