Well, no one said this was going to be an easy play for OCC, which is trying to implement a Fintech Charter. The money transmitter license process in the United States is quite a cumbersome process. For many startups, it is almost an impossible task to get the licenses in all 50 States (47 or 48 of them require it). All this takes serious money and not to mention, time – which most startups do not have.
OCC’s initiative to grant a fintech charter license is a direct threat to the independent state regulators who see this as something of a challenge to themselves being a licensing authority. I personally feel OCC, once they are determined to go ahead with it, will do so and will probably win, but the State Regulators may impose some skewed law, requiring the federally chartered license holder to still seek a local state license.
With this week’s close of the comment period on the December 2016 whitepaper by the Office of the Comptroller of the Currency (“OCC”) regarding special purpose charters for fintech