Letter to the OCC on the National Bank Chartering Notice of Proposed Rulemaking

To Whom It May Concern,

The American Bankers Association (ABA)  appreciates the Office of the Comptroller of the Currency ("OCC") providing this opportunity for public comment on important developments regarding OCC chartering. OCC’s National Bank Chartering Notice of Proposed Rulemaking  (proposed rule) is a meaningful part of a larger conversation involving a host of recent OCC charter applications, OCC’s conditional approval of some of those applications, and the yet-incomplete regulatory frameworks to which many recent and likely many future OCC charter applicants will be subject.

We urge OCC to ensure that robust, broadly applicable safety and soundness standards are well understood and upheld during this period of rapid innovation, to provide greater transparency throughout its charter application and decisioning processes, and to show patience as emerging regulatory frameworks to which many recent OCC charter applicants will ultimately be subject take shape. We also suggest a change to OCC's regulations which would better ensure new OCC charter applicants’ names do not misrepresent the nature of the financial services they intend to offer.

Download the comment letter to read the full text.