In March 2016, the Office of the Comptroller of the Currency (“OCC”) released a white paper6 on financial technology innovation. The white paper sets forth a framework for “responsible innovation.” Our firm’s client alert relating to the white paper may be found at the following link: http://www.mofo.com/~/media/Files/ClientAlert/2016/04/160406OCCFintechFramework.pdf.
The white paper is largely concerned with the rise of FinTech and its impact on how financial services are created and delivered to consumers. The white paper is also concerned with the development of financial products that are offered to consumers, and the development of an adequate framework to address them.
The OCC supports a framework that is based on responsible innovation, which is defined as “the use of new or improved financial products, services, and processes to meet the evolving needs of consumers, businesses, and communities in a manner that is consistent with sound risk management and is aligned with the bank’s overall business strategy.” The OCC will continue to review new products and technologies, analyzing how they may or may not support the stability of U.S. banks