OCC Lays Out Responsible Innovation Framework

On October 26, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its Recommendations and Decisions for Implementing a Responsible Innovation Framework (“Framework”). The Framework is a follow up to the OCC’s March 2016 white paper on Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective (“White Paper”). The Framework reflects the comments received in response to the White Paper, as well as other OCC internal and external outreach. While the Framework does not address the concept of a federal FinTech charter discussed by the OCC on several occasions this year, the OCC is expected to address the concept later this fall.

The Framework discusses the recommendations made by the OCC’s Innovation Framework Development Team that were approved by the Comptroller of the Currency and the OCC Executive Committee. This alert highlights several of the key approved recommendations, as well as certain concepts that were in the White Paper that did not result in approved recommendations.

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