OCC’s New Comptroller Announces Innovative Fintech Initiatives | Global Fintech & Payments Blog

  • Electronic activities that are part of or incidental to the business of banking
  • Furnishing products and services by electronic means and facilities
  • Engaging in an electronic activity that includes several component activities
  • The sale of excess electronic capacity and by-products
  • Acting as digital certification authority
  • Data processing and correspondent services
  • The location of a national bank conducting electronic services
  • The location under 12. U.S.C. § 85 (related to rate of interest on loans) of national banks operating exclusively through the internet
  • Shared electronic space
  • Outstanding issues. Are there digital banking activities or issues related to digital banking activities that the OCC does not currently address and should?
  • Crypto-related activities. What types of activities related to cryptocurrencies or cryptoassets are financial services companies or bank customers engaged in? To what extent does customer engagement in crypto-related activities impact banks and the banking industry?
  • Distributed ledger technology. How is distributed ledger technology used, or potentially used, in banking activities, and are there any specific matters on this topic that should be clarified in regulatory guidance?
  • What new payments technology and processes should the OCC be aware of, and what are the potential implications of these technologies and processes for the banking industry?
  • “Regtech.” What new or innovative tools do financial services companies use to comply with applicable regulations and supervisory expectations?
  • COVID-19. Are there issues the OCC should consider in light of changes in the banking system that have occurred in response to the COVID-19 pandemic (e.g., social distancing)?

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Latham & Watkins

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