Recent comment letters in response to the OCC’s fintech charter show increased criticism for the agency’s proposal; consumer protection groups, community banks and state regulators have all voiced opposition while supporters have been disappointed by the process for the charter; supporters are concerned that financial inclusion plans and other provisions for the charter might be overly burdensome; consumer protection provisions are also a point of emphasis with groups suggesting specific consumer protection measures such as interest rate caps, default rate limitations and underwriting standards; lack of details on a number of business factors including capital requirements and balance sheet versus off balance sheet funding have also reduced confidence in the charter. Source
