It appears that the OCC will require fintech applicants to apply as nondepository institutions, meaning that these fintect firms will not require FDIC insurance as they will not take deposits.  However, the OCC  could make some requirements part of the chartering process, including, but not limited to requiring  compliance with the Community Reinvestment Act.   This process will benefit our fintech clients who have been subject to regulatory compliance and licensing issues in the states where they operate.  This national charter will grant the same preemption  that currently held by  national banks.   We look forward in assisting our clients in obtaining these charters and continuing to work with the strategic alliance  model.

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