OCC should consider new charter through open, transparent process

July 29, 2020

CUNA and other organizations oppose an Office of the Comptroller of the Currency (OCC) proposed narrow-purpose payments charter, the organizations wrote to the agency Wednesday. The OCC recently discussed the possibility of a narrow-purpose payments charter, and CUNA and its co-signers believe this could introduce “serious risks” into the financial services system.

“We have not yet seen a clear indication of how these principles would be applied to a narrow-purpose charter, such as a payments charter. We would urge the OCC to clarify its expectations before proposing any narrow purpose charters,” the letter reads. “Specifically, we encourage the OCC to continue to proceed carefully, deliberately, and transparently as it has throughout its deliberations on new charters. The issues being considered have broad implications for the banking system and longstanding policy determinations. Any change being contemplated should be subject to robust public comment well before considering a new charter.”

CUNA also called for the OCC to ensure the Bank Holding Company Act oversight is applied to any special purpose national bank, as the oversight reflects Congress’s policy determinations regarding oversight and supervision of holding companies that engage in activities beyond the bank subsidiary.

“Any change to this balance would represent a significant policy change. We believe that such a significant policy change should be subject to scrutiny in the public notice and comment process, and not simply by issuing a special purpose national charter,” the letter reads.