Back in early December the OCC announced their intention to create a national Fintech Charter. At the time they announced a request for public comments until January 15. Lend Academy and LendIt sent in a combined response before the deadline and it is reproduced below. You can also read it in PDF format here.
Dear Comptroller Curry:
On behalf of LendIt Conference LLC and Lend Academy LLC, I am writing in response to your request for comment on the proposed special purpose Fintech Charter.
First some background. My name is Peter Renton and I have been active in the Fintech industry since 2009. I began as an individual investor on Lending Club and Prosper, the two leading peer to peer lending platforms. I started Lend Academy, a media site dedicated to the broader online lending industry, because I believed in the potential of the industry to bring change to financial services.
I started LendIt with my co-founders back in 2013 because there was no event yet dedicated to the online lending industry. Together, we felt that the industry needed a place to come together to network and discuss the latest innovations. LendIt was the first and is the largest event in the online lending space today.
A More Efficient Financial System
As someone without a background in finance what struck me when I began learning about this industry was how inefficient it was. With 50 states, many of which have their own licensing, fee and interest rate requirements, there was no way for an online platform to operate in a uniform manner. Despite that many platforms have been able to get some traction albeit in a less than ideal way.
I would like to draw your attention to a study done in 2014 by Thomas Philippon of the Stern School of Business at NYU. When I read this paper I was staggered by the fact that the unit cost of financial intermediation has not improved much at all over the last 100 years. With all the advances in technology I would have thought that financial intermediation would have become many times more efficient during this time.