According to Stephen Lybarger, deputy comptroller of licensing at the OCC, the new OCC fintech charter might be better suited for mortgage companies and online lenders; the OCC does expect their first application to be filed sometime in Q1, though there has been a lot of push back from state regulators; there has been some confusion as to who the charter might be best for, it really depends on the future plans of the fintech; if an online lender were to go the charter route and in a few years changed their strategy to become more like a bank they would need to refile a different application; payments firms might be the perfect fit since they don’t need to hold deposits or capital to lend. Source.
