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The Office of the Comptroller of the Currency (“OCC”) recently announced that it would consider applications by Fintech companies to organize a national bank to conduct their activities. This should be a wake-up call for many institutions, but particularly credit unions and other community institutions. The action by the OCC was inevitable in light of the developments in the financial services industry and makes good economic sense since electronic banking is cost effective and can reach consumers any time day or night. The OCC clearly has emerged as a leader and an enthusiast of wedding technology to the bank charter. The OCC noted that such banks, as should be the case, will be subject to the same safety and soundness standards, albeit with any modification due to the nature of their business.

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