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TCH Comments on OCC’s ‘Responsible Innovation’ White Paper

The Clearing House (TCH) has filed a comment letter in response to the OCC’s white paper on ‘responsible innovation’ and the role of national banks in FinTech, which was issued on March 31, 2016.  The OCC’s paper identifies the principles that the OCC plans to use as it continues to develop its comprehensive framework for understanding and evaluating innovative products, services and processes.  The comment letter commended the OCC for its willingness to evaluate and develop its own infrastructure and policies in order to foster well-informed engagement with banks and nonbanks on FinTech issues, but cautioned the OCC that FinTech innovation is rapidly evolving and that flexibility and timeliness of execution are critical components of the needed regulatory framework.