TCH, together with the ABA, BPI, CBA, CUNA, ICBA and NAFCU, sent a letter to Brian Brooks, the Acting Comptroller of the Currency, voicing concerns with the OCC’s proposed narrow-purpose payments charter. The letter urges the OCC to undertake an open and transparent process in considering new charters, such as a payments charter, noting that any change being contemplated should be subject to robust public comment prior to being given effect. Additionally, the letter notes the need for consolidated supervision that may be missing under the narrow purpose charter.
To read the full comment letter click here.
OCC's RESPONSE (August 20, 2020): TCH and the co-signers of the comment letter about the OCC’s proposal to issue payments charters received a response from Acting Comptroller Brian Brooks. In his response, Brooks thanks the commenters for their “assessment of legal and policy issues” and provides his assurances that “as the OCC proceeds” it will do so in a “transparent, deliberate, measured” manner that is consistent with applicable law and regulation. Brooks observes that in the past decade payment activity has shifted from being almost entirely conducted by banks to consumers and businesses increasingly turning to specialized firms that “operate outside of supervised and chartered banks for payment services.” Brooks then makes the case for chartering these firms, which, in his view, ensures the same level of oversight as any bank receives and a level playing field.
To read Brian Brooks' (Acting Comptroller of the Currency) response letter click here.