TCH, together with the ABA, BPI, CBA, CUNA, ICBA, NAFCU, CRL, NCRC and NCLC, submitted a letter to Brian Brooks, Acting Comptroller of the Currency, sharing their concern with the brevity of the public comment period for recent novel national bank and national trust charter applications. The letter recommends a public comment period of 90 days for all novel charter applications, including recent filings, and notes that this request is consistent with a July request that urged the OCC to undertake an open and transparent approach in considering new charters. The authors of the letter reason that financial services innovation can benefit the economy and create opportunities for small businesses and consumers, but can also pose new issues and risks. Consequently, adequate time should be given for a thorough review of novel charter applications and their implications for consumers and the financial services industry.
To read the full comment letter click here.