In an extensive comment letter to the OCC today, the American Bankers Association offered feedback on a recent advance notice of proposed rulemaking on several issues related to digital technology and innovation. ABA generally agreed with the OCC’s approach to regulating digital activities and offered several specific recommendations that the agency should follow as it moves forward in this area.
Importantly, ABA urged the OCC to use an open and transparent process when it considers issuing new charters—a point the association also raised in a separate comment letter last week on the OCC’s proposed payments charter. ABA also emphasized the importance of ensuring that new entrants into the banking system are held to the same rigorous regulatory standards as banks.
ABA also noted that the OCC could serve in a supportive role by providing a learning center that could help facilitate innovation by providing a centralized location where banks and third-party firms could obtain information about bank regulation and supervisory expectations related to third-party relationships.
“The benefits of financial innovation are only realized when they are delivered responsibly, in a way that does right by customers,” ABA said. “This means getting regulation right is critical. Regulation must be flexible enough to allow innovations to be driven from within traditional banks. We must also ensure that customers receive the protection they deserve wherever they get their financial services through consistent regulation and oversight.”