Read the ANPR here

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Article Highlights:

On June 4, 2020, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) and invited comments on the OCC’s digital banking rules and other issues related to digital banking and financial services technology and innovation. Among other things, the OCC requests comments on:

  • Whether existing legal standards governing digital activities are adequately clear and flexible in light of technological changes in the banking industry, unduly impede innovation, or create gaps in coverage of digital banking activities;
  • Cryptocurrencies or other cryptoassets;
  • Blockchain or distributed ledger technologies;
  • Artificial intelligence and machine learning;
  • Emerging payments technologies and their implications for banking;
  • Effective regtech tools;
  • Special purpose national banks;
  • Whether small financial institutions face unique issues related to innovation;
  • Whether COVID-19 has identified or created issues that the OCC should consider; and
  • Any other changes in the development and delivery of banking products and services that the OCC should consider.

Some observers believe this OCC ANPR is the first step towards even more digital and open banking in the United States. Importantly, the ANPR reminds banks that they “should adjust their business models and practices to a new financial marketplace and changing customer demands” in order to remain competitive. As the OCC reviews its regulations and examinations of digital banking activities through information gathered via the ANPR, financial institutions should be encouraged to consider their adoption of banking technology.