34 As envisioned by the OCC, obtaining a special purpose charter would have the practical effect of allowing certain fintech companies (companies that make loans, make payments, or accept deposits) to potentially bypass the need for connecting to a bank for certain purposes in favor of becoming licensed as banks themselves.
The OCC’s proposal raises interpretive and policy issues for the Federal Reserve regarding whether charter recipients would become Federal Reserve members or have access to Federal Reserve accounts and services, such as direct access to payment systems.