December 2, 2016

STATEMENT BY DFS SUPERINTENDENT MARIA T. VULLO REGARDING THE OCC SPECIAL PURPOSE NATIONAL BANK CHARTERS FOR FINTECH COMPANIES

Particularly now, with so much uncertainty at the federal level, New York will not allow consumer protections to fall into the void. The New York State Department of Financial Services (DFS) opposes any effort to federalize what states have been doing - and doing well - for over a century. Any reliance on a federal fintech regulatory framework, such as the proposal contemplated by the OCC, would be irresponsible if it were to ignore the states’ historical role and longstanding expertise in this arena. State regulators, like DFS, are best positioned to continue to protect consumers and ensure that dynamic service providers like fintech firms will continue to flourish within an appropriately tailored regulatory regime. History has demonstrated that states, not the federal government, have the requisite knowledge and experience to effectively regulate nondepository financial service providers and guard against predatory and abusive practices.

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