How FinTech is changing the Regulatory Environment: Compliance Keynote at Next

COMPLIANCE
KEYNOTE
SEPTEMBER 26, 2017
HOW FINTECH IS CHANGING
THE REGULATORY
ENVIRONMENT

AGENDA
Copyright © 2017 Accenture. All rights reserved. 1
1. STATE OF
FINTECH &
REGTECH
2. THE
PLAYERS
3. WAYS TO
COLLABORATE
4. WHAT YOU
CAN DO NOW

INTRODUCTION
BASIS OF OUR PERSPECTIVE…
The perspectives in this presentation are based on experiences and insights gained through direct
engagement in the Financial Services industry.
ACCENTURE
RESEARCH
ACCENTURE
VENTURES
ACCENTURE
STUDIOS
ACCENTURE
INNOVATION
CENTERS
ACCENTURE
FINTECH
ACCELERATORS
ACCENTURE
LABS
Identify and
anticipate
game-changing
business, market
and technology
trends through
provocative
thought leadership.
Trends
Incubate and prototype
new concepts through
applied R&D
projects that are
expected to have
a significant
near-term impact on
clients businesses.
Research &
Development
Partner with and invest
in growth-stage
companies that create
innovative
enterprise technologies,
using an open
innovation approach.
Investment &
Open Innovation
Build innovative
solutions with
speed and agility.
Solution
Innovation
Bring solutions
to scale and
demonstrate their
impact for clients.
Use Cases
& Assets
Mentorship program to
bring together FinTech
start-ups and leading
financial institutions
across New York,
London, Hong Kong
and Dublin. Over 110
companies have
graduated since 2011.
Platform to grow
innovative technology
PROJECT
WORK
Assisting clients
identify, select,
implement and
integrate technology to
solve business
challenges, improve
operational efficiency
and reduce cost.
Client
Engagement

THE GROWING IMPACT OF FINTECH
STRONG INVESTMENT TREND
Global financing for Venture Capital (VC)-backed FinTech companies has topped $10 billion annually
since 2015, a trend expected to continue this year according to CB Insights.
$589
$744
$577
$593
$1170
$898
$1072
$1648
$1822
$1392
$3177
$2587
$4326
$5187
$1989
$4992
$3754
$2580
$2158
$2842
$5193
Amount ($M)
VC-BACKED FINTECH
COMPANIES RAISE $5.2B
ACROSS 251 DEALS IN Q2’17
• Investment dollars to VC-backed
FinTech companies in 2017 are on
pace to rise 19% from 2016, at the
current run rate
• Global FinTech deal activity could
surpass 2016’s all-time high if the
rest of the year sustains H1’17’s deal
pace
115
104
133
121
136
165 167 171
183
195
218 210
243 240
217
268
247
213
216
245
251
Deals
Source: The Global Fintech Report Q2 2017, CB Insights, Research Report: https://www.cbinsights.com/research/report/fintech-trends-q2-2017/

THE GROWING IMPACT OF FINTECH
STRONG MOMENTUM BEHIND REGTECH
For RegTech alone, there has been nearly $5 billion in equity funding since 2013, across almost 600
deals.
1290
558 1088 1294 1128 894
2013 2014 2015 2016 2017
R
Full-Year Projection Disclosed Funding ($M)
83
126 126
147
103
148
Deals Projected
2017 ON PACE TO SET RECORD
OF 148 DEALS WORTH NEARLY
$1.29B
• Year to date, RegTech startups seen
103 deals worth $894M in funding
• At the current run rate, deals and
dollars in 2017 will reach a deal high
of 148 deals worth $1.3B, bringing
investment over the last 5 years to
more than $5B
Source: The State of RegTech, CB Insights, September 20, 2017

COUNTRIES HAVE
DEVELOPED
REGULATORY
SANDBOXES TO FOSTER
DEVELOPMENT OF
FINTECHS AND
REGTECHS (UK, CANADA,
AUSTRALIA, SINGAPORE,
MALAYSIA, RUSSIA,
SWITZERLAND, BAHRAIN,
HONG KONG, AND
THAILAND).1
REGULATORY ENVIRONMENT
WITH RESPECT TO FINTECH & REGTECH
Regulators are increasingly embracing FinTechs and RegTechs, with many of them actively supporting
their development through regulatory sandboxes, inter-country bridges, and special charters.
10
HAS ESTABLISHED A
SPECIAL PURPOSE
NATIONAL BANK
CHARTER FOR
FINTECH COMPANIES
TO FACILITATE
NATION-WIDE
ADOPTION.3
OCC
COUNTRIES HAVE
ESTABLISHED
FINTECH BRIDGES TO
COORDINATE
INTERNATIONAL
DEVELOPMENT AND
ADOPTION OF
FINTECHS
(AUSTRALIA,
SINGAPORE, SOUTH
KOREA, AND UK).2
4
Sources:
1. Regulatory Sandboxes: A Practice For Innovation That Is Trending Worldwide, ETH News: https://risk.thomsonreuters.com/content/dam/openweb/documents/pdf/risk/report/cost-of-compliance-2017df
2. Cost of Compliance 2017, Thomson Reuters: https://risk.thomsonreuters.com/content/dam/openweb/documents/pdf/risk/report/cost-of-compliance-2017.pdf1
3. OCC’s Noreika endorses fintech charter, slams state regulators, American Banker: https://www.americanbanker.com/news/occs-noreika-endorses-fintech-charter-slams-state-regulators

NEW CHARTER TYPES ARE DRAWING ATTENTION
OCC’S CHARTER PROPOSAL
Copyright © 2017 Accenture. All rights reserved.
The Office of the Comptroller of the Currency’s (OCC) proposal to issue National Bank charters to
FinTech companies has faced many challenges with no applications to date.
December 2, 2016
OCC proposes a special
purpose national bank
charter for FinTechs
April 26, 2017
State regulators sue the
OCC, arguing it lacks the
legal authority
June 19, 2017
OCC opens Innovation
Office
January 27, 2017
Over 100 public
comments on OCC
proposal
Today
Progress awaits
appointment of new OCC
director
OCC’s approach differs from other nations’ sandbox idea,
in which regulators select FinTechs to pursue defined
activities for a set time period, while waiving certain laws
REACTION TO THE OCC PROPOSAL
State regulators: “… unlawful expansion
of the chartering authority …”1
NYDFS:
“reckless folly”4
FinTech CEO: “…a safe and
positive impact on financial
service innovation …”3
State Bank Association: “… supportive
of efforts to bring fintech firms into the
mainstream regulatory system …”2
Bank Trade Association: fosters
“…innovation, competition and
improved products for customers.5
Acting Comptroller of the Currency
Keith Noreika:“Federal regulators aren’t
ready to take concrete steps to offer
fintech firms a special charter…”6
Sources: See Reference slide

THE PLAYING FIELD
SANDBOXES AND ACCELERATORS
FinTech firms: their global reach continues to expand with the multiplication of sandboxes and
accelerator programs.
Regulatory
Sandboxes
Accelerators
& Incubator
Programs
Australian Securities
and Investments
Commission (ASIC)
The Monetary
Authority of
Singapore (MAS)
Hong Kong
Monetary
Authority
(HKMA)
FinTech
Innovation Labs
NOT EXHAUSTIVE
1864 Accelerator
– Flat6Labs
3D FinTech
Challenge
Anthemis
Foundry
ATDC FinTech
Program
Axel Springer Plug
and Play Accelerator
Bank of England
FinTech
Accelerator
Barclays Accelerator Program
Capital One Growth
Labs in the UK
Citibank
Accelerator
Program
Coin
Apex
Commerce
Innovated
FinTech Innovation Lab
by Intel and The Floor
FUSION
iAccelerate
JPMorgan In-
Residence
Program
LAUNCHub
Main Incubator
Mambu FinTech Startup Program
Ryerson Futures
Plug and
Play
QC FinTech
Lab
Six Thirty
Startupbootcamp
The Watson
Centre by
IBM
ValueStream
Wayra
Y Combinator
Ynext
Scivantage
FinTech
Incubator
Program
FCA –
Innovate
Sources:
FinTech, RegTech and the role of compliance, Thomson Reuters, December 5, 2017: https://blogs.thomsonreuters.com/answerson/fintech-regtech-compliance/
Accenture Primary and Secondary Research
41 International Accelerators & Incubators Nurturing the Future of the Financial Services Industry, Let’s Talk Payment:
https://www.google.com/amp/s/letstalkpayments.com/41-international-fintech-accelerators-incubators-nurturing-the-future-of-the-financial-services-industry/amp/

DIFFERENT PATHS TO ADOPTING REGTECH
COLLABORATION AND PARTNERING MODELS
8
Joint activities, investment and acquisition have all been attempted.
8
1. JOINT
ACTIVITIES
JOINT RESEARCH AND
PRODUCT PLACEMENT/
DEVELOPMENT, WORKING
WITH OPEN/ APPLICATION
PROGRAM INTERFACE
(API) PLATFORMS.
+ Time to market
+ Flexibility
+ Building expertise
‒ No exclusivity
‒ Reputational risk
‒ Strategic misalignment
2. INVEST
SETTING UP A VENTURE
CAPITAL ARM TO INVEST IN
STARTUPS & FOCUS
MANAGERIAL ATTENTION
ON A CERTAIN AREA.
+ Organic capability growth
+ Lower investment stake
‒ No autonomy/control
‒ Overpricing
‒ Required knowledge &
capabilities
3. ACQUIRE
ACQUIRE FINTECH
STARTUPS OUTRIGHT,
INTEGRATING THEM OR
RUNNING THEM AS
STANDALONE ENTITIES.
+ Reduced speed-to-
market
+ Inorganic capability
growth
‒ Risk of culture bleeding
‒ Overpricing
‒ Acqui-hire
4. BUILD
BUILD NEW INNOVATIONS
IN-HOUSE TO CREATE
PRODUCTS.
+ Independence
+ Personalization &
Customization
‒ Slower speed-to-market
‒ Potentially not aligned
with best of breed
‒ Legal ramifications

HOW FIRMS ARE ENGAGING FINTECH / REGTECH
FIRMS ARE ADOPTING FINTECH / REGTECH
SOLUTIONS AT A FASTER PACE
This is replacing investments in traditional Compliance areas.
9
52%
33%
35%
~$5BN
OF FIRMS BELIEVE THAT
REGTECH SOLUTIONS ARE
IMPACTING HOW THEY MANAGE
COMPLIANCE, WHILE 17% HAVE
ALREADY IMPLEMENTED A
REGTECH SOLUTION.1
OF FIRMS HAVE INCREASED
FOCUS ON ASSESSING FINTECH
/ REGTECH SOLUTIONS AS
COMPARED TO LAST YEAR.2
OF FIRMS EXPECT THEIR
BUDGETS FOR REGTECH TO
INCREASE IN THE COMING
YEAR.3
ACROSS 585 DEALS IN
REGTECH EQUITY FUNDING
SINCE 2013.4
Sources:
1. Cost of Compliance 2017, Thomson Reuters: https://risk.thomsonreuters.com/content/dam/openweb/documents/pdf/risk/report/cost-of-compliance-2017.pdf
2. Ibid
3. Ibid
4. RegTech Europe: 60+ Startups Helping Financial Services Companies Navigate Regulations, CB Insights Research Briefs:
https://www.cbinsights.com/research/RegTech-europe-market-map/

COMPLIANCE MODERNIZATION REQUIREMENTS
THE MODERN DAY COMPLIANCE FUNCTION IS
MARKED BY SEVERAL KEY CHARACTERISTICS
10
These are driven or facilitated by emerging technology trends and capabilities.
People
• Elastic Workforce - Trained resources that support subject matter advisors (SMA) and business as usual
(BAU) staff as needed
• Cost efficiencies with center of excellence (COE) or business process outsourcing (BPO)
Technology
Architecture /
Platform
• New Open / API-based architectures that allow “plug-in” of new technical capabilities to add, upgrade or
swap components much easier, thereby facilitating faster integration of RegTech solutions
• Rapid adoption of state-of-the-art RegTech solutions as they reach maturity
• Robust, secure and scalable
Data /
Information
• Data quality is high quality and data sets are fit for purpose
• New Data sources can be quickly onboarded into evolving analytical library
End-to-End
Process
• Machine Learning and Intelligent Automation embedded in process where available (e.g., surveillance)
• Integrated Case Management to handle Regulatory and Compliance issues across the enterprise
Analytics, MI
and Reporting
• High Quality Management Information (MI) Dashboards and Business Intelligence (BI)
• Standalone and integrated analytics across Compliance functions

Analytics
Domain
Expertise
RegTech Mkt
Knowledge
NEW SKILLS ARE REQUIRED IN COMPLIANCE
TO EFFECTIVELY LEVERAGE FINTECH
The profile of talent and skills required in organizations will continue to evolve as technology becomes
increasingly integrated into daily activities, meaning that even traditional business-focused roles will
require understanding of things like data, analytics and applications of Compliance technology.
Focus and Proficiency
Communications
Business Acumen
Data Scientist
Analytics
Ethical Monitor
Performance Monitoring
Control
Oversight
Compliance
Organization
IT Architecture
Experts
Surveillance and
Monitoring
Risk and Controls
MI / Reporting Experts
Leadership
Data Science Experts Focus and Proficiency
Data Architecture
Business Acumen
Analytics
Domain Expertise
Technology Architecture
Systems Design
Data Science
RegTech Market Knowledge
…and Compliance Officers, in
particular, will need a deeper
understanding of tech to effectively
perform their jobs and enable
better collaboration.Source: Accenture 2017 Compliance Survey
Tech
Arch
Systems
Design
Data
Science
Business
Acumen
Data
Arch

• Quarule, Inc.
12
• Silverfinch (CSS
Company)
• AssetLogic SARL
• TheMarketsTrust
(Gust, Inc.)
• IdentityMind™
• Trunomi Ltd.
• Trulioo Inc.
• Detectica Inc.
• Digital Reasoning
Systems, Inc.
• Fund Recs™
• Fiserv, Inc.
COMPLIANCE/REGTECH COLLABORATION
BARRIERS AND REWARDS
There are some significant barriers to increasing collaboration between Compliance and RegTech, but
there are many potential rewards as well.
RegTech collaboration brings
increased scrutiny, and
Regulators are bringing big data
and analytics to their
Surveillance toolkit.
RegTech collaboration requires
significant investment.
Compliance budgets cannot fund
the innovation needed to
modernize capabilities.
Scrutiny is magnified
Compliance budgets are built
for BAU – not innovation
Leadership in Risk & Compliance
tends to take a conservative
approach, which limits
willingness to invest and
leverage newer and unproven
technology solutions.
Limited willingness to take
risks when investing in newer
capabilities
BARRIERS BENEFITS / REWARDS
Risk Data
Aggregation
Data utilities to allow efficient
distribution and storage of data in
secure and controlled environments
Forecasting &
Scenario Analysis
Risk-management solutions that
include portfolio simulation and
regulatory compliance reporting
Trade Surveillance
Software to help reconcile positions
(e.g., cash, Forex) and reconstruct
trades
KYC / Client
Identification
Solutions to manage client
onboarding processes and conduct
due diligence reviews
Transaction
Monitoring
Applications to scan transactions to
help determine potentially suspcious
or fraudulent activity
Employee
Monitoring
Automated solutions that monitor and
interpret voice and eCommunications
Semantic technologies that assist
with reg interpretation and managing
of jurisdictional requirements
Reg Interpretation
& Management

BANKS & FIRMS
• Efficiency
• Happy customers
• Cost reduction / Lower cost of
Compliance
• Reduced cost of compliance
• Faster deployment of services
• Better, more reliable technology
REGTECHS &
FINTECHS
• Access to market and other
resources needed
• Reinforcement of trust
• Reduced cost of customer
acquisition
REGULATORS
• Customer protection
• Reduced systemic risk
• Better competition in the
market
• Increased market competition
• Increased efficiency in the
market
INDUSTRY
• Increased level of “safety and
soundness”
• Protected customers
• Higher level of Compliance at
a lower cost
BENEFITS OF
COLLABORATION

SMOOTHER PATH TO COLLABORATION
NEW PERSPECTIVES ARE EMERGING, MAKING IT
EASIER TO COLLABORATE AND PARTNER
SUCCESSFULLY
BANKS &
FIRMS
ORIGINAL PERSPECTIVE ON
COLLABORATING
• Mistrust of regulators (viewed as
police)
• Mistrust of vendors and capabilities
• Conservative approach to adopting
new technology
• Reserved approach towards
collaboration
• Not open to sharing data and info
externally (“closed loop system”)
NEW PERSPECTIVE ON
COLLABORATING
• Open to collaboration and joint
activities
• Increased appetite for innovation
BARRIERS
• Lack of leadership support
• Silo’d organizational structures
• Inflexible architectures
• Legacy systems
• Lack of needed (technical) talent and skills
• Lack of resources
• Conflicting priorities
• Lack of vision and/or innovation strategy

SUCCESSFULLY
FINTECHS &
REGTECHS
COLLABORATING
• Unwilling to accept criticism and
feedback (hubris)
• Limited scope of offering (specific use
cases)
• Selective “partnering and
collaboration” only to improve their
offering
NEW PERSPECTIVE ON
COLLABORATING
• Open to partnering in mutually
beneficial way (willingness to adapt
product)
• Increased appetite for innovation
BARRIERS
• Lack of industry / regulatory knowledge
• Limited resources
• Cultural fit with prospective partners
• Immature offering
• Evolving value proposition (“solution
without a problem syndrome”)

SUCCESSFULLY
REGULATORS
COLLABORATING
• Limited awareness of specific
innovations and capabilities provided
by RegTechs
• Conservative mindset towards
adopting new technology
• Limited support of innovation
• Lack of clarity on their specific
mandate to foster innovation (i.e.,
who is responsible)
• Limited coordination across other
regulators
NEW PERSPECTIVE ON
COLLABORATING
• Increased level of support towards
innovation
• Increased promotion and facilitating industry
discussion on technology adoption
• Participation in industry forums & sandboxes
• Willingness to mentor (“office hours”)
• Increased focus on new entrants
• Increased fostering of innovation and
competition (e.g., OCC FinTech charters)
BARRIERS
• Taking a firm position invariably results in
debate and stakeholder reaction
• It is not clear what kind of new or evolving
regulation are required that focus on
FinTech
• Long standing mistrust of regulators (i.e.
viewed as “the police”)
• Despite increase use of technology,
shortage of technology expertise within
regulators themselves

CULTURAL FIT AND STEREOTYPES
THERE HAS TRADITIONALLY BEEN A GAP
BETWEEN PERCEPTION AND REALITY THAT HAS
INHIBITED COLLABORATION
BANKS &
FIRMS
FINTECHS &
REGTECHS
REGULATORS
How they view themselves… How others see them…
• Leading edge
• Flexible
• Technically advanced
• Noble & changing the world for the better
• Technically advanced
• Cool
• Protectors
• Noble & changing the world for the better
• Important
• Difficult to work with
• Too large and inflexible
• Not innovative
• Uneducated on the ways of the industry
• Arrogant
• Inexperienced
• Confusing from a technical point of view
• Enforcers
• Indecisive
• Unfair / Biased in their regulation
• Unapproachable

FI AND FINTECH COLLABORATION
FINTECH INNOVATION LAB SURVEY
Finding #1:
There’s a disconnect between FIs and FinTechs on the scope and purpose of Proof of Concepts
(POCs ), which commonly end up dragging for months with no clear success criteria or exit strategy.
Finding #2:
FIs and FinTech companies highlight different areas as problematic when moving from prospecting to
procurement.
Finding #3: FI processes are too complex and onerous for small FinTechs.
Finding #4:
FIs and FinTechs disagree on the rate of live implementations achieved with FinTechs believing the
success rate is higher than FIs (<25% convert to implementations according to FIs surveyed).
Finding #5
FIs are working more actively with regulators than FinTechs, with 60% of FIs surveyed claiming they
are actively working with regulators but only 17% of FinTechs are doing the same.
Several key findings were uncovered in our recent survey of 35 financial institutions (FIs) and 52
FinTechs from the FinTech Innovation Lab accelerator program:
Source: Accenture 2017 FinTech Survey (35 Financial Institutions, 52 FinTechs)

BARRIERS TO ACHIEVING SUCCESS
BARRIERS TO COLLABORATION mostly originate in the cultural clash between highly
regulated, control-driven FIs and nimble and innovation-driven FinTech companies.
FIs & FinTechs operate very differently and have sharply different views of their experiences working
together:
FINTECH OPPORTUNITIES get bogged down in lengthy and diffuse approval processes
within FIs - FinTechs advocate for POCs that are 1 month or shorter but commonly end up
in approval processes of 3+ months with no clear success criteria or exit strategy and
spending time that could be productive on administrative activities.
FIS AND FINTECH COMPANIES have different perceptions of collaboration barriers - FIs
see regulation, compliance and security as the biggest hurdles to advancement. FinTechs
cite issues related to lack of cooperation from FIs.

FI ACTIONS TO IMPROVE SUCCESS RATE
BE TRANSPARENT with the FinTech companies you’re collaborating with and agree on the
scope, timeframe and exit strategy for the POC.
There are ways that FI can make themselves more FinTech-friendly:
SPEED UP AND SIMPLIFY your processes – consider how a small company will find
dealing with you - consider streamlining the POC approval process and creating a “fast
track” procurement process for FinTechs.
COLLABORATION WITH FINTECHS has a higher probability of yielding benefits if
targeted to solve a specific business issue or problem.
CREATE SANDBOXES that FinTech companies and FIs can use effectively for the POC.

FINTECH ACTIONS TO IMPROVE SUCCESS RATE
LEARN TO SPEAK the same language as FIs and recognize and understand the stumbling
blocks that are holding back progress.
Similarly, there are steps FinTechs can take to make themselves FI-friendly:
REGULATION, COMPLIANCE AND SECURITY concerns are the top reasons for not
proceeding with a POC, according to 60 percent of the FIs surveyed - FinTechs would
greatly benefit from a better understanding of these concerns and should work alongside FIs
to find solutions.
UNDERSTAND THE SPECIFIC business or industry need first, then build or tailor the
solution around it – many new FinTechs have solutions in search of a problem or are
exploring the re-purposing of a solution intended for a different problem.

WHAT YOU CAN DO NOW
STEPS TO FOSTER COLLABORATION AND
INNOVATION IN COMPLIANCE
22
BANKS &
FIRMS
FINTECHS &
REGTECHS
REGULATORS
• Create and migrate towards Open
Banking (API-based) architectures that
lend themselves to plugging in new
technology capabilities
• Hold internal discussions to obtain buy-
in and ease constraints to achieving
collaboration and adoption of technology
• Define a FinTech & RegTech strategy
and the desired outcomes to help drive
actions and decisions on prospective
partners and solutions
• Continue to study & learn about
regulatory obligations
• Meet with regulators early and often to
obtain their guidance and point of view
• Refine value-proposition and capabilities
to focus on relevant compliance use
cases (define the problem you are solving
before building the solution)
• Embrace technology as a way to lower
the overall cost of compliance in the
industry
• Define new standards / protocols to
facilitate collaboration (e.g., data sharing,
APIs, etc.) with an eye on eliminating
unnecessary barriers and fostering
innovation
• Actively promote and participate in
regulatory sandboxes to gain early
understanding of evolving technology and
potential risks that may need to be
addressed

REFERENCE
Sources – timeline:
• OCC to Consider Fintech Charter Applications, Seeks Comment, OCC, December 2, 2016: https://www.occ.gov/news-issuances/news-
releases/2016/nr-occ-2016-152.html
• Public Comments on Exploring Special Purpose National Bank Charters for Fintech Companies, OCC, January 27, 2017:
https://www.occ.gov/topics/responsible-innovation/fintech-charter-comments.html
• State regulators sue OCC over fintech charter, American Banker, April 26, 2017: https://www.americanbanker.com/news/
• OCC to Hold Innovation Office Hours in New York, OCC, June 19, 2017: https://www.occ.treas.gov/news-issuances/news-releases/2017/nr-occ-2017-
68.html
• OCC Fintech Plan Faces Uncertainty as Comptroller Term Expires, Credit Union Times, April 18, 2017: http://www.cutimes.com/2017/04/18/occ-
fintech-plan-faces-uncertainty-as-comptroller?slreturn=1506375193
Sources – quotations:
1. CSBS Files Complaint Against Comptroller of the Currency, Conference of State Bank Supervisors, April 25, 2017: https://www.csbs.org/news/press
releases/pr2017/Pages/042617.aspx
2. Comments on Exploring Special Purpose National Bank Charters for fintech Companies, Massachusetts Bankers Association letter, January 15,
2017: https://www.occ.gov/topics/responsible-innovation/comments/comment-mass-bankers.pdf
3. Response to Request for Comments to Consider Fintech Charters, OCC, January 27, 2017:https://www.occ.gov/topics/responsible-
innovation/comments/comment-wing-cash-parity-pay.pdf
4. NY regulator sues U.S. OCC over national charters for online lenders, Reuters, May 12, 2017: http://www.reuters.com/article/us-new-york-occ-
fintech/ny-regulator-sues-u-s-occ-over-national-charters-for-online-lenders-idUSKBN1882QO
5. Exploring Special Purpose National Bank Charters for Fintech Companies, BAFT, January 17, 2017: https://www.occ.gov/topics/responsible-
innovation/comments/comment-baft.pdf
6. OCC Not Yet Ready to Offer Special Charters to Fintechs, Bloomberg BNA, September 13, 2017: https://www.bna.com/occ-not-yet-n57982087846/

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only and does not take into
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