On July 7, 2017, the Office of the Comptroller of the Currency released its Semiannual Risk Perspective report identifying the risks faced by national banks and federal savings associations in the 12-month period ending December 31, 2016. The Report, which is intended to highlight key risk issues facing the federal banking system, noted that strategic, credit, operational and compliance risks of banks remained a “top concern” for the agency during this period. The Report comes at a time of heightened interest in, and increased regulatory scrutiny of, Fintech companies offering traditional bank products such as loans. The OCC signaled earlier this year that the agency would begin considering possible special purpose national bank charters to Fintech companies. The strong tone of the Report is noteworthy because of the highly publicized criticisms of the OCC’s efforts in this regard.

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