The 49 consumer, civil rights, small business, and other community organizations signed on to this letter to express strong opposition to new federal nonbank lending charters that would enable chartered entities to avoid state interest rate caps, other state consumer protection laws, and state oversight, putting consumers and small businesses at risk. The Office of the Comptroller of the Currency (OCC) has expressed interest in granting a new type of special purpose "national bank" charter for financial technology ("fintech") firms, including firms that engage in lending and other activities but do not take deposits. The OCC's legal authority to charter nondepository lenders unilaterally and without Congressional assent is doubtful, 3 but the OCC should not charter such entities even if it has power to do so.
