Supporting Responsible Innovation in the Federal Banking System

Response to OCC Paper re Innovation.pdfIn this comment letter, the Ford Foundation-funded coalition comprising of Woodstock Institute, the Main Street Alliance, California Reinvestment Coalition, and National People’s Action write to the Office of the Comptroller of the Currency on that office’s recent paper entitled “Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective.” In general, we welcome the OCC’s development of a comprehensive framework to address innovation, and we believe, given the already fast pace of innovation, that it should be implemented swiftly. At the same time, we express concerns about the potential harm to small businesses, consumers, and communities if innovation is not checked by an adequate and appropriate regulatory framework.