The white paper further addressed the point for charter applicants engaged in lending:
[T]he OCC expects a special-purpose bank engaged in lending to explain its commitment to financial inclusion in its business plan.The plan must identify and define the relevant market or community, describe what and how the bank will offer its products and explain how its products and services will promote financial inclusion.
In the white paper, the OCC requested comment on several further issues before it begins granting fintech charters. Questions included what capital and liquidity requirements the OCC should impose, how a fintech firm can demonstrate its commitment to financial inclusion, how fintech firms that do not lend (such as a payments provider) can demonstrate a commitment to inclusion, whether a special-purpose fintech charter would have competitive advantages over a full-service bank charter and how the OCC can ensure fintech charter applicants mitigate the unique risks they face. Comments are due by Jan. 15, 2017.
Read the white paper.