On December 16, 2015, the Office of the Comptroller of the Currency (OCC) issued its semiannual risk assessments for federally chartered financial institutions (PDF here). Relevant to FinTech, the OCC noted:

Banks are increasingly adopting innovative products, services, and processes in response to the evolving needs for financial services and growing competition from other banks and financial technology firms. Doing so often involves assuming unfamiliar risks, an expanded reliance on third-party relationships, and the need to update or acquire new systems and technology platforms. Banks involved in responsible innovation recognize the benefit to consumers and businesses (including their own operational efficiencies), as well as the need for sound risk management to properly oversee and control heightened risks.

The OCC's point of banks' need to innovate is consistent the familiar topic of the complicated relationship between federally charted banks and FinTech. It is common to see newspapers headlining the disruption FinTech is causing in banking market. A more subtle analysis may focus on the symbiosis between the two : banks need the innovation of FinTech and FinTech can benefit from the established relationship of banks.

This article is presented for informational purposes only and is not intended to constitute legal advice.