Key takeaways

• On March 15, 2017, the OCC released a draft supplement to its Licensing Manual and a summary of comments, both related to the proposed special purpose national bank charter rule from December 2016.
• The draft supplement describes the process for firms to follow when applying for a charter, including protocols for pre-filing discussions with the OCC.
• The summary of comments makes clear that the OCC does not intend any type of relaxed supervision or “regulatory sandbox” for charter recipients.