The undersigned consumer, civil rights and privacy groups submit these comments on the Office of the Comptroller of the Currency’s (OCC) proposed Innovation Pilot Program.
We support the OCC’s focus on fostering compliance with the law, promoting fair treatment for consumers, ensuring the safe and responsible use of technology, and enhancing the OCC’s understanding of the use and risks of financial technology. We especially appreciate the fact that the OCC seeks to achieve these goals without waiving consumer protection regulations or risking the appearance that the agency is approving or promoting the products of particular companies.
To further protect consumers and the public, we urge the OCC to: