Fintech companies will also be required – like banks – to develop a formal plan for failure and to have a hands-on board of directors. Curry called for the development of "a formal agency policy" that will determine whether the OCC grants a fintech's application for a charter or not. The OCC asked for public comments – due Jan. 15 – to determine exactly how the charter should be granted.

http://www.americanbanker.com/news/law-regulation/occ-grants-new-charter-to-fintech-firms-with-strings-attached-1092669-1.html