The Office of the Comptroller of the Currency is refashioning itself to be innovation friendly. It started appropriately by admitting that it had a problem: “a low risk tolerance for innovative products and services.” It then set out to remedy the problem by, among other things, setting up an innovation office and proposing a special purpose national bank charter for fintech firms. That’s all well and good, but the proof of the pudding is in the eating. Based on the terms that the OCC laid out in its recent draft document on “evaluating charter applications from financial technology…

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