A suggestion for the new Acting Comptroller’s first day

First days at a new job are always busy: finding your office, doing paperwork, being introduced to people whose names you will promptly…

First days at a new job are always busy: finding your office, doing paperwork, being introduced to people whose names you will promptly forget. It’s rare to get any work done on the first day, but you should try.

Acting Comptroller of the Currency Keith Noreika should pause the OCC’s efforts to develop the fintech charter and assess whether the charter as it has developed to date really meets the needs of the industry and the public. Unfortunately, based on the most recent information the charter was shaping up to be needlessly burdensome and to improperly de facto impose laws that Congress did not intend to impose on non-depository institutions. Before the process moves further, and before any firm makes choices or bears costs to pursue a charter the new administration should be able to decide what the charter should look like.

What should not be paused is the OCC’s response to the CSBS’s law suit. That should be contested fully to ensure that any questions as to the OCC’s authority are completely resolved.

After that, his new colleagues will likely want to take him to lunch.