On September 13th the Conference of State Bank Supervisors (CSBS) filed a memorandum of law opposing the OCC’s motion to dismiss. The CSBS seeks to rebut (1) the OCC’s argument that the CSBS’ lawsuit should be dismissed because it is untimely; and (2) the OCC’s further contention that even if the challenge isn’t premature, the OCC has the authority to offer non-depository fintech charters anyway. As one might expect, the CSBS’ arguments closely follow those it made in its