The Office of the Comptroller of the Currency (OCC) announced its decision to accept applications for special purpose national bank charters from nonbank companies (fintech charters) that do not and would not engage in receiving deposits or be insured by the Federal Deposit Insurance Corp. Since then, the OCC was instructed by a federal judge that such a charter was beyond its mandate as fintech companies do not engage in the business of banking by receiving deposits. Since then, the OCC has ignored this ruling in pursuit of what it now calls a "Payments Charter." CSBS and state regulators are opposed to all OCC non-bank charters. The OCC's non-bank charter plans creates winners and losers, stifles innovation, and endangers important state consumer protections for non-bank firms.