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Venable partner John Beaty was quoted in a December 8, 2016, American Banker article on plans by the Office of the Comptroller of the Currency (OCC) to apply financial inclusion requirements in the Community Reinvestment Act (CRA) to its pending fintech charter. While the OCC acknowledged the CRA would not apply to all fintech companies, it still asked charter applicants to submit a financial inclusion plan. The OCC also suggested it might use the charter to experiment with new ways to comply with the CRA.

"Applicants are going to say it's more important to me to get approval quickly than it is to find the least burdensome approach to solve this issue," predicted Beaty. The CRA has "been worked on a lot by the agencies and there are fairly well-articulated expectations embedded by the guidance that's been given out by the agencies," he added. "The pragmatic approach for some fintech companies will be to simply try to get as close to CRA as they can."