Stealth Sandbox

On June 8, we made the case that the OCC is "establishing a mini-sandbox in the United States." Previous posts have also made the case that cross-border regulatory cooperation is increasingly the norm among FinTech regulators through Memoranda of Understanding (MOU)

The following day, news broke that the Monetary Authority of Singapore had signed another MOU establishing regulatory cooperation with more banking supervisors on a trans-Pacific basis. The counterparty in question this time is the Association of Banking Supervisors of the Americas (ASAB).

The ASBA membership includes three federal banking regulators in the United States: the Federal Reserve, the Federal Deposit Insurance Corporation and....the OCC.

The MOU text has not (yet?) been released. MOU terms can vary significantly, even within the FinTech context. Some can serve as simple promises to exchange supervisory information. Others (like the UK-Hong Kong MOU) can include mechanisms to facilitate entry into counterparty FinTech sandboxes.

Even if the most recent MOU is a bare-bones agreement, it illustrates another below-the-radar, technical move by the OCC to advance incrementally a Fintech-friendly policy in the United States.

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