OCC Innovation Pilot Program Proposal
Summary
SIFMA provided comments to the Office of the Comptroller of the Currency’s (OCC) on their proposal to create an
Innovation Pilot Program (the Pilot Program).
Excerpt
June 14, 2019
By Electronic Submission ([email protected])
Office of Innovation
Office of the Comptroller of the Currency
400 7th Street, S.W.
Washington, D.C. 20219
Re: OCC Innovation Pilot Program Proposal
The Securities Industry and Financial Markets Association (SIFMA)1 appreciates the opportunity to comment on the Office of the Comptroller of the Currency’s (the OCC) proposal to create an Innovation Pilot Program (the Pilot Program).2 SIFMA has urged policymakers to develop mechanisms for innovation, such as the proposed Pilot Program, as valuable regulatory frameworks for fostering the use of emerging technologies to develop new business models,
products and services.3
We applaud the OCC for issuing this proposal. Whether established entities or new entrants to the market, U.S. financial firms face regulatory risk and constraints in bringing innovative financial services and technologies to market, which in turn hampers their ability to provide innovation’s benefits to consumers and investors. Moreover, because the current U.S. regulatory framework for addressing innovation is largely entity-based rather than activities-based, consumers and investors face innovation’s risks unevenly, based in large measure on whether innovative activities take place inside or outside of the regulatory perimeter rather than on the nature of the activities themselves.
1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the
U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation,
regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and
related products and services. We serve as an industry coordinating body to promote fair and orderly markets,
informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry
policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional
member of the Global Financial Markets Association (GFMA).
2 https://www.occ.treas.gov/topics/responsible-innovation/occ-innovation-pilot-program.pdf
3 https://www.sifma.org/wp-content/uploads/2018/04/SIFMA-EO-Fintech-White-Paper.pdf