The U.S. Department of the Treasury (the "Treasury") has released a fourth report in a series of reports produced in response to Executive Order 13772, which sets out the Administration's seven core principles for regulating the U.S. financial system (the "Core Principles"). This report, entitled "A Financial System That Creates Economic Opportunities: Nonbank Financials, Fintech, and Innovation" (the "Fourth Report") analyzes and provides recommendations for the regulation of nonbank financial companies, the fintech sector and other forms of financial market innovation through the lens of the Core Principles. Thematically, the Fourth Report primarily addresses the following two Core Principles: (1) making regulation efficient, effective, and appropriately tailored and (2) enabling American companies to be competitive with foreign firms in domestic and foreign markets.
This briefing specifically discusses the Treasury's recommendations regarding online lending in the Fourth Report. The Clifford Chance fintech team will distribute a series of briefings over the next two weeks that will provide summaries and analysis of various topics within the Fourth Report. We will also distribute a separate summary of the proposed OCC Fintech Charter.