A variety of banking and finance technologies have been introduced or popularized by upstarts since the 2008 financial crisis: digital currencies, new data points in determining creditworthiness, and automated anti-fraud processes. The Office of the Comptroller of the Currency, a bank regulator that operates as an independent agency within the Treasury Department, has been at the vanguard of grappling with how decades-old banking laws might apply to the changing world of banking.

In 2016, the comptroller’s office began developing a special purpose bank charter to effectively let nonbank financial technology firms that offer online lending, payments, or other financial services become banks for legal purposes without looking like a traditional bank or taking deposits.