Financial technology companies – and marketplace lending companies in particular – face the limitations of an overlapping state and federal regulatory framework. While the Conference of State Banking Supervisors and a consortium of various states have begun a dialogue to assess and propose solutions to ease that burden, a more uniform nationwide regulatory structure is crucial in ensuring that consumers and business owners can gain access to the convenient, affordable credit options they clearly need. To that end, successful and responsible fintech firms and marketplace lending platforms of today may be able to serve customers better if they are able to apply to become the de novo banks of tomorrow, and the MLA has long supported reinvigorating the FDIC-supervised Industrial Loan Company charter and the OCC’s efforts to provide the Special Purpose National Bank (SPNB) charter to fintech firms. Treasury and federal banking regulators could also examine ways that requirements under the Bank Holding Company Act, and the Dodd Frank Act’s Volcker Rule, both related to ownership stakes limit de novo applications without meaningful improvements to safety and soundness. Additionally, the interpretation of the Change of Bank Control Act should be modified to provide more opportunity for de novo charters in situations where the shareholder of the parent company of the entity sponsoring a bank has less than 50% ownerships stake and will not have any active role in the bank subsidiary management.