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Public Comments on the OCC’s Innovation Pilot Program

On April 30, 2019, the OCC published and solicited comments on a paper titled Innovation Pilot Program. The program, as proposed, would provide eligible entities with regulatory input early in the testing of new or innovative activities that could present significant opportunities or benefits to consumers, businesses, financial institutions and communities. Comments may be submitted by e-mailing through June 14, 2019.

In general, the OCC will publish all comments on its Web site. Comments and supporting materials will be published without change, including any business or personal information provided such as name, address, e-mail address, or phone number. Comments received, including attachments and other supporting materials, are subject to public disclosure. Do not include any information in your comment or supporting materials that you consider confidential or inappropriate for public disclosure.

Comments on the paper are accessible below. Questions on the program may be directed to the Office of Innovation, at, or at (202) 649-5200.

Commenter Affiliation Location Comment Date Read Comment
James Gutierrez, Chief Executive Officer Aura Financial Corporation (Aura) San Francisco, CA 06/24/2019 Comment
Alton Afford     06/18/2019 Comment
Alton Afford     06/16/2019 Comment
Greg Baer
President & CEO
The Bank Policy Institute Washington, DC 06/14/2019 Comment
Sam Dzirasa,
Board Member at-large
MIT Sloan Club of DC   06/14/2019 Comment
Kenneth W. Edward, Associate General Counsel,Regulatory Affairs Upstart San Carlos, CA 06/14/2019 Comment
Randolph Kantorowicz, CEO Mobile Money (MoMo) New York, NY 06/14/2019 Comment
Tom Quaadman,Executive Vice President U.S. Chamber of Commerce’s Center for Capital Markets Competitiveness Washington, DC 06/14/2019 Comment
Adam Lesman, General Counsel ODX New York, NY 06/14/2019 Comment
Brent Adams, Senior VP of Policy & Communication Woodstock Institute Chicago, IL 06/14/2019 Comment
Charles DeSimone, Vice President Securities Industry and Financial Markets Association (SIFMA) New York, NY 06/14/2019 Comment

Lauren Saunders, Associate Director

National Consumer Law Center (on behalf of its low income clients), and

Allied Progress

Americans for Financial Reform Education Fund

Atlanta Legal Aid Society, Inc.

California Reinvestment Coalition

Center for Digital Democracy

Center for Economic Integrity

Center for Responsible Lending

Consumer Action

Consumer Federation of America

Consumer Reports

National Association of Consumer Advocates

National Fair Housing Alliance

Public Citizen

Public Justice Center

Reinvestment Partners

Washington, DC 06/14/2019 Comment
Rob Morgan, VP Emerging Technologies American Bankers Association Washington, DC 06/14/2019 Comment
Andre Cotton, Regulatory Counsel Consumer Bankers Association Washington, DC 06/14/2019 Comment
David McCann, Chief Technology Officer Abrigo Austin, TX 06/14/2019 Comment
Michael Emancipator, Vice President, Regulatory Counsel Independent Community Bankers of America Washington, DC 06/13/2019 Comment
Jake Schild, Content Curator & Editor Sunrise Banks St. Paul MN 06/12/2019 Comment
Jackson Mueller, Associate Director

Dan Murphy, Senior Associate

Michael S. Piwowar, Executive Director
Milken Institute Washington, DC 06/11/2019 Comment
Adam Hoehn Alliance Partners Chevy Chase, MD 06/05/2019 Comment
Thomas W. Lynn     05/01/2019 Comment