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42 CREDIT UNIONS SUPPORT OCC'S FINTECH PROPOSAL, SORT OF e National Association of Federally- Insured Credit Unions is coming out in support—at least in part—of the OCC's recent proposal to afford special purpose national bank charters to FinTech companies. In a letter to the Office of the Comptroller of the Currency (OCC), NAFCU Regulatory Affairs Counsel Andrew Morris said that, while the organization is behind the OCC's recently proposed initiative to allow FinTechs to operate as banks, it also believes these companies need regulation and supervision. And, in particular, they should be held to the same standards of already existing banks and credit unions. "Innovation in financial services and technology contributes to the growth of the entire financial sector," Morris wrote. "However, NAFCU believes that FinTech companies require a minimum level of regulation and supervision to ensure fair competition and consumer protection … NAFCU also believes that chartered FinTech companies should be held to the same consumer protection laws as chartered banks and credit unions and that the OCC should only deviate from such uniformity in extraordinary circumstances." Morris also called attention to the issues of cybersecurity with FinTechs. "Fintech companies stand to play a vital role in the financial sector," Morris wrote, "and their cybersecurity security standards should reflect the increased risk of handling and processing large volumes of financial data online. If FinTech companies are to be entrusted with aggregating millions of consumer records and information— both financial and non-financial in some instances—then they should be held to the same high standards as banks and credit unions of similar size and complexity." Overall, the move to offer special purpose charters to FinTechs is only the first step of many in expanding the lending market. In the future, other nonbank entities may also be granted charter eligibility, and when this occurs, it will be important to ensure a level playing field for all financial institutions, Morris said. "As the OCC begins to identify requirements for prospective charter applicants," Morris wrote, "it should ensure that online lenders, aggregators, and other non bank entities that seek the benefits of a charter are generally held to the same consumer protect and data standards as banks and credit unions." e OCC proposed allowing special purpose bank charters for FinTech firms in late November 2016. In his announcement, Comptroller of the Currency omas Curry said doing so was in the overall public interest. "FinTech companies hold great potential to expand financial inclusion, empower consumers, and help families and businesses take more control of their financial matters," Curry said. "FinTechs, while not without some risks, also can potentially deliver these products and services in a safer and more efficient manner. Preferences and needs of consumers, communities, and business are changing. And chartering companies that are finding new and better ways of satisfying those needs is another step toward supporting responsible innovation that is good for consumers, good for the federal banking system, and good for the country." DIAGNOSING THE HEALTH OF HOUSING MARKETS e top 10 healthiest housing markets in the United States, according to software and data solutions provider SmartAsset, beginning with the number one region, are: Edgewood, Kentucky; Mesquite, Texas; Northridge, Ohio; Concord, Missouri; Jenison, Michigan; Bethel Park, Pennsylvania; Forest Hills, Michigan; Richland, Washington; Pearl City, Hawaii; and Clawson, Michigan. Michigan was the only state to have more than one city in the top 10. Furthermore, according to a report by Trulia, Detroit had the largest year-over-year increase in the amount of homes that were flipped relative to the total number of homes sold, rising from 1.2 percent in 2015 to 6 percent in 2016. e current figure is the highest that has been seen since 2000. e rankings for healthy markets are determined by: stability, affordability, fluidity, and risk of loss. Stability was gauged based upon two equally-weighted measures: the number of years residents typically stayed in their homes and the percentage of homeowners who had negative equity and, therefore, a higher risk of foreclosure. e company measured affordability by calculating the percentage of household income which was reserved for paying the monthly costs of the household. Housing market fluidity for each region was measured by examining the length of time a home was on the market before being sold. Risk was determined by assessing the percentage of homes that decreased in value. For the overall measurement of market health, 40 percent of the weight was attributed to affordability, while all other factors received a weight of 20 percent each. e city with the highest fluidity, or the quickest turnaround time from when a house was listed on the market to when it was sold, was Pella, Iowa, with the average home staying on the market for only 4.3 days before being sold. West Allis, Wisconsin came in second, with homes staying on the market for an average of 5.5 days. e average household fluidity for the entire U.S. is 169.6 days.

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