In comments to the Office of the Comptroller of the Currency (OCC), National Consumer Law Center, on behalf of its low-income clients, Consumer Federation of America, Consumers Union, Main Street Alliance, and U.S. PIRG are calling on the OCC to withdraw its proposal to issue a special national charter for non-bank lenders. The OCC's white paper Exploring Special Purpose National Bank Charters for Fintech Companies proposes to create a new class of "national banks" for the purposes of financial innovation. However, not only does the OCC lack the authority to create this new class of "national banks," but companies which fall into this category would be able to state interest rate caps, state consumer protection laws, and state oversight to the great detriment of consumers.