Did You Know About the Finder Rule? by Mary Beth Guard
Under the so-called "finder rule", a national bank can act as a "finder" to bring together buyers and sellers. As noted by OCC General Counsel Julie Williams in a recent speech, advances in technology have allowed banks to use their finder authority on a much broader scale, to do things like establish electronic marketplaces on the Internet. Because the finder authority is not limited to provision of financial products and services, these activities could pertain to transactions involving anything. Break out of your normal compliance officer "you can't do this; you've got to do that" mold and demonstrate your compliance expertise instead by offering suggestions about how your bank could deploy the finder rule authority to tap new sources of fee income!
State-chartered banks aren't left out either. Contact your regulator to see if the wildcard statute (a provision in the law that, to some extent, allows state banks to exercise powers granted to national banks) would allow you to engage in finder activities.
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