Unlike denials (as received by Wise and Bunq) a return doesn’t come with a detailed explanation. The company didn’t publicly disclose the development when it happened, as it had with the submission of its application. And Zerohash hadn’t voluntarily withdrawn the filing, as was its option.
A spokesperson for the OCC didn’t immediately respond to questions about the application, and spokespeople for Morgan Stanley declined to comment.
Just a month before returning Zerohash’s effort, the regulator issued an explanation for how it makes such decisions, including its new approach to returning applications without registering a decision. The OCC will return a filing, the agency said, if it doesn’t contain necessary information on the company’s finances or officers. Or, it noted, “the OCC may return a filing as materially deficient if, after attempting to have the filer furnish all required information for the OCC to assess the statutory or regulatory criteria through an additional information request, the responses do not sufficiently respond to the requests.”
When the Independent Community Bankers of America filed an objection to the application in April, the community-bank group’s letter noted: “In less than twelve months the OCC has conditionally approved or received applications from Circle Internet Group, Ripple, Paxos Trust, BitGo, Fidelity Digital Assets, Crypto.com, Payoneer (PAYO), and now Zerohash. This pace — eleven filings or approvals in under one hundred days in some windows — precludes deliberate, transparent policymaking.”