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August 3, 2020


Mr. Brian P. Brooks

Acting Comptroller of the Currency
Office of the Comptroller of the Currency
400 7th Street, S.W.
Washington, D.C. 20219

Re: National Bank and Federal Savings Association Digital Activities

Docket ID OCC-2019-0028

Dear Comptroller Brooks:

We greatly appreciate the dedication of the Office of the Comptroller of the Currency (OCC) to
support American competitiveness and innovation. Payments systems are changing, and the
technologies and processes that support the American financial system are quickly evolving to
take advantage of the enormous promise this brings for additional choice for consumers, both in
the United States and around the world. As such, we believe it is important for regulators to
respond to innovation with a nuanced, risk-based approach.

In order to maintain the country’s leadership position in financial services, which is facing
competition from other regions around the world, the United States must continue to support
innovation amongst its own companies and within its regulatory frameworks to keep its edge.
Innovation amongst existing and new entrants can help expand access and serve a larger
segment of citizens.

Novi Financial was founded with the mission of making payments work better for everyone. We
believe that national banks equally should have the ability to participate and compete in making
payments work better for everyone, whether using traditional payment methods, or cryptoassets
and distributed ledger technology.

National banks should also have the ability to use distributed ledger technology to perform
traditional banking functions such as custody, identity verification, payments processing and
trade finance. Further clarity on these points from a full rulemaking would benefit both national
banks and their customers.

We look forward to continued, meaningful engagement with the OCC and other policy
stakeholders through a robust and iterative conversation and consultation period for any
applicable rules and regulations.

At Novi, we believe that new innovations can provide more affordable and efficient means to
move value through our economy. To reach this goal, we have prioritized educating
stakeholders on how technologies such as distributed ledgers and stablecoins can work with,
and within, the financial services sector. We are encouraged by this request for comment from
the OCC. We look forward to the continued participation of industry and regulators to support
American innovation.

1601 Willow Road, Menlo Park, California 94025

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