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The issue with using a bank charter to service a product like ODC and New Logic is that those companies are now subject to regulatory review. The OCC and state bank regulators have, by extension, the right to review, audit and inspect any 3rd party relationships. So in theory the OCC could go to CAN or ODC offices for an audit. The regulatory bodies also have the right to tell the bank to terminate any 3rd party relationships at their discretion.

Great point JB