Brooks’s appointment as the acting head of the OCC in 2020 was a significant moment for financial innovation. The OCC plays a pivotal role in regulating national banks and federal savings associations in the United States. During his tenure, Brooks actively championed the use of fintech and blockchain technology in the banking sector. He introduced regulatory initiatives that provided banks with the green light to offer cryptocurrency custody services and stablecoin payment systems, a move seen as groundbreaking in the financial industry.

One of Brooks’s key initiatives at the OCC was the creation of the Special Purpose Payments Charter, which aimed to provide a regulatory framework for fintech companies to operate as banks. This initiative signified a major shift in the way traditional banks and fintech firms are regulated, acknowledging the transformative role of technology in financial services. Brooks’s emphasis on fostering innovation and competition in the banking industry was well-received by many in the fintech community.

In addition to his work on cryptocurrencies and fintech, Brooks also addressed the need for modernizing Community Reinvestment Act (CRA) regulations. The CRA, originally enacted in 1977, encourages banks to meet the credit needs of the communities they serve. Brooks sought to bring CRA regulations in line with the digital age, recognizing that financial services were increasingly delivered online, and traditional CRA evaluations needed to adapt.

While his tenure as acting head of the OCC was marked by progressive regulatory reforms, Brooks’s departure from the agency in early 2021 was met with mixed reactions. Some praised his proactive approach to financial innovation, while others expressed concerns about the potential risks associated with rapid changes in the industry.