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Comments due: OCC (proposed rule; ‘true lender’)

September 3

The Office of the Comptroller of the Currency (OCC) is proposing a regulation to determine when a national bank or Federal savings association (bank) makes a loan and is the “true lender” in the context of a partnership between a bank and a third party, such as a marketplace lender. Under this proposal, a bank makes a loan if, as of the date of origination, it is named as the lender in the loan agreement or funds the loan.

Reg lookup: National Banks and Federal Savings Associations as Lenders


September 3
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