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The District of Columbia Continues to Fight the “True Lender” Rule in Court

April 19, 2021 By Kelley Barnaby and Anne Martin

A&B ABstract: Innovative partnerships between banks and nonbanks have expanded lending services to consumers and small businesses. These partnerships, known as marketplace lending arrangements, offer non-traditional loan products to consumers and small businesses. Significantly, state laws establishing interest rate caps do not apply to marketplace lending arrangements where the bank is the true lender. But […]

Filed Under: Uncategorized Tagged With: #truelender

OCC’s Final “True Lender” Rule Takes Effect

December 27, 2020 By Stephen Ornstein

A&B ABstract: On October 27, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a noteworthy final rulemaking that sets forth when a national bank or federal savings association originates a loan and is deemed the “true lender” in the context of a partnership between a bank and a non-bank third party, known […]

Filed Under: State Law Tagged With: #marketplace, #truelender

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