Analysis

OCC's 'True Lender' Plan Draws States' Ire, Industry Angst

Law360 (September 11, 2020, 11:35 PM EDT) -- The Office of the Comptroller of the Currency's draft "true lender" rule governing bank financing partnerships is likely to face challenges from states and consumer advocates if it advances as written, and it may also throw a wrench into financing arrangements used by car dealerships and mortgage lenders, according to experts and public feedback on the plan.

In comments made public over the past week, state attorneys general, consumer advocacy organizations, industry groups and others weighed in on the OCC's proposal to establish a simple test for determining who legally qualifies as the true lender when a federally chartered bank partners...

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