OCC Finalizes Bright-Line “True Lender” Rule
By EsqSocial Corporation 29/10/20
On October 27, the Office of the Comptroller of the Currency (OCC) issued its final rule on how to determine when a national bank or federal savings association (referred to collectively as a national bank) is the “true lender” in the context of a partnership between a national bank and a third party. The final rule follows the OCC’s proposed rulemaking on July 22 with little deviation, establishing that when a national bank makes a loan, it is the true lender if, as of the date of origination,...
By: Troutman Pepper