Line In The Sand: OCC Issues Final Rule Adopting Bright-Line “True Lender” Standard

Capping off months of proposed rules and settlements addressing marketplace lending issues, on October 27, 2020, the Office of the Comptroller of the Currency (OCC) finalized a rule specifying that a national bank or federal savings association (collectively, “banks”) will be considered the “true lender” of a loan originated in connection with a lending partnership between the bank and a non-bank service provider if, as of the date the loan is originated, the bank is named as the lender in the...
By: Morrison & Foerster LLP

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