True Lender Update: States vs. OCC; No FDIC Rule; Possible State True Lender Rules?
By EsqSocial Corporation 15/01/21
In recent months, we’ve provided several updates on “True Lender” and “Valid When Made” developments from the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and state litigation. For national banks, the OCC’s True Lender rule became effective on December 29, 2020. However, as expected, the Attorneys General of New York, California, Colorado, the District of Columbia, Massachusetts, Minnesota, New Jersey, and North Carolina (the States) filed a...
By: McGlinchey Stafford