Congress has voted to overturn the Office of the Comptroller of the Currency’s (“OCC’s”) “true lender” rule under the Congressional Review Act (“CRA”), and the President has signed the resolution. Repeal of the “true lender” rule under the CRA prevents the OCC from issuing any substantially similar rule unless authorized by law to do so.
The True Lender Rule, which became effective December 29, 2020, provided that a bank would be deemed to have made a loan if, on the date of its origination, the bank either (1) is named as the lender in the loan agreement, or (2) funds ...
About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
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MVA White Collar Defense, Investigations, and Regulatory Advice Blog Updates
- John Fagg and Jim McLoughlin commentary featured in Lawdragon: White Collar Enforcement Under the Biden Administration
- LEGAL ALERT Re: Consumer Financial Protection Bureau’s Small Business Lending Data Collection under the Equal Credit Opportunity Act
- Federal Reserve Board Issues Denial to Custodia Bank
- States Look to Impose Financing Disclosure Requirements on Commercial Loans and the CFPB Considers Potential TILA Preemption Considerations