Banking
Oct. 12, 2020
The ‘true lender’ rule and the battle over the bank partnership model
The Office of the Comptroller of the Currency recently issued a proposed rule clarifying when a national bank is the ”true lender” of a loan, and which provides much-needed guidance for banks and fintech lenders that offer loans through partnership models.
Salwa Kamal
Attorney
McGuireWoods LLP
Salwa focuses her practice on consumer financial litigation for a range of bank and auto lender clients.
Alexander Gershen
Alexander focuses his practice on consumer financial litigation and fintech product counseling.
Carolee Hoover
Partner
McGuireWoods LLP
Carolee focuses her practice on consumer class action litigation for clients ranging from national banks to fintech companies.
On July 22, the Office of the Comptroller of the Currency issued a proposed rule clarifying when a national bank is the ”true lender” of a loan, and which provides much-needed guidance for banks and fintech lenders that offer loans through partnership models. Along with its recent “valid-when-made” rule, the “true lender” rule is another step streamlining regulations for national banks and loans originated by them, while simultaneously expanding the OCC’s supervisory ...
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