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ARTICLE · 30 OCTOBER 2020

A Close Look At The OCC's "True Lender" Proposal

Ballard Spahr LLP
Ballard Spahr LLP
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Ballard Spahr LLP

Ballard Spahr LLP

Ballard Spahr LLP, an AmLaw 100 law firm with 19 US offices, serves clients in more than 50...

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After reviewing the legal foundation for federal preemption of state law limits on interest, we discuss the OCC's proposed approach for determining when a bank is the "true lender" in programs with non-bank agents, ...

United StatesFinance and Banking

After reviewing the legal foundation for federal preemption of state law limits on interest, we discuss the OCC's proposed approach for determining when a bank is the "true lender" in programs with non-bank agents, our arguments in support of the proposal made in our comment letter to the OCC, key arguments made in support of or against the proposal by other commenters, the OCC's likely next steps, and the 2020 election's potential impact.

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