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OCC Issues Proposed Rule Clarifying the ‘True Lender’ in Bank/Nonbank Lending Partnerships

USA - July 20 2020 On July 20, 2020, the Office of the Comptroller of the Currency ("OCC") proposed a rule that would that would clarify that a national bank or…

Nicholas A. Wilson

Summary of Final Volcker 2.0 for Fund Activities

USA - June 25 2020 On June 25, 2020, the Federal Reserve Board, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the U.S…

Nicholas A. Wilson

Agencies Approve Volcker 2.0 for Fund Activities

USA - June 25 2020 On June 25, 2020, the Federal Reserve Board (“Fed”), the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the U.S…

Nicholas A. Wilson

FDIC Finalizes Rule Clarifying Validity of Interest Rates on Assigned Bank Loans Following Second Circuit Ruling in Madden v. Midland Funding LLC

USA - June 25 2020 On June 25, 2020, the Federal Deposit Insurance Corporation (“FDIC”) finalized a rule to clarify that when state-chartered banks sell, assign or…

Nicholas A. Wilson

OCC’s Brooks Indicates National Payments Charter to Be Offered Later This Year

USA - June 24 2020 In the June 24, 2020 episode of the American Bankers Association's Banking Journal Podcast, Brian Brooks, Acting Comptroller of the Office of the…

Kara A. Kuchar, Adam J. Barazani, Donald J. Mosher