CFPB Monitor

MAY 6, 2021

A Maryland administrative action recently removed to the state’s federal district court illustrates how Maryland law continues to present challenges for the bank partner structure used by many lenders. The new Maryland matter demonstrates that participants in bank model programs continue to face state licensing threats.

Maryland 78

Maryland Lending Missouri FDIC 78

CFPB Monitor

SEPTEMBER 10, 2020

The DBO indicated that it “is investigating whether LoanMart’s role in the arrangement is so extensive as to require compliance with California’s lending laws. While several states oppose the preemption of state usury laws in the context of bank/nonbank partnerships, federal banking regulators have taken a different stance.

Utah 78

Utah California FDIC West Virginia 78

CFPB Monitor

MARCH 15, 2022

The OCC’s attempt to provide a clear bright line test for determining when a bank is the “true lender” in a bank-model program through a regulation was overturned by Congress under the Congressional Review Act.) Maryland, New York, North Carolina, Ohio, Pennsylvania, West Virginia, and Colorado.

California 78

California Innovation Utah West Virginia 78

PYMNTS

FEBRUARY 14, 2019

That’s because it marked the first hearing dedicated to a proposed bill in Congress that would offer financial institutions protections against federal regulators when dealing with legal cannabis operations. The bill would prevent federal regulators from targeting banks that accept deposits from legal cannabis operators. Cash Dangers.

Oregon 230

Oregon Colorado Operations Washington 230

PYMNTS

FEBRUARY 13, 2019

That’s because it marked the first hearing dedicated to a proposed bill in Congress that would offer financial institutions protections against federal regulators if dealing with legal cannabis operations. The bill would prevent federal regulators from targeting banks that accept deposits from legal cannabis operators. Cash Dangers.

Oregon 115

Oregon Colorado Operations Washington 115